.PEOPLES'" 

COMPANY 

INNOVATIVE. REAL ESTATE. SOUJTIONS.. 

US Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

December 18, 2015 

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RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 

C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b); 91.103(b); 91.109; 91.119; 91.121; 

91.151 (a); 91.203(a) & (b); 91.405(a); 91.407(a)(1 ); 91.409; 91.417(a) & (b) 

Ladies and Gentlemen: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Peoples Company, a real estate company and 

operator of a small "quadcopter" (UAS) equipped for photos and videos of properties 

primarily in the State of Iowa, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FARs") to allow commercial operation of its UASs, so long as 

such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

The purpose of proposed flights are to provide photos and videos of real estate 

offered for auction and for sale and to provide photos and videos to assist in property 

management, real estate appraisal, development and construction. 

The name and address of the applicant is: 

Peoples Company of Indianola 

ATTN: Alan McNeil 

700 6th Avenue 

DeWitt, Iowa 527 42 

Telephone No. 563.659.8185 

Email: alan@totalrealtyco.com 
US Department of Transportation 

December 18, 2015 

Page2 

The UAS and flights 

The UAS is a 2.8 lb battery powered quadcopter (four motors, four blades), a 

handheld remote controller for control, associated control receivers on the aircraft, 

camera gimbal with Sony EXMOR 1/2.3" Effective Pixels: 12.4M (total pixels: 12.76M) 

and video transmitter to a small 2.5" x 5" screen for camera shot placement only (UAS 

is controlled only by line of sight). The aircraft is equipped with a flight controller on 

board the UAS. The controller offers the following: 

1. GPS Assisted Flight- GPS allows the quadcopter to hover when no 

commands are being sent. 

2. Non-GPS Modes - If GPS signals are lost or unavailable the aircraft uses 

P-OPTI or P-ATTI to monitor the altitude and provide control assistance to 

help keep the aircraft stable and under control. 

3. Return to Home - Allows the quadcopter to return to home and land when 

battery power is low or "fail safe" button is pushed on the transmitter. This 

is beneficial if the pilot becomes disoriented or there are battery issues. 

4. The remote controller comes with preprogrammed flight limitations, 

including height limits, distance limits, and no fly zones. These function 

concurrently to manage flight safety. The quad copter is preprogrammed 

to not operate in a no fly zone or immediately land if a no fly zone has 

been entered. 

5. Aircraft status indicators - Give the user the status of the aircraft 

throughout different sequences of blinking lights and/or alarms. 

The Phantom 3 Professional Quick Start Guide and User Manual are included for 

review with this packet. 

The UAS also has front LEOs and aircraft status indicators. The LEOs are used 

for orientation and location of the aircraft from the line of sight. The aircraft status 

indicators are used to confirm the operation of the aircraft. 

The remote control transmitter offers full telemetry showing altitude (with preset alarms 

of altitude and warnings when approaching 400' agl), as well as warnings for low 

voltage and signal strength, emergency return to home programmed fail safe and 

emergency return to home button. 
US Department of Transportation 

December 18,2015 

Page 3 

The video transmitter receiver operates at 2.400 Ghz-2.483 Ghz. We understand 

it is legal to operate this without any additional licenses. If we are incorrect, we will 

immediately apply for all necessary licenses or change to a different frequency. (Photos 

are included as Exhibit "A"). 

The UAS will be flown with a pilot in command (PIC) and a ground based visual 

observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions: 

• All operations will occur in Class G airspace at no more than 400' AGL. 

The vast majority of flights will be well below this limit at an average of 

150' 200' AGL to accomplish the best photographs and videos. 

• Any required permits will be obtained from local and state governments 

before flights. 

• The aircraft will not operate directly above human beings at any time or 

within 150 feet of human beings. 

• Maximum Flight Time will be 15 minutes. The battery allows 20 plus 

minutes of flight time. Batteries are inspected and always fully charged 

before use. 

• The aircraft will not operate within 5 miles of an airport/heliport without 

prior approval from said airport/heliport. 

• All operations will be during the daytime and in ideal weather conditions of 

less than 15mph winds and clear skies. 

• Aircraft will remain in visual line of site at all times not to exceed % mile 

from PIC. 

