September 16, 2015

Exemption No. 12880

Regulatory Docket No. FAA−2015−2294

Mr. Greg Wilkinson

Worth Every Dollar Appraisals LLC

P.O. Box 170467

Atlanta, GA 30317‐0467

Dear Mr. Wilkinson:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 27, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Worth Every Dollar Appraisals LLC (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial imaging of commercial and residential property.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
2

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Worth Every Dollar Appraisals LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, Worth Every Dollar Appraisals LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
4

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
P.O. Box 170467

Atlanta, GA 30317

Local: 404.835.7481

Toll Free: 866.591.1804

Fax: 866.457.2501

gregw@wortheverydollar.com

May 27, 2015 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue 

Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001 

RE: Petition for Exemption under Section 333 FAA Modernization and Reform Act of 2012 

 Public 112-95 February 14, 2012, Section 333 

Dear Sir or Madam: 

Attached you will find Worth Every Dollar Appraisals LLC request for an exemption from the listed Federal 

Aviation Regulations to allow for commercial operations of its Small Unmanned Aircraft System (“sUAS”) 

for aerial imaging of commercial and residential property in connect with our appraisal operations in metro 

Atlanta, GA. With the ability to use sUAS’s in our process it can lead to more accurate valuation analysis’s 

provided by our company. 

We thank you for your time and consideration of expedition of this request. Should you have any questions 

or concerns please do not hesitate to contact us. 

Sincerely, 

Greg Wilkinson 

Certified Residential Appraiser – GA #CR260229 

Worth Every Dollar Appraisals ® 

/enclosure application
1

Introduction

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, Worth Every Dollar Appraisals LLC, a real property appraisal company, hereby applies for

an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its

Small Unmanned Aircraft Systems ("sUAS") for aerial imaging for inspecting and/or recording of secured

and controlled environment construction sites, proposed development sites, existing construction,

overall inspections of property and aerial photography in connection with real property valuations, so

long as such operations are conducted within and under the conditions outlined herein or as may be

established by the FAA as required by Section 333.

As detailed in this document, the requested exemption would permit the operation of sUAS under

controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4)

would provide safety enhancements to the already best practices safety protocols followed by Worth

Every Dollar Appraisals LLC at each one of its project sites. Approval of this exemption would thereby

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to

"...establish requirements for the safe operation of such aircraft systems in the national airspace

system." Section 333(c) of the Reform Act.

This exemption request is exclusively for the use of the sUAS manufactured by DJI, DJI Phantom 3

Advanced model, serial number P76DCE11013346.

Regulations from which the exemption is requested: 14 C.F.R. Part 21

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  

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) & (b)

Exemption Applicant

Worth Every Dollar Appraisals LLC

Attn: Greg Wilkinson

PO Box 170467

Atlanta, GA 30317‐0467

(404) 835‐7481 – voice

(866) 457‐2501 – fax

info@wortheverydollar.com ‐ email

www.wortheverydollar.com – web

   
2

Intended sUAS Use

Evaluating overall property characteristics by documenting the overall extent of the improvements,

condition of the improvements, and any deferred maintenance items present. Investigation and findings

specifically for building exteriors would be greatly enhanced by the use of a sUAS. Using a sUAS would

reduce the time and improve the analysis for exterior construction improvements and defects on

multiple story buildings. A sUAS could inspect, find, and record information that would be otherwise be

inaccessible to a real property appraiser. This type of inspection would greatly improve the ability to

properly value the land and improvements being appraised.

I. STATUTORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority

includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, from the

requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may

grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this

section or any sections 44702‐44716 of this title if the Administrator finds the exemption in the public

interest. 49 U.S .C. §44701 (f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate in the

National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national

security. In making this determination, the Secretary must consider:

 The UAS's size, weight, speed, and operational capability;

 Whether the UAS operates within the visual line of sight of the operator

 Whether the UAS operates outside of highly populated areas and away from close proximity to

airports  

Reform Act §333(a). If the Secretary determines that a UAS "may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe  operation of such aircraft in the national

airspace system." Id. §333(c).  

