August 30, 2015 U.S. DepartmentofTransportation Docket ManagementSystem 1200 NewJerseyAve., Washington, DC20590 RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuantto the Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), Darrell Best (the "applicant"), operator ofan Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal Aviation Regulations ("FARs") to allow for commercial operation foraerial imaging and video of homes 

### &properties applicant listforsale. Applicant G. Darrell Best 1600 CR 1006 WalnutSprings, TX 76690
Attachments DJI PilotTraining Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(2) 14 CFR 91.417 (a) and (b)
Extent of relief I seek, and why
14 CFR Part 21 subpart H The UAs to be operated carries neither pilot norpassengerand carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I request exception. In the restricted environmentand underthe conditions proposedoperation will be at least as safe, or safer, than a conventional aircraftoperatingwith an airworthiness certificate withoutsaid restrictions.
14 CFR 91.7 (a) As there will be no airworthiness certificateforthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check list priorto each flight an equivalent level ofsafety will be provided.
14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no abilityto carry a flight manual on the aircraft. There is no 

### room, capacity, or pi loton board to adequately carry flight manual. A equivalent level ofsafetywill be maintained by keepingthe flight manual atground control pointwhere the pilotwil) have immediate access to it. 14 CFR 91.103 As FAA approved flight manuals will not be provided forthe aircraft an exemption wi II be needed. Normal procedures including but not limitedto; reviewingweather, flight battery requirement, landing and takeoffdistances, alongwill all ofthose found in attachment "OJ I PilotTraining". An equivalent level of safetywi II be provided by preflight protocol) to properly match the machine. 14 CFR 91.109 UAS and remotely piloted aircraftdo not have fullyfunctional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraftvia radio communications. The equivalent level ofsafety provided because neithera pilot norpassengerwill be carried in the aircraft, and by the speed and size ofthe aircraft. 14 CFR 91.113 (a) and (b) I can achieve an equivalent level ofsafety as achieved by current regulations because my UAS does not carry pilot nor passenger. While helpful, a pilots' license will notensure remote control pilotingskills.
14 CFR 91.121 The UAS may not have a barometricaltimeter, but instead does have a GPSaltitude read out. I believe an exemption maybe needed. An equivalent level ofsafety is achieve by the operator receiving live flight data monitoringand confirming current altitude alongwith altitude of launch site shown on GPS altitude indicator. 14 CFR 91.203 (a) and (b) Similarto, 14 CFR 91.9 (b) (2), giventhe size and configuration, the UAS has no abilityto carry certificate and registration documents on the aircraft. There is no room, capacity, or piloton board to adequately such documents. An equivalent level ofsafetywili be achieved by keepingthese documents, tothe extenttheyare applicable tothe UAS, at the ground control pointwhere pilot has immediateaccess to them.
14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) Given these sections only applyto aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operatorwill perform preflight inspections and ensure UAS is in working condition before initiatingeach flight.Darrell Best is seeking relieffrom all FARs above preventing applicant from conducting aerial photography and video of real estate taken at levels less than 400ft, at a speed lessthan 33.5 mph, and with a maximum flighttime of25 minutes. The UAS"drone"to be used is a OJI Phantom 2 Plus. At2.74 poundsthe weight ofthe UAS meetsthe definition of"small unmanned aircraft" found in section 331"The Reform Act".ln orderto obtain high quality photography and videothe UAS will be used at speeds much less than it'stop speed of33.5 mph. Due to the UAS being battery powered there are no combustible fuels onboard. Maximum flighttime forthis particular UAS is 25 minutes battery life, flights to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated withthe aircraftto be utilized i findthis exception to be reasonable with an equivalent, or greater, level ofsafetyto be reached by the operator. Safety Please see attachment "OJ I PilotTraining" forsafety precautions I use foreveryflight. Additionally: 1. I do notoperate within 5 miles ofan airport unless priorcontact toAir Traffic Control or the airport manager has been made. 2. I land my UAS priorto manufacturer recommended minimum level ofbattery power 3. I pilot my UAS through remote control by line ofsight. 4. My UAS uses GPS and a flight safetyfeature where by it returns to a preprogrammed position and then slowly lands ifcommunication with the remote control pilot is lost. 5. I actively analyze flight data and othersources of informationto constantly update and enhance safety protocols. 6. I conduct extensive pre-flight inspections and protocol, duringwhich safety carries primary importance. 7. I always obtain all necessary permissions priortooperation; and, 8. I have procedures in place to abort flights in the event ofsafety breaches or potential danger. Public Interest The use ofan UAS inthe real estate industry provides both buyers and sellers a higher level ofservice. For a buyera higher level of marketing and advertising is achieved, appealingto more buyers, resulting in a quickersale oftheirhome. Quicker home sales also helps accelerate the economy as awhole. Buyers experience the benefitofencompassing awhole property, sometimes several acres, in one photo or a shortvideo. Notonlydoesthis benefitthe specific home seller or home buyer, but it benefits the general public because it is much more efficientthan traditional ways of usinga plane or helicopter to achieve the same result. We can now provide this level ofservice while being conservative with fuel, time, emissions, noise, and other resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will poses much less ofa safety concern forthe general publicwhen compared to larger manned aircraft.

