Petition for	Exemption	of	Section	333

a) Benjamin	E.	Carraway July	14,	2015

390	Seldom	Seen	Trl Canton,	GA	30115

(770)	595

- 1875 carraway.ben@gmail.com

b) I	seek	exception	from	14	C.F.R.	21,	subpart	H;	14	C.F .R.	45.23(b);	14	C.F.R.	§§ 61.113	(a)	&	(b);	14	C.F.R.	§	91.7	(a);	14	C.F.R.	§	91.9	(b)(2);	14	C.F.R.	§ 91.103(b);	14	C.F.R.	§	91.109;	14	C.F.R.	§	91.119;	14	C.F.R.	§	91.121;	14	C.F.R. §	91.151(a);	14	C.F.R.	§§	91.203(a)	and	(b);	14	C.F.R.	§	91.405	(a);	14 C.F.R.	§ 91.407	(a)(1);	14	C.F.R.	§	91.409	(a)(2);	14	C.F.R.	§	91.409	(a	)	(2);	and,	14 C.F.R.	§§	91.417	(a)	&	(b)	to	commercially	operate.

c) Granting	this	exexmption to	fly	a	DJI	Phantom	commercially	would	add	value

to	the	real	estate	market. In	a	market	o therwise	only	accessible	from	higher budget	entities,	UAS	allow	for	low	budget	agencies	to	enhance	marketing	via aerial	images. d) Through	thorough	safety	requirements,	the	PIC	would	operate	at a	level	to

ensure	absolute	safet y	for	his/her	self	and	all	associ ated	indiv id uals. Stringent	requirement	will	be	implemented	to	ensure	the	general	public	is not	harmed	from	the	operation	of	UAS.

Regarding	the	Unmanned	Aircraft	System

The	UAS	in	question	is	a	DJI	Phantom	V.	1.1.1	with	modified	extended	landing	gear.

A ttached	is	a	Tarot	T

- 2D	Gimbal	to	hold	a	GoPro	Hero	3+	Black	or	equivalent.

Operating	Temperature

- 10 °C	~	50°C Power	Consumption

3.12W

Take

- Off	Weight <1200g Hovering	Accuracy	(GPS	Mode)

Vertical:	0.8m

Horizontal:	2.5m Max	Yaw	Angular	Velocity 200°/s

Max Tilt	Angle

45° Max	Ascent	/	Descent	Speed 6m/sMax	Flight	Velocity 10m/s Diagonal	Distance	(Motor	Center	To	Motor	Center)

350mm

Charger	and	Battery	Parameters

Charger AC Input

100

- 240V

Charge Current

1A/2A/3A

Current Drain For Balancing

200mA

Power

20W

Battery Type

LiPo
Average flight time is 8

- 12 minutes in air.

Transmitter	Parameters

Working Frequency

2.4GHz ISM

Control Channels

7 Channels

Communication Distance

1000m
Receiver Sensitivity ( 1%PER )

>

- 100dBm

Power Consumption Of TX

< 20dBm

Working Current /Voltage

52 mA@6V

AA Battery
4 Required

Note:	Frequency	complies	with	FCC	RF	safety	rules



## Aircraft	Upkeep:

Pre

- flight	inspection:	Each	f light	consists	of	a	mandatory	8 point	pre

- flight	saf e ty check	by	PIC.

1. Right

- forward	propeller and	motor inspection

2. Left

- forward	propeller	and	motor	inspection

3. Right

- back	propeller	motor	inspection

4. Left

- back	propeller	motor	inspection

5. Landing	gear	inspection6. Battery	cable	inspection

7. Transmitter	test

8. Global	Po sitioning	Satellite	test Failure	of	any	point	results	in	the	flight	to	be	aborted	until	maintenance	and	repair

is	conducted.

Maintenance:

Maintenance	of	the	UAS	includes	regular	inspection	of	all	components	used in	flight.	In	addition,	UAS	lights	are	ro utinely	checked	and	voltage	of	batteries inspected.

Regarding	the	Unmanned	Aircraft	PIC The	unmanned	aircraft	PIC	must	pass	a	series	of	stringent	requirements	from	a technological	and	physical	standpoint.	Sufficient	skill	and	flight	hours	must	be log ged	and	observed	before	taking	control	of	the	UAS.

PIC	must	posses	significant	knowledge	of	UAS	in	question.	Only	following	a course	and	test	teaching	about	aircraft	may	the	PIC	be	allowed	to	take	command.

If	PIC	has	prior	flight	time,	time	must	total 20	hours	of	flight	with	specified	UAS.

PIC	must	pass	a	physical	and	it	must	be	current	within	(1)	year	of	flight.

Regarding	the	Operation	of	the	Unmanned	Aircraft

1. UAS	would	be	used	for	real	estate photography. All	flights	would	occur	away from	popul ated	area s as	compliant	with	FAA	guidelines. To	ensure	safety	for both	persons	and	property,	UA	would	be	not	be	flown	directly	overhead	any person	or	structure.	In	addition	to	this	mandate,	aircraft	would	be	limited	to

within	20	feet	of	all	aforementioned edifices	and	persons.

2. The	maximum	operating	speed	of	aircraft	would	be	limited	to	10	miles	per hour,	with	a	maximum	altitude	of	100	feet.		PIC	would	operate	under instruction	to	not	fly	UA	in	conditions	that	may	prohibit	VLOS	in	any	way. Fog	or	other	possi ble	barriers	to	VLOS	would	cause	an	immediate	abort	of flight.

3. To	alleviate	concern	in	association	with	flying	near	populated	areas,	no	flight may	be	conducted	within	300	feet	of	any	commercial	or	retail	establishment.4. To	alleviate	concern	in	association with	flying	in	proximity	to	airports,	PIC must	check	airport	proximity	prior	to	flight	and	ensure	flight	is	not conducted	within	(10)	miles	of any	airports.

5. All	flights will	be	operated	using	visual	line

- of

- sight	(VLOS)	of	aircraft.	PIC

are	instructed	to	n ot	fly	into	conditions	which	may	prohibit	VLOS.

6. As	aforementioned,	each	flight	will	be	preceded	by	an	(8)	point	safety	check ensuring	aircraft	is	in	proper	condition	for	flight.	Any	concerns	will	result	in a	flight	abort	until	further	inspection,	maintenan ce	and	repair	is	conducted.



# THE	AIRCRAFT	WOULD	BE	LIMITED	TO

UNDER	200	FEET	AND	>5	MILES

PROXIMITY	FROM	NEAREST	AIRPORT

Low	Battery	RTH:	The	low	battery	level	failsafe	is	triggered	when	the	DJI	Flight Battery	is	depleted	to	a	point	that	may	affect	the	s afe	return	of	the	aircraft.	Users	are advised	to	return	home	or	land	the	aircraft	immediately	when	these	warnings	are shown.	DJI	Pilot	app	will	advise	user	to	return	the	aircraft	to	the	Home	Point	when low	battery	warning	is	triggered.	Aircraft	will	automa tically	return	to	the	Home Point	if	no	action	is	taken	after	10	seconds	countdown.	User	can	cancel	the	RTH	by pressing	once	on	the	RTH	button.	The	thresholds	for	these	warnings	are automatically	determined	based	on	the	current	aircraft	altitude	and	its	dis tance from	the	Home	Point.	Aircraft	will	land	automatically	if	the	current	battery	level	can only	support	the	aircraft	to	land	to	the	ground	from	the	current	altitude.	User	can use	the	remote	controller	to	control	the	aircraft’s	orientation	during	t he	landing

process.

Respectfully	submitted,

Benjamin	E.	Carraway