1 Central Texas Drones

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DEANS CONSULTING LLC

DBA; CENTRAL TEXAS DRONES

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIRMENTS 

OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121;

91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Submitted on April 30, 2015

By,

John David Deans

DEANS CONSULTING LLC

DBA, CENTRAL TEXAS DRONES

979.203.1534
2 Central Texas Drones

Table of Contents

Contents

SUMMARY.....................................................................................................................................................3

INTRODUCTION TO PETITIONER ...................................................................................................................3

The UAV PHANTOM II VISION PLUS..............................................................................................................3

BASIS FOR PETITION......................................................................................................................................4

A. Name and Address of The Petitioner....................................................................................................4

B. DEANS CONSULTING LLC Requests Relief from the Following Sections of 14 C.F.R.............................5

C. The Extent Of Relief That DEANS CONSULTING LLC Seeks...................................................................9

D. THE REASONS WHY GRANTING THE EXEMPTION WOULD BE IN THE PUBLICS INTEREST .................12

E. The Reason Why Granting The Exemption Would Not Adversely Affect Safety. ...............................13

F. Additional Information........................................................................................................................13

G. Summary to be Printed in Federal Register .......................................................................................15

CONCLUSION...............................................................................................................................................15
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SUMMARY 

DEANS CONSULTING LLC, which is Doing Business As (DBA) CENTRAL 

TEXAS DRONES, seeks exemptions from Title 14, Code of Federal Regulations 

§§ 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 

(a)(1), 91.409 (a)(1) and (2), 91.417 (a) and (b) to operate a DJI PHANTOM II 

VISION PLUS VISON PLUS UAS. This exemption will allow DEANS 

CONSULTING LLC to operate an Unmanned Aerial Vehicle commercially for the 

purpose of conducting aerial videography and photography in the real estate and 

construction markets of Central and Southeast Texas. These images and videos 

will provide community awareness and geospatial understanding. 

INTRODUCTION TO PETITIONER 

DEANS CONSULTING LLC, is a consulting company serving the Information 

Technology (IT) needs of real estate clients which require the ability to produce 

high definition video and photos of rural properties in central Texas via UASbased aerial photography. DEANS CONSULTING LLC seeks relief to use a 

Phantom II Vision Plus quad-copter to commercially capture video of listings 

while working on private property. DEANS CONSULTING LLC will utilize a 

Visual Observer (V.O.) while maintaining Visual Line of Sight (V.L.O.S.) between 

the quad-copter and a UAV operator who will have a current private pilot’s 

license. 

The UAV PHANTOM II VISION PLUS 

The DJI PHANTOM II VISION PLUS VISON PLUS is a quad-rotor Unmanned 

Aircraft System (UAS) weighing less than 3 pounds. The Phantom II Vision Plus 

UAS that DEANS CONSULTING LLC will be responsible for also utilizes a 

mobile ground station. The UAS features a safety Return to Home function that in 

the event of a signal loss, the UAS will return to a preset position and land. The 

Return to Home feature can also be triggered manually. PHANTOM 2 VISION 

PLUS uses a 5.8GHz RC system. To avoid communication interference, DEANS 

CONSULTING LLC will not use other 5.8GHz devices (including 2.4G Wi-Fi or 

2.4G wireless video transmission module) except the 2.4G Bluetooth and 2.4G 

Datalink. The Phantom II Vision Plus can fly at approximately 30kts. CENTRAL 

TEXAS DRONES has no need to operate at a speed greater than 10kts. The 
4 Central Texas Drones

Phantom II Vision Plus is powered by a single Lipo battery. This battery gives the 

Phantom II Vision Plus an approximate 15 minutes worth of flight time with its 

attached payload of the integrated DJI camera and the associated gimbal that 

connects the camera to the quad-copter. 

BASIS FOR PETITION 

DEANS CONSULTING LLC pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to operate the DJI PHANTOM II VISION PLUS UAS 

within the National Airspace System, and for an exemption from the requirements 

of 14 C.F.R. §§ 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 

91.407 (a)(1), 91.409 (a)(1) and (2), 91.417 (a) and (b). 