Worth Every Dollar Appraisals' sUAS is a multi‐rotor vehicle, weighting 5 or fewer lbs. including payload.

The sUAS operates under normal conditions at a speed of no more than 50 knots and has the capability

to hover and move in the vertical and horizontal plane simultaneously. The sUAS will operate only in the

pilot's visual line of sight at all times and will operate only within the recommendations described in the

DJI Flight Manual, such operations will insure that the sUAS will "not create a hazard to users of the

national airspace system or the public." Reform Act Section 333 (b).  

Given the small size of the sUAS involved and the restricted and sterile environment within which they

will operate, this application falls within the zone of safety (an equivalent level of safety) in which

Congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to

commence immediately.

Also due to the small size of the sUAS and the low altitudes and restricted areas in which our sUAS will

operate, approval of the application presents no national security issue.
3

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations,

and the significant public benefit, including enhanced safety, the grant of the requested exemptions is in

the public interest. Accordingly, Worth Every Dollar Appraisals LLC respectfully requests that the FAA

grant the requested exemption without delay.

II PUBLIC INTEREST

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a)

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking

required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress's

intent of allowing UAS to operate with significant safety precautions in low risk environments.

  

The use of sUAS on a construction or inspection site can significantly reduce the risk to workers of falls

while inspecting a job site. The sUAS can inspect, photograph, and collect data on hard to get to areas

that otherwise would require worker inspection or inhibit the inspection. Falls are the leading source of

workplace fatality and injury on construction sites, and reducing falls through sUAS use for site imaging

could reduce this risk.

  

The UAS we propose to fly in this application are under five pounds and carry no combustible material

on board, as opposed to the much larger conventionally powered small aircraft.

Lastly, UAS reduce the environmental impact by dramatically decreasing the energy used for aerial

imaging and data collection over a construction site. Our sUAS uses rechargeable lithium ion batteries,

as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier.

III EQUIVALENT LEVEL OF SAFETY

Worth Every Dollar Appraisals LLC proposes that the exemption requested herein apply to civil aircraft

that have the characteristics and that operate with the limitations listed herein. These limitations

provide for at least an equivalent or even higher level of safety to operations under the current

regulatory structure because the proposed operations represent a safety enhancement to the already

safe protocols followed on job sites and imaging and surveying operations conducted with helicopters

and other conventional aircraft.  Worth Every Dollar Appraisals LLC will be bound by the following

limitations when conducting its UAS operations under an FAA issued exemption:

 The sUAS will be less than 5 pounds.

 Flights will be operated within visual line of sight of a pilot.

 Maximum total flight time for each operational flight will be 15 minutes. The sUAS calculates

battery reserve in real time, and will return to its ground station with at least 20% battery power

reserve should that occur prior to the 15 minute limit.

 Flights will be operated at an altitude of 200 feet AGL, never exceeding 400 feet AGL.

 Crew for each operation will consist of the sUAS pilot who will keep the sUAS within their visual

line of sight at all times and a spotter.

 The sUAS pilot will be trained in flight, operations, and safety procedures as detailed in this

document and as detailed in the DJI Manual.
4

 The sUAS will only operate within confined areas as defined in this document. This document

and the DJI Manual also require the establishment of a Security Perimeter for the flight

operations area.

 A briefing will be conducted in regard to the planned sUAS operations prior to each days

production activities. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

 All onsite personnel will consent to the sUAS flyover on site by waiver, and the operator will

obtain additional verbal or written consent of all persons who will be allowed within 100 feet of

the flight operation.

 The pilot will have been trained in operation of sUAS generally and received up‐to‐date

information on the particular sUAS to be operated as required by this document.

 Written and/or oral permission from the relevant property holders will be obtained.