# ~hfJ~co~ are11Best

214-517-7789

# PHANTOM PILOT TRAINING GUIDE Earning Your Stripes Vl.l

Learn tv1ore: www.dji.com

# ,6 CAUTION

This product is not suitable for people under the age of 18. Please carefully read the "Quick Start Guide", "User Manual", "Disclaimer", and fully watch the tutorial videos before using the PHANTOM. Users should make every effort to fly regularly in order to improve their flight skills as an advanced level pilot (

# ***)

.Please fly safely and responsibly.


### Please follow these guidelines prior to flying your Phantom: 

## Q Always turn on the Remote Controller prior to turning on the Phantom. @Toggle Sl, S2 to the top. 

# 8 Be sure there are no distractions when you're flying. 

# G When starting your training, be sure you are in a very large open area. Be aware of your surroundings. Always fly in areas void of obstacles and away from traffic and people. 

## Q) Before actually taking off, be sure you have calibrated the compass and you have full GPS satellite reception (Slow Continuous Green Flashing). 

# 8 Never fly higher than 400 feet. 

# 8 During training, stay behind your imaginary barrier and never fly behind yourself. 

## @) When in doubt, gently pull down on the throttle stick and land. 

# 0 DO NOT PANIC.

The aircraft nose should face AWAY from the pilot before takeoff.

DO NOT fly the Phantom within a radius of 2 meters.

DO NOT touch the propellers after the Phantom has been started. Nose



### CAUTION

FORBIDDEN 

# ® Tail 

### NO TOUCH

# Basic Flight Maneuvers (

# * ) a Take off and land with battery facing you
.



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Hover in one spot keeping battery facing you, make sure to control Left/Right/Forward/Back movement.

Rotate left, rotate right but try to keep the battery pointed at yourself.

# Basic Flight Maneuvers (

# * )

Slowly fly forward/back/left/right with back of Phantom pointed at yourself.

Fly forward to a spot 20-30 feet away. Then fly back keeping the battery pointed at yourself.**··~**



### tv1ark a spot (B) on the ground lOft away from the Phantom's take off point. Hover and fly towards that spot and land at the spot (B). Then go back into a hover and bring the Phantom back to its original position (A) and land again. 

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a Fly left 3 meters away from your take-off point, then fly right lOft from your take-off point all while keeping battery pointed at yourself.



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Then, while keeping the aircraft nose pointed forward, fly a 4 point square box formation going clockwise. Be sure to be in control and stop and hover in place at each point before proceeding to the next point.

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Do the same as above but fly the 4 point box formation counter-clockwise. Be sure to be in control and stop and hover in place at each point before proceeding to the next point.



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# Skilled Flight Maneuvers (

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D In a hover, starting with the battery pointed at yourself, rotate 360 degrees clockwise.

In a hover, starting with the battery pointed at yourself, rotate 360 degrees counter-clockwise.

Starting with the battery pointed at yourself, go into a hover. Then rotate the Phantom 90 degrees facing left, and fly a 4 point square box formation going clockwise. Be sure to be in control and stop and hover in place at each point before proceeding to the next point.**-r-----~-----** 

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Starting with the battery pointed at yourself, go into a hover. Then rotate the Phantom 90 degrees facing right, and fly a 4 point square box formation going counter-clockwise. Be sure to be in control and stop and hover in place at each point before proceeding to the next point.



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With the battery pointed at yourself, fly a circle. Try to keep the altitude and also the circle as uniform as possible.

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Hover with the aircraft nose pointed at yourself and try to keep the Phantom in one place.



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# <***) IJ Fly a 4 point square box clockwise and rotate the phantom in the direction of travel.

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# <***) a Fly a figure 8 without rotating the Phantom. Be sure to keep the altitude the same and the circle as uniform as possible.

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## & Land Mode Be sure you are in a large open area. Before you take off, make sure you have a good GPS lock by ensuring your LED indicators are flashing Green. Fly the Phantom at least 50ft away from your take off point. Turn off the Remote Controller. The Phantom will enter it's failsafe Return-To-Home Mode. Let the Phantom finish it's routine and land itself within 2 meters of the take off point.



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### Intercepting Return Home 

## & Land Mode Be sure you are in a large open area. Before you take off, make sure you have a good GPS lock by ensuring your LED indicators are flashing Green. Fly the Phantom 50ft away from your take off point. Turn off the Remote Controller. The Phantom will enter it's failsafe Return-To-Home Mode. When the Phantom is returning home, you can intercept RTH Mode by switching the Sl Switch from the top position to the middle or lower position, then continue flying the Phantom.

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# ' • 15 meters 

# •

## www.dji.com

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