August 30, 2015 

U.S. DepartmentofTransportation 

Docket Management System 

1200 NewJerseyAve., 

Washington, DC20590 

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

Regulations 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act"), 

Darrell Best (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an exemption 

from the Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial imaging and 

video of homes & properties applicant list for sale. 

Applicant 

G. Darrell Best 

1600 CR 1006 

Walnut Springs, 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 nor passenger and 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 environment and under the conditions proposed 
operation will be at least as safe, or safer, than a conventional aircraftoperatingwith an airworthiness 

certificate without said restrictions. 

14 CFR 91.7 (a) 

As there will be no airworthiness certificateforthe aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check list prior to each flight an equivalent level of safety will be 

provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is 

no room, capacity, or pi lot on board to adequately carry flight manual. A equivalent level of safety will 

be maintained by keeping the flight manual at ground control point where the pilotwil) have immediate 

access to it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft an exemption wi II be needed. 

Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing 

and takeoff distances, along will all of those found in attachment "OJ I PilotTraining". An equivalent level 

of safety wi II be provided by preflight protocol) to properly match the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

through the use of a control box that communicates with the aircraft via radio communications. The 

equivalent level of safety provided because neither a pilot norpassengerwill be carried in the aircraft, 

and by the speed and size of the aircraft. 

14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills. 

14 CFR 91.121 

The UAS may not have a barometric altimeter, but instead does have a GPSaltitude read out. I believe 

an exemption maybe needed. An equivalent level of safety is achieve by the operator receiving live 

flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS 

altitude indicator. 

14 CFR 91.203 (a) and (b) 

Similarto, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate 

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately 

such documents. An equivalent level of safetywili be achieved by keepingthese documents, to the 

extent they are applicable to the UAS, at the ground control point where pilot has immediate access 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 apply to aircraft with an airworthiness certificate, theses sections do not apply 

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in 

working condition before initiating each 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 less than 33.5 mph, and 

with a maximum flight time of25 minutes. The UAS"drone"to be used is a OJI Phantom 2 Plus. At2.74 

pounds the weight of the UAS meets the definition of"small unmanned aircraft" found in section 

331"The Reform Act".ln order to obtain high quality photography and video the UAS will be used at 

speeds much less than it's top speed of 33.5 mph. Due to the UAS being battery powered there are no 

combustible fuels on board. Maximum flight time forth is 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 with the aircraft to be utilized i find this exception to be reasonable with an equivalent, 

or greater, level of safety to be reached by the operator. 

Safety 

Please see attachment "OJ I PilotTraining" for safety precautions I use foreveryflight. 

Additionally: 

1. I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport 

manager has been made. 

2. I land my UAS priorto manufacturer recommended minimum level of battery power 

3. I pilot my UAS through remote control by line of sight. 

4. My UAS uses GPS and a flight safety feature where by it returns to a pre programmed position and 

then slowly lands if communication with the remote control pilot is lost. 

5. I actively analyze flight data and other sources of information to constantly update and enhance 

safety protocols. 

6. I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance. 

7. I always obtain all necessary permissions prior to operation; and, 

8. I have procedures in place to abort flights in the event of safety breaches or potential danger. 

Public Interest 

The use of an UAS in the real estate industry provides both buyers and sellers a higher level of service. 

For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting 

in a quicker sale oftheirhome. Quicker home sales also helps accelerate the economy as a whole. 

Buyers experience the benefit of encompassing a whole property, sometimes several acres, in one 

photo or a short video. Notonlydoesthis benefit the specific home seller or home buyer, but it benefits 

the general public because it is much more efficient than traditional ways of using a plane or helicopter 

to achieve the same result. 

We can now provide this level of service 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 of a safety concern for the general public when 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 . 

B 

• 

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. 

' ' 

' ' ' ' ' ' ' ' ' ' '0 

A' ' ' ' 

~ ' ' ' ' ~\ eA 
Basic Flight Maneuvers ( * ) 

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. 

3 meters 3 meters 

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. 

I , 

, 

, 

, 

~ , 

, -----~-----~ 

. / • --------- -~·- ---------· 

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. 