 All required permissions and permits will be obtained from territorial, state, county, or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

 If the sUAS loses communications or loses its GPS signal, it will have capability to return to a pre‐ 

determined location within the Security Perimeter and land.

IV DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91203(a)(1) Subpart H, entitled

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with

the aircraft to be utilized by Worth Every Dollar Appraisals LLC, an exemption from Part 21 Subpart H

meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform

Act. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the

size, weight, speed, operational capability, and proximity to airports and populated areas of the

particular sUAS. Our sUAS will be operated at low speed in a controlled environment, at least five miles

from an airport and a safe distance from any densely populated area.

An analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate,

in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a

conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the

restrictions and conditions proposed.  

The sUAS to be operated hereunder is less than 5 lbs. fully loaded, carries neither a pilot nor passenger,

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area

as set out in this document and the DJI manual . Like other civil aircraft, operations under this

exemption will be tightly controlled and monitored by the operator, pursuant to this document and the

DJI Manual's requirements, and under the requirements and in compliance with local public safety

requirements, to provide security for the area of operation as is currently done on active job sites.

These safety enhancements, which already apply to civil aircraft operated in connection with job sites,

provide a greater degree of safety to the public and property owners than conventional operations

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.
5

Lastly, application of these same criteria demonstrates that there is no credible threat to national

security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive

materials or flammable liquid fuels, and ability to carry an external load no greater than 2 lbs.

14 C.F.R. 45.23(b): Marking of the Aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or light‐sport category

aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light‐

sport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station.  

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the UAS

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be  

placed. Given the size of the sUAS, two‐inch lettering will be impossible. The word "Experimental" will

be placed on the fuselage in compliance with §45.29 (f).  

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by

§45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the

sUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions

Nos. 10700, 8738, 10167 and 10167A.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command Sections 61.113 (a) &

(b) limit private pilots to non‐commercial operations. Because the sUAS will not carry a pilot or

passengers, the proposed operations can achieve the equivalent level of safety of current operations by

requiring the pilot operating the aircraft to have completed a sUAS flight training course of 10 hours

before flying a sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is

remotely controlled with no living thing or cargo on board. The area of operation is controlled and

restricted, and all flights are planned and coordinated in advance as set forth in this document. The risks

associated with the operation of the sUAS are so diminished from the level of risk associated with

commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as

requested with a pilot who has met the minimum requirements of this document exceeds the present

level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.7 (a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

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

requirements contained in the DJI Manual for maintenance and use of safety checklists prior to each

flight, as set forth in this document, an equivalent level of safety will be provided.

14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry

such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight

manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The

FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299,

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. 91.103: Preflight Action  

This regulation requires each pilot in command take certain actions before flight to ensure the safety of

flight. An exemption is needed from this requirement as the pilot will take separate preflight actions,
6

including checking for weather conditions, checking flight battery requirements, checking takeoff and

landing distances, and all other actions in the Preflight Checklist in this document and the DJI Manual.

These actions will provide an equivalent level of safety.

14 C.F.R. 91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that

is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUAS

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

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

has previously approved exemptions for aircraft without fully functional dual controls. See Exemption

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor

passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the

controller, and by the size and speed of the aircraft.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is

for a multi‐rotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which

will typically operate at altitudes of 200 AGL, so an exemption may be needed to allow such operations.

The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security

perimeter, where buildings and people will not be exposed to operations without their pre‐obtained

consent.  