A. Name and Address of The Petitioner 

DEANS CONSULTING LLC

6206 Ganske Road

Burton, TX 77835

deansconsulting@gmail.com

979.203.1534
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B. DEANS CONSULTING LLC Requests Relief from the Following Sections of 14 

C.F.R. 

1. Sections 61.113, entitled Private pilot privileges and limitations: Pilot in 

Command, Subsections (a) and (b) prescribed the following, in part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if –

(1) The flight is only incidental to that business or employment and 

(2) The aircraft does not carry passengers or property for 

compensation or hire. 

2. Section 91.7, entitled Civil airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy 

condition. 

3. Section 91.119, entitled Minimum Safe Altitudes: General 

Except when necessary for takeoff or landing, no person may operate an

aircraft below the following altitudes: 

(a) Anywhere, An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. 

(b) Over congested areas. An altitude of 1000 feet above the highest obstacle 

within a horizontal radius of 2000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the 

surface—
6 Central Texas Drones

(1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person 

operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-Shift-Control aircraft may be 

operated at less than the minimums prescribed in paragraph © of this 

section. 

4. Section 91.121, entitled Altimeter Settings, subsection (a), states the following, 

in relevant part: 

(a) Each person operating an aircraft shall maintain the cruising altitude of 

flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the 

route and within 100 nautical miles of the aircraft; 

(ii) If there is not station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of 

an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the 

elevation of the departure airport or an appropriate altimeter 

setting available before departure; 

5. Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection (b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 20 minutes. 

6. Section 91.405, entitled Maintenance required, subsection (a) stated the 

following: 

Each Owner or Operator of an Aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part 

and shall between required inspection, except as provided in 
7 Central Texas Drones

paragraph (c) of this section, have discrepancies repaired as prescribed in 

part 43 of this chapter. 

7. Section 91.407(a)(1), entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsections (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized 

under §43.7 of this chapter. 

8. Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may 

operate an aircraft unless, within the preceding 12 calendar months, it has 

had—

(1) An annual inspection in accordance with part 43 of this chapter 

and has been approved for return to service by a person authorized by 

§ 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

9. Section 91.417, entitled Maintenance Records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—
8 Central Texas Drones

(i) A description (or reference to data acceptable to the Administrator) 

or the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the 

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the net 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed engines,

rotors, propellers, and appliances. 

a. The Owner or operator shall retain the following records for 

the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this 

section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this 

sections shall be retained and transferred with the aircraft 

at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or

operator under § 43.11 of this chapter shall be retained 

until the defects are repaired and the aircraft is approved 

for return to service. 
9 Central Texas Drones

C. The Extent Of Relief That DEANS CONSULTING LLC Seeks 

1. Extent of Relief that DEANS CONSULTING LLC Seeks Regarding 

Section 61.113 (a) and (b) Private Pilot Privileges and Limitations 

Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command 

holding a current Private Pilots Certificate to operate the Central Texas Drones

Phantom II Vision Plus The flight would be complimented by a Visual Observer 

who, along with the pilot, will maintain Visual Line of Sight with the Phantom II 

Vision Plus at all times. All operations conducted will be incidental to Central 

Texas Drones’ business. The Phantom II Vision Plus is not able to carry 

passengers. 

2. Extent of Relief that Central Texas Drones seeks in Regards to Section 91.7(a) 

Civil Aircraft Airworthiness 

Relief from Section 91.7(a) is requested to allow Central Texas Drones to 

determine airworthiness of the Phantom II Vision Plus As part of this 

determination the following will be adhered to: 

a. Prior to the Phantom II Vision Plus’ flight the PIC will inspect the UA to 

ensure it is in a condition that will be conducive for a safe flight. The ground 

control station will be included in the above inspection. 

b. Central Texas Drones will follow the DJI Phantom II Vision Plus’

aircraft/component, maintenance, overhaul, replacement, inspection and life 

limit requirements. 

c. Central Texas Drones will comply with all DJI manufacturer Safety 

Bulletins. 
10 Central Texas Drones

3. Extent of Relief that Central Texas Drones seeks in Regards to Section 91.119 

Minimum Safe Altitudes General

Relief from 91.119 is requested to allow Central Texas Drones to operate the 

Phantom II Vision Plus at altitudes not to exceed 400’ AGL over private property 

at a distance at or greater than 5NM from the nearest airport as depicted on current 

Aeronautical Charts. Central Texas Drones also wishes to be granted exemption to 

operate at an altitude not greater than 50’ AGL (below tree level) between 1NM 

and 5NM from the nearest airport as depicted on current Aeronautical Charts. 