_____ ,.... ____ ~ 

, ' ,' ~ , ' , ' , ' 

, ' ,' ' , ' , ' , ' , ' -----------~~-~----------· 
Skilled Flight Maneuvers ( * * ) 

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-----~-----\ 

, \ 

, \ 

, \ 

.... \ , \ 

, \ 

, \ 

, \ 

, \ 

, \ 

el---------- 11----------~ 
Skilled Flight Maneuvers ( * * ) 

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. 

, 

, 

, 

• 

, 

~ ----- ~----

, 

, 

, 

, 

, 

, 

, 

, 

, \ 

\ 

~ \ 

\ 

\ 

\ 

\ 

\ 

\ 

\ 

------ -·-~--------- -- With the battery pointed at yourself, fly a circle. Try to 

keep the altitude and also the circle as uniform as possible. 

----------------~ 

, 

, .... ----- ~ 

~ ~ ) '\_ ----------~----------) (!) 

Hover with the aircraft nose pointed at yourself and try 

to keep the Phantom in one place. 

<ID ~··· 
Advanced Flight Maneuvers ( * * * ) 

D 

; 

I 

' .. 

El 

"' 

Fly a circle and keep the aircraft nose pointed towards you. 

Be sure to keep the altitude the same and the circle as 

uniform as possible. 

, ... ... -----------------

.. ~~~ - ~ad~------ .. ------......... -

... --

Fly a 4 point square box clockwise while keeping the aircraft 

nose facing in your direction. 

I 

I 

I 

~ I 

I 

I 

--- -- ~- -- - -~ I \ 

I \ 

: ' 

' • - - -----........... ------- -- -- Fly a 4 point square box counter-clockwise while keeping 

the aircraft nose facing in your direction. 

-rr - -----~----"""'\ I \ 

I \ 

I \ 

II \ 

I \ 

I, ~ I \ 

I \ 

I \ 

I \ 

I \ 

.. --- -- ---·-~- ----- ----· 
Advanced Flight Maneuvers <* * *) 

IJ Fly a 4 point square box clockwise and rotate the 

phantom in the direction of travel. 

I 

I 

• 

I 

I 

I 

I \ 

\ 

\ 

\ 

.. -------- - -- ~~ Fly a circle counter-clockwise and keep the aircraft 

nose pointed in the direction of travel. Be sure to keep 

the altitude the same and the circle as uniform as possible. 

\ 

' ... 

~ ~~~ 

...... -_.... --- .... -

.. -------

; 

I ; ; 

r:J Fly a circle counter-clockwise with the aircraft nose 

pointed at the center of the circle. Be sure to keep 

the altitude the same and the circle as uniform as 

possible. 

~~~ ~~~ 

.. --...... --- .... --~------

(JD 
Advanced Flight Maneuvers <* * *) 

a Fly a figure 8 without rotating the Phantom. Be sure to keep 

the altitude the same and the circle as uniform as possible. 

~--.--------~ ~ 

-- ,' . ~ ~ ~~~----~----·~-------~ ;'~ ~ -- ~, 

, -, 

.~ .. _ _.,'' ~~. ~ ~~ 

--- ·---------

Fly a Figure 8 with the aircraft nose of the Phantom 

pointed in the direction of travel. Be sure to keep the 

altitude the same and the circle as uniform as possible. 

~--.. ···-----~ -~-

-- ~-~----~-----~-------~ ; 

,~~ - -- ~, 

, - ~ , ~ .. , -------- ----------

Fly Figure 8 patterns while experimenting with different orientations. 

For example, aircraft nose always pointed in a given direction or 

opposite/left/right the direction of travel, etc. Be sure to keep the 

altitude thesame and the circle as uniform as possible. 

~ ..... _____ )j. -~-

,__ ,' - u --~----------~-------~ ~,* ~ -- ~, 

; .. 

~ ; ~ , .. -~~ 

.. -------- • -------
Emergency Situations 

D 

El 

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 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. 

-----------------1 

T 

15 meters • 

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. 

'' " '" ,,..,... ~ '' 0 '' ~ ' 

' 

• 15 meters 

• 
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