# .PEOPLES'" COMPANY INNOVATIVE. REAL ESTATE. SOUJTIONS..

US Department ofTransportation Docket Management System 1200 NewJerseyAvenue SE Washington, DC 20590 December 18, 2015 ";{"' jJ l.; 

### l**~-**

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14C.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: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Peoples Company, a real estate company and operatorofa small "quadcopter" (UAS) equipped for photos and videos ofproperties 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 underthe conditions outlined herein oras may be established bythe FAA as required by Section 333. The purpose ofproposed 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 ofthe applicant is: Peoples Company of Indianola ATTN: Alan McNeil 700 6th Avenue DeWitt, Iowa 52742 Telephone No. 563.659.8185 Email: alan@totalrealtyco.comUS Department ofTransportation 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 controllerfor 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 transmitterto a small 2.5" x 5" screen forcamera shot placement only (UAS is controlled only by line ofsight). The aircraft is equipped with aflight controller on board the UAS. The controller offers the following: 1. GPS Assisted Flight- GPS allows the quadcopterto hoverwhen no commands are being sent. 2. Non-GPS Modes

- IfGPS signals are lost or unavailable the aircraft uses P-OPTI or P-ATTI to monitorthe altitude and provide control assistance to help keep the aircraft stable and undercontrol. 3. Return to Home

- Allows the quadcopterto return to home and land when battery power is low or "fail safe" button is pushed on the transmitter. This is beneficial ifthe pilot becomes disoriented orthere are battery issues. 4. The remote controller comes with preprogrammed flight limitations, including height limits, distance limits, and no fly zones. These function concurrentlyto manage flight safety. The quadcopter is preprogrammed to not operate in a no fly zone or immediately land ifa no fly zone has been entered. 5. Aircraft status indicators

- Give the userthe status ofthe 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 hasfront LEOs and aircraft status indicators. The LEOs are used fororientation and location ofthe aircraftfrom the line ofsight. The aircraft status indicators are used to confirm the operation ofthe aircraft. The remote control transmitteroffersfull telemetry showing altitude (with preset alarms ofaltitude 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 ofTransportation 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. Ifwe are incorrect, we will immediatelyapplyforall necessary licenses orchange to a differentfrequency. (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 offlights will be well belowthis limit at an average of 150' 200' AGL to accomplish the best photographs and videos. • Any required permitswill be obtained from local and state governments before flights. • The aircraft will not operate directlyabove human beings at anytime or within 150feet of human beings. • Maximum Flight Time will be 15 minutes. The battery allows 20 plus minutes offlight time. Batteries are inspected and always fully charged before use. • The aircraft will not operate within 5 miles ofan airport/heliportwithout priorapproval from said airport/heliport. • All operations will be during the daytime and in ideal weatherconditions of less than 15mph winds and clear skies. • Aircraft will remain in visual line ofsite at all times notto exceed % mile from PIC. • Visual Observerwill serve as additional eyes on the aircraft and be within voice reach to communicate with the PIC. • Aircraft will notfly in the area ofanyfull scale aircraft and ifa full scale aircraft comes into airspace during the aircraft's flight, it will be landed immediatelyto allow right ofwayto full scale aircraft. • At anytime aircraft is being flown, signs will be posted in at leastthree (3) locations, warning of UAS operations are being conducted and to stay at least 200' away at all times of landing and takeoffarea (marked with a large orange cone). • The PIC, Jared Chambers, has flown remote aircraftfor 1.5 years. This has been exclusively multi-rotortypes such as the DJI Phantom (quadcopter). There have been no incidents ofinjury or property damage.US Department ofTransportation December 18, 2015 Page4

• The Applicant believes that a private pilot's license is notapplicable to flying a UAS for several reasons (flight controls are differentthan 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 ofthe exemption being granted ifthe FAA deems it is indeed required. Ifthe FAA rules that a private pilot's license is not needed after granting the exemption and the PIC has notobtained 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 ofprivacy and will only be used forthe 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 ofthe FAA Reform Act & Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14C.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 leasttwo "arms" ofthe 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 cockpitto include said manual. Operating manual will be kept with PIC.US Department ofTransportation 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. 14C.F.R. 91.109: UAS are controlled by a transmitter and do not have the capabilityfor dual controls. It is Applicant's understanding there have been other aircraft approved without dual controls. 14C.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. 14C.F.R. 91.121: UAS does not have a traditional altimeter. It does however have a barometrictype which displays the altitude on the transmitterofwhich is monitored at all times to prevent exceeding 400' AGL. There isa/so an alarm on the transmitter when reaching within 50'of400'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 offlight time with a 30% reserve of battery power. Ifthis level is reached the UAS returns to home and lands. However, no flight will last longerthan 15 minutes as an extra safety precaution. All batteries are only used iffreshly 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 documentswill be with the PIC on the ground level.US Department ofTransportation December 18, 2015 Page 6 14C.F.R. 91.405, 91.407, 91.409, 91.417: 