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the

location where it is operated. No flight will be taken without the permission of the property owner

and/or local officials. Because of the advance notice to the property owner and any onsite personnel as

outlined in the Manual, all affected individuals will be aware of the planned flight operations. Compared

to flight operations with aircraft or rotorcraft weighting far more than the maximum 5 lbs. proposed

herein and carrying flammable fuel, any risk associated with our operations is far less than those

presently presented with helicopters and other conventional aircraft operating at or below 500 AGL in

the construction industry. In addition, the low‐altitude operations of the UAS will ensure separation

between these s UAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to

an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting

available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown

on the GPS altitude indicator before flight.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited

to operations in sterile and controlled environments as outlined in the Manual, and has a limited range

and flight time which require an exemption from 14 CFR 91.151(a). The battery powering the sUAS

provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14
7

CFR §91.151, sUAS flights would be limited to 0 minutes in length. Given the limitations on the sUAS's

proposed flight area and the location of its proposed operations within a predetermined area, a longer

time frame for flight in daylight or night VFR conditions is reasonable. Worth Every Dollar Appraisals LLC

believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR

91.151(a)). Operating the sUAS, in a controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does

not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed

of the sUAS. Additionally, limiting sUAS flights to 15 minutes would greatly reduce the utility for which

the exemption will be granted. An equivalent level of safety can be achieved by limiting flights to 15

minutes, or enough battery reserve to ensure that the UAS lands at the ground station with at least 20%

of battery power (as determined by the onboard monitoring system and the pilot), whichever happens

first. This restriction would be more than adequate to return the sUAS to its planned landing zone from

anywhere in its limited operating area. Similar exemptions have been granted to other operations,

including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The regulation provides in part:  

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate....

(2) (b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at

the cabin or cockpit entrance so that it is legible to passengers or crew.  

(3) The sUAS fully loaded weighs no more than 5 lbs and is operates without an onboard pilot.

Therefore there is no ability or place to carry certification and registration documents or to

display them on the UAS.  

(4) An equivalent level of safety will be achieved by keeping these documents at the ground flight

control point where the pilot flying the sUAS will have immediate access to them, to the extent

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A,

9797, 9797A, 9816A, and 10700.

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...," and

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to Worth Every Dollar Appraisals. Maintenance will be accomplished by the

operator pursuant to the flight manual and operating handbook as referenced in this document and the

DJI Manual. An equivalent level of safety will be achieved because these sUASs are very limited in size

and will carry a small payload and operate only in restricted areas for limited periods of time. If

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400

feet AGL. As provided in the DJI Manual and this document , the operator will ensure that the sUAS is in

working order prior to initiating flight, perform required maintenance, and keep a log of any
8

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed:  

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14

C.F.R. § § 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a)

and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate

commercially a small unmanned vehicle (55 lbs or less) in construction operations. Approval of

exemptions allowing commercial operations of sUASs in the construction industry enhances safety while

reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are

much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing

fewer than 5 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass

and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore,

will not expose them to the risks associated with manned aircraft flights.

The operation of sUASs, weighting less than 5 lbs., conducted in the strict conditions outlined above, will

provide an equivalent level of safety supporting the grant of the exemptions requested herein, including

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These

lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as

a result, are far safer than conventional operations conducted with turbine helicopters operating in

close proximity to the ground and people.

   
9

Equipment for Exemption and Aircraft Performance
10

Equipment for Exemption and Aircraft Performance ‐ continued

Maintenance

To ensure safe operational control a maintenance schedule will be followed, a personal tailored

maintenance manual has been created, and quality replacement part will be used.

 Before and after every flight, the multi‐rotor's operational condition will be inspected for

damage and deterioration, paying attention to the props for damage, cracks or ware and the

UASs fuselage for damage. If damage, cracks or unusual ware is detected the flight will be

suspended until proper repairs have been made using the manufactures approved replacement

parts and/or approved repair facilities

 There is no intention in modifying aircraft beyond factory specifications. The sUAS will be in

compliance with the FAA airworthiness regulations.

Safety

Propeller guards: Propeller guards such as the DJI manufactures guards will always be in use during

commercial flights.

Spotter:  To ensure safety, the property owner, a contractor, or another party, will be on site to review

and observe hazards before and during the flight.
11

Population of Intended Areas: To ensure safety, all non‐essential personnel will be removed from the

area. There will be no flight over densely populated areas like stadiums, schools, malls, casinos, and the

like during operating hours.