• Visual Observer will serve as additional eyes on the aircraft and be within 

voice reach to communicate with the PIC. 

• Aircraft will not fly in the area of any full scale aircraft and if a full scale 

aircraft comes into airspace during the aircraft's flight, it will be landed 

immediately to allow right of way to full scale aircraft. 

• At any time aircraft is being flown, signs will be posted in at least three (3) 

locations, warning of UAS operations are being conducted and to stay at 

least 200' away at all times of landing and takeoff area (marked with a 

large orange cone). 

• The PIC, Jared Chambers, has flown remote aircraft for 1.5 years. This 

has been exclusively multi-rotor types such as the DJI Phantom 

(quadcopter). There have been no incidents of injury or property damage. 
US Department of Transportation 

December 18, 2015 

Page4 

• The Applicant believes that a private pilot's license is not applicable to 

flying a UAS for several reasons (flight controls are different than a 

traditional aircraft and PIC holds a real estate license in the State of Iowa, 

and is a native born American which should satisfy any suspicions of 

being linked to Terrorism). Although the PIC will obtain a private pilot's 

license within 120 days of the exemption being granted if the FAA deems 

it is indeed required. If the FAA rules that a private pilot's license is not 

needed after granting the exemption and the PIC has not obtained a pilot's 

license at that time, then PIC would request permission to not obtain a 

private pilot's license. 

• The UAS will never be used as an invasion of privacy and will only be 

used for the purposes listed above. 

• Liability insurance will be maintained at all times. 

• Applicant's equipment is not inexpensive and Applicant takes public and 

property safety seriously. Applicant has developed pre-flight plans, flight 

plans and emergency procedures and maintenance procedures. 

Exemptions 

Exemption Request Section 333 of the FAA Reform Act & Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) & 

(b); 91.7(a); 91.9(b); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 

91.405(a); 91.407(a)(1); 91.409; 91.417(a) &(b) · 

14 C.F.R. Part 21, 45.29, 45.23: 

The aircraft has no area to display numbers or letters that are at least 2" in size. To 

Applicant's knowledge there is no Registration System for UAS. Applicant will place in 

the largest letters possible "Chambers Auction & Appraisal Company" on at least two 

"arms" of the craft. 

14. C.F.R. 91.7: 

To Applicant's knowledge there is no aircraft airworthiness certificates for UAS. 

Applicant will before each flight run through the enclosed pre-flight checklist to ensure 

airworthiness. 

14 C.F.R. 91.9(b) 

There is no cockpit to include said manual. Operating manual will be kept with PIC. 
US Department of Transportation 

December 18, 2015 

Page 5 

14 C.F.R. 91.103: 

Since there will not be a FAA approved quadcopter manual to be provided Applicant will 

need to be exempt. Applicant will again follow its enclosed pre-flight checklist to ensure 

safety and airworthiness. 

14 C.F.R. 91.109: 

UAS are controlled by a transmitter and do not have the capability for dual controls. It is 

Applicant's understanding there have been other aircraft approved without dual controls. 

14 C.F.R. 91.119: 

Since flights will never be above 400' AGL and usually 150' to 200' AGL, Applicant 

requests an exemption as the altitudes cited in 14 C.F.R. 91.119 would cause us to 

exceed said 400' AGL. 

14 C.F.R. 91.121: 

UAS does not have a traditional altimeter. It does however have a barometric type 

which displays the altitude on the transmitter of which is monitored at all times to 

prevent exceeding 400' AGL. There is a/so an alarm on the transmitter when reaching 

within 50' of 400' AGL. 

14 C.F.R. 91.151: 

The UAS does not use traditional fuel but rather battery power. The battery provides for 

up to 18 minutes plus of flight time with a 30% reserve of battery power. If this level is 

reached the UAS returns to home and lands. However, no flight will last longer than 15 

minutes as an extra safety precaution. 

All batteries are only used if freshly charged. All batteries are visually inspected and 

volt tested before each flight. 

14 C.F.R. 91.203: 

There is no cockpit to include said certificates or registration documents. Any 

certificates, exemptions or registration documents will be with the PIC on the ground 

level. 
US Department of Transportation 

December 18, 2015 

Page 6 

14 C.F.R. 91.405, 91.407, 91.409, 91.417: 

-

As there is no airworthiness inspections available Applicant requests an exemption. 