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As there is no airworthiness inspections available Applicant requests an exemption. Again Applicant will perform pre-flight checklists to ensure safety. IfApplicant's pre-flight checklist does not pass, the flight will be aborted. Any items ofconcern will promptly be repaired using similar components and records will be keptthrough maintenance records. Applicant is prepared to modify oramend any part ofthis petition forexemption to meet orexceed concerns ofsafety. Applicant does lookforward to working with the FAA to provide a great service to its community and profession in a safe manner. Upon receipt ofthis request, please date stamp the additional copy ofthe first and last page of this letter and return it to me in the self addressed, stamped envelope also enclosed. Thank you in advance foryour consideration ofthis request. Sincerely,

Alan McNeil Peoples Company of Indianola

## UAV Pre-Flight/FlightPlanChecklist 

# .PEOPLES'M COMPANY Date: INNOVA!'IVE. REAL ESTArE. SOLUTIONS



## --------------------- Name: Observer:



## -------------------------------------- 

## ------------------------------ (Person in Control) 

### FlightLocation:------------------------------- WeatherCondition/Visibility/Wind Speed:----------------------- BEFORELOCATION Ensure Flight Location is notwithin 5 Miles ofAirport/Heliport. Ifso, call airport/heliportfor properauthority before flying. Record Contact Name, Phone, and Airport ifapproval is received Review Current Weather Conditions/Forecast as reported bythe NWS Check all BatteryVoltages/Condition- (if not charged, must charge before goingto location) Inspect all wires, plugs, and solder connections 

### ATLOCATION Check BatteryVoltage and Visual Inspection ofBattery Inspect Props on UAS forcracks, loose securing screws/bolts, proper rotation Visually Re-check Current WeatherConditions Site Survey -Identifyany possible hazards such as phone poles, flag poles, utilitywires, flocks of birds, traffic, large groups of people etc. IdentifyTakeoff and Landing Location (same location) IdentifyVantage Points for PIC and Observer Ensure before motors are armed, no one is in hazard area DURING FLIGHT • Remain Alertfor Possible Aircraft, Bystanders, or other hazards such as changing weather or birds • Fly only as high as needed forshot but neverabove 400' AGL • Every minuteview telemetry data showing battery level and flighttime (flights are 15 minutes max) 

### LANDING • Ensure Landing Area is clearfrom hazards or bystanders • View Wind Direction and Compensate Flight ifneeded • Land Aircraft- Motorsare shut offimmediately after landing • Bystanders are notallowed to approach aircraft until battery has been disconnected 

### EMERGENCYLANDING • Land immediately at asafe and close location when: o Other aircraft are spotted or heard (including other UAS) o Bystanders have gathered ora bystander has entered the proximity o Changes in weather orwind o Birds enteringthe area o Anything happens to distract pilot o If PIC feels uncomfortableforany reason Flightwasperformedto all flightplans andprotocols containedherein: (signbelow)

12119 Stratford Drive, Suite B Clive, Iowa 50325 

## www.PeoplesCompany.com 855.800.LAND

# .PEOPLESTM COMPANY INNOVATIVL REAL BTATE. SOLUTIONS.



### Maintenance/RepairReport Date:



### ------- PersonPerformingMaintenance:

Reason forMaintenance orRepair:

Part(s) BeingReplaced/Repaired (including anymanufacturerinformation):

AfterMaintenance/Repair: • Test Flight to be Performed in Ultra Safe Zone: o Location ofTest:---------------------- 0 Date:-------

• Tests to be Performed: o Low Hover, Low Flight Control Test (in all flight modes) o IfPassed- 2"d Test Flight will be ofa normal flight plan o Failure in eithertest flight will result in grounding ofthe 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