Airports: According FAA rules and to ensure pilot(s) safety, there will no flight in or around airports

unless explicit permission is granted according to current FAA regulations.

Weather: To ensure safety of spotter, property owners, pets, and wildlife, flights will be conducted in

optimal weather conditions. Flights will not be conducted in winds above 20 mph.

Return‐to‐Home Feature: In the event the DJI Phantom 3 loses signal or runs critically low on battery the

sUAS has a GPS controlled return to home feature. The "home" is set upon flight startup.

Flying in Confined Areas: There is a high probability of flying in confined spaces, around residential

properties. The PIC and spotter will be in constant communication by two way radio, cell phone, or

other approved FAA communications device when geographically separated during flight to ensure

awareness of obstacles, hazards and sUAS location.

Line of Site: The sUAS will always be within the unaided line of site of the pilot and spotter. If the sUAS

cannot be seen the return home failsafe will be used to regain visual control.   

Height: Fights will not exceed 400 ft AGL at any time.

Potential Hazards

The following are potential hazards that may, or may not be, present during flight operations. The PIC

and spotter will make every attempt to be aware of:

 Other sUASs  

 Homes, commercial buildings, out buildings, low and high voltage power lines

 Trees, shrubs, and hedges  

 Automobiles and other mechanical vehicles  

 Wildlife  

 Rivers, lakes, ponds, and other bodies of water  

 Unaccounted for people  

 Unaccounted for animals  

Privacy Concerns

During flight operations privacy concerns are of high priority. With each commercial flight a signed

agreement, will be in place.  The property owner or authorized agent will sign a letter authorizing the

video and photography service performed by Worth Every Dollar Appraisals LLC.

During each flight operation, the sUAS PIC will be extremely mindful of neighboring parcels to not film,

record, or take pictures of people and property without their written & signed consent. In regards to

homes that are within residential neighborhoods, it is easy for the camera's field of view to record and
12

take pictures of homes and properties that are not intended to be advertised for sale. As the sUAS

increases altitude, so does the risk of inadvertently filming a home or property that hasn't given written

permission to do so. Where privacy is a concern every attempt will be made to omit neighboring

properties.

Homes and properties with acreage have a higher degree of uncertainty when trying to determine lot

lines, boundaries, and proximity to neighboring properties than a suburban home. People looking to

purchase a home with acreage, or a larger lot, have a higher degree of interest on knowing were the

approximate lot lines are and an aerial perspective affords them such information and it’s the appraisers

responsibility to value the property accordingly. The use of a sUAS would be the most efficient means to

provide such information.   

People looking to purchase and/or sell a home, or a property, with a view, or on waterfront, want to see

the home or property from an aerial perspective. This is part of property characteristics and what helps

determine the overall value of the property. In addition, even though neighboring parcels might be

shown in the picture and video, the neighboring properties will only be included if is necessary to the

subject property's final video or still photography.

Pilot Qualifications

The current PIC, Greg Wilkinson, maintains a flight log the presently contains 10 hours of flight training

for both the DJI Pantom 2 Vision+ and the DJI Phantom 3 Advanced sUAS.  In addition, the current, and

any future PIC, will adhere to the following:

 The Pilot in command will be familiar with current FAA regulations regarding UAS commercial

usage.

 The Pilot in command will have sufficient eye sight (with or without corrective lenses and

without the aid of binoculars) to see and operate the UAS at the distances necessary for the

purpose of the flight.

 Pilot will be in good health.

 New Pilots in training will shadow and act as the Pilot in Command Spotter for 1 month or for a

minimum of 10 hours prior to first flight.

 New Pilots will demonstrate a workable knowledge of the sUAS and proficiency in operational

control at all times.

 Pilots in training will watch online training videos to further enhance their skills.

 Each pilot will follow set flight plans and schedules and be aware of current FAA regulations.

   
13

Pre Flight Checklist

Authorization to Record Video and Still Photography

On file with Worth Every Dollar Appraisals LLC