Again Applicant will perform pre-flight checklists to ensure safety. 

If Applicant's pre-flight checklist does not pass, the flight will be aborted. 

Any items of concern will promptly be repaired using similar components and records 

will be kept through maintenance records. 

Applicant is prepared to modify or amend any part of this petition for exemption 

to meet or exceed concerns of safety. Applicant does look forward to working with the 

FAA to provide a great service to its community and profession in a safe manner. Upon 

receipt of this request, please date stamp the additional copy of the first and last page of 

this letter and return it to me in the self addressed, stamped envelope also enclosed. 

Thank you in advance for your consideration of this request. 

Sincerely, 

Alan McNeil 

Peoples Company of Indianola 
UAV Pre-Flight/Flight Plan Checklist .PEOPLES'M 

COMPANY 

Date: INNOVA!'IVE. REAL ESTArE. SOLUTIONS 

---------------------

Name: Observer: -------------------------------------- ------------------------------ (Person in Control) 

Flight Location:-------------------------------

Weather Condition/Visibility/Wind Speed:-----------------------

BEFORE LOCATION 

Ensure Flight Location is not within 5 Miles of Airport/Heliport. If so, call airport/heliport for proper authority before 

flying. Record Contact Name, Phone, and Airport if approval is received 

Review Current Weather Conditions/Forecast as reported by the NWS 

Check all Battery Voltages/Condition- (if not charged, must charge before going to location) 

Inspect all wires, plugs, and solder connections 

AT LOCATION 

Check Battery Voltage and Visual Inspection of Battery 

Inspect Props on UAS for cracks, loose securing screws/bolts, proper rotation 

Visually Re-check Current Weather Conditions 

Site Survey -Identify any possible hazards such as phone poles, flag poles, utility wires, flocks of birds, traffic, large 

groups of people etc. 

Identify Takeoff and Landing Location (same location) 

Identify Vantage Points for PIC and Observer 

Ensure before motors are armed, no one is in hazard area 

DURING FLIGHT 

• Remain Alert for Possible Aircraft, Bystanders, or other hazards such as changing weather or birds 

• Fly only as high as needed for shot but never above 400' AGL 

• Every minute view telemetry data showing battery level and flight time (flights are 15 minutes max) 

LANDING 

• Ensure Landing Area is clear from hazards or bystanders 

• View Wind Direction and Compensate Flight if needed 

• Land Aircraft- Motors are shut off immediately after landing 

• Bystanders are not allowed to approach aircraft until battery has been disconnected 

EMERGENCY LANDING 

• Land immediately at a safe and close location when: 

o Other aircraft are spotted or heard (including other UAS) 

o Bystanders have gathered or a bystander has entered the proximity 

o Changes in weather or wind 

o Birds entering the area 

o Anything happens to distract pilot 

o If PIC feels uncomfortable for any reason 

Flight was performed to all flight plans and protocols contained herein: (sign below) 

12119 Stratford Drive, Suite B 

Clive, Iowa 50325 www. PeoplesCompany.com 855.800.LAND 
.PEOPLESTM 

COMPANY 

INNOVATIVL REAL BTATE. SOLUTIONS. 

Maintenance/Repair Report 

Date: -------

Person Performing Maintenance: 

Reason for Maintenance or Repair: 

Part(s) Being Replaced/Repaired (including any manufacturer information): 

After Maintenance/Repair: 

• Test Flight to be Performed in Ultra Safe Zone: 

o Location of Test:----------------------

0 Date:-------

• Tests to be Performed: 

o Low Hover, Low Flight Control Test (in all flight modes) 

o If Passed- 2"d Test Flight will be of a normal flight plan 

o Failure in either test flight will result in grounding of the aircraft until proper repair can be 

completed 

Sign: ______________________ (PIC) 

Sign:-------------------------(Observer) 

12119 Stratford Drive, Suite B 

Clive, Iowa 50325 www. PeoplesCompany.com 855.800.LAND 
DJI Phantom 3 Professional 

4K Camera 

On Front 

EXHIBIT 

A 
DJI Phantom 3 Professional 

Flight Control Transmitter 

Flight Control Transmitter 
DJI Phantom 3 Professional 

Removable Battery