Central Texas Drones will adhere to the following in order to maintain an 

acceptable level of safety associated with operations over private property:

(a) Central Texas Drones will display signs in the immediate vicinity of 

operations stating: “Aerial Photography In Progress. Use Caution.” 

(b) Central Texas Drones will not allow the Phantom II Vision Plus to 

operate at a speed greater than 10kts. 

(c) Central Texas Drones will require the UAS operator (PIC) to be fully 

trained on the Phantom II Vision Plus by adhering to the recommendations 

contained within the Phantom II’s operating manual. 

(d) Central Texas Drones’ UAS operator (PIC) will have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 

hours of total time as a UAS rotorcraft pilot including at least 10 hours 

logged as a UAS pilot with a multi-rotor UAS. In addition the operator will 

have logged a minimum of 5 hours as a UAS pilot operating the make and 

model UAS that Central Texas Drones operates. 

(e) Central Texas Drones’ UAS operator (PIC) will be familiar with and able 

to manually institute the Phantom II’s Return to Home (RTH) feature. This 

feature aborts a flight operation and automatically returns the UAS to a 

predetermined GPS safe point. 

(f) Central Texas Drones’ UAS operator (PIC) will not operate over private 

property without first finding a suitable alternate landing spot on the 

property. 

(g) Central Texas Drones’ UAS operator (PIC) will abort the flight in the 

event of unpredicted obstacles or emergencies in accordance with the 

operating documents. 
11 Central Texas Drones

(h) Central Texas Drones will utilize a two man flight team consisting of the 

Pilot in Command (PIC) and a Visual Observer (VO). This team will 

maintain visual line of sight with the Phantom II Vision Plus at all times and 

remain within hearing of one another. 

(i) Central Texas Drones will not permit flight around vessels, vehicles and 

structures without permission from the owner. 

4. Extent of Relief that Central Texas Drones Seeks in Regards to Section 91.121 

Altimeter Settings 

Relief from 91.121 is requested because the Phantom II Vision Plus utilizes 

electronic GPS with a barometric sensor. 

In order to maintain an equal level of safety that 91.121 requires, the PIC of the 

Central Texas Drones UAS will abort the flight in the events that the UA loses 

communications with the GPS signal. 

5. Extent of Relief that Central Texas Drones Seeks in Regards to Section 

91.151(b) Fuel Requirements for Flight in VFR Conditions 

Relief from 91.151(b) is requested to the extent that allows Central Texas Drones

to operate the Phantom II Vision Plus up to a point (considering wind and forecast 

weather conditions) that there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 40% battery power remaining. 

6. Extent of Relief that Central Texas Drones Seeks in Regards to Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) These are all 

associated a with Airworthiness certificate 

Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is requested 

to the extent that allows Central Texas Drones to operate the Phantom II Vision 

Plus Quad-Copter as necessary. These sections are all related to airworthiness 

certificates of aircraft. There is not currently an airworthiness certificate for small 

UAS’s. Central Texas Drones would comply in full to any conditions and 

limitations that the Administrator would place in order to receive an approved 

Grant of Exemption. 
12 Central Texas Drones

D. THE REASONS WHY GRANTING THE EXEMPTION WOULD BE IN THE 

PUBLICS INTEREST 

1) Aerial photography lends a unique perspective to the viewer. The angles 

of capture show areas that are not able to be seen by an earthbound 

photographer. This type of photography has been used for some time by real 

estate agencies and construction firms. Unfortunately though, it is often cost 

prohibitive for small business. The expensive fees demanded by traditional 

aerial photography outfits have often given large firms an advantage. With a 

Grant of Exemption from the Administrator, Central Texas Drones can be of 

immense benefit to small business by providing affordable aerial 

photography. 

2) The granted use of aerial photography by Central Texas Drones would 

assist the public by allowing them to form a geospatial perspective and 

academic understanding of the area surrounding the subject of their interests. 

This would certainly help the clients of Central Texas Drones garner 

business and therefor would directly have a positive effect upon the 

economy. 

