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	otherwise	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	safety	for	his/her	self	and	all	associated	individuals.	

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.	

Attached	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/s
Max	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	flight	consists	of	a	mandatory	8 point	pre-flight	safety	

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	inspection
6. Battery	cable	inspection

7. Transmitter	test

8. Global	Positioning	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	routinely	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	

logged	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	populated	areas 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	possible	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	not	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,	maintenance	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	safe	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	automatically	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	distance	

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	the	landing	

process.	

Respectfully	submitted,

Benjamin	E.	Carraway