3) The risk associated with UAS aerial photography is less than the risk 

associated with traditional aerial photography. The UAS that Central Texas 

Drones incorporates weighs less than 3lbs. This UAS is also fueled by a 

single battery. The amount of damage that may occur in the event of an 

incident or accident is substantially less than that which may occur in the 

event of an incident or accident involving the traditional form of aerial 

photography. Traditional aerial real estate photographers rely upon full size 

aircraft operating at low altitudes and with a full load of combustible fuel. 

Responsible UAS operations are inherently in the public’s interest. 
13 Central Texas Drones

E. The Reason Why Granting The Exemption Would Not Adversely Affect 

Safety. 

Central Texas Drones’ high level of professionalism and desire to set the standard 

for successful and safe UAS real estate operations squarely coalesces with the 

FAA’s safety mission. In addition, Central Texas Drones will strictly follow the 

conditions and limitations of the FAA Grant. Some procedures that Central Texas 

Drones has in place include: 

a) Standard Operating Procedures (SOP); which will include a pre-flight 

checklist, airworthiness inspection by the Pilot in Command, signage 

depicting a notice of aerial photography in progress, and NOTAMS issued 

48 hours in advance of a flight. 

b) During flight operations, Central Texas Drones will utilize a two person 

team consisting of the Pilot in Command and a Visual Observer. All 

operations will remain within line of sight of the UAS team. 

c) The UAS will at all times have the GPS Return to Home safety feature 

activated. In the event of a “loss of signal” or if the Pilot in Command deems 

it necessary the UAS will return to a preset position and land. 

d) In the event that the aerial photography safety zone is violated, the Pilot in 

Command will abort the mission and return to the safe landing zone. 

e) Central Texas Drones will only operate the UAS over private property 

with the permission of the property owner and will stay a safe distance away 

from vehicles, structures and people. 

f) As Federal guidelines are developed, Central Texas Drones will stay up to 

date and within compliance of all changes. 

F. Additional Information 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. Central Texas Drones commitment to 

being at the forefront of the rapidly emerging UAS commercial use sector is 

second only to their commitment to operating responsibly. Central Texas Drones 

owner, John David Deans, holds a private single engine land certificate and will be 

the primary Pilot in Command of the Phantom II Vision Plus UAS that Central 
14 Central Texas Drones

Texas Drones will use in the Real Estate/Construction markets. This added 

investment of not only being the Pilot in Command but also the owner of the 

company, gives Central Texas Drones a commitment to safety and excellence that 

will lead it to becoming the flag bearer for small business UAS use. 

Central Texas Drones will obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any operations 

under this grant of exemption. 

All aircraft operated by Central Texas Drones, in accordance with this exemption, 

will be identified by serial number and registered in accordance with 14 CFR part 

47. CENTRAL TEXAS DRONES will comply with making November markings 

in accordance with 14 CFR part 45, Subpart C. The November markings placed 

upon the Central Texas Drones Phantom II Vision Plus UAS will be as large as 

practical. 

Attached are the Operating Manual and Quick Start Manual that are used in 

conjunction with the Central Texas Drones Standard Operating Procedures. 
15 Central Texas Drones

G. Summary to be Printed in Federal Register 

DEANS CONSULTING LLC requests exemption from TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 

(c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 

(a) and (b). CENTRAL TEXAS DRONES requests relief from these sections from 

the FAA Administrator per the intentions of the FAA Moderation and Reform Act 

of 2012 so that DEANS CONSULTING LLC can produce photography and video 

for clients within the real estate and construction markets. 

CONCLUSION 

As set forth herein, DEANS CONSULTING LLC seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the DJI PHANTOM II VISION PLUS UAS 

commercially within the Real Estate and Construction markets. The Administrator 

will be assisting small business by granting this petition. In accordance with the 

FAA Modernization and Reform Act of 2012, CENTRAL TEXAS DRONES respectfully 

requests that the FAA Administrator grants this petition for exemption from TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 

91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 

91.417 (a) and (b) 

If there are any areas that have not been addressed, please contact me for 

supplemental information.

John David Deans

DEANS CONSULTING LLC 

6206 Ganske Road

Burton, TX 77835

deansconsulting@gmail.com

979.203.1534