### LawrenceToth KT 

### &Associates of Michigan, Inc. KellerWilliamsAnnArbor Market Center 3134 Baker Rd. Dexter, Ml48130 (Office) 734-426-6669 (Fax) 734-661-4315 August 15, 2015 U. S. DepartmentofTransportation Docket Management System 1200 New JerseyAve., SEWashington, DC 20590 Subject: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. Part21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) 

### & (b), 91.103, 91.119, 91.121, 91.203,91.151 Following the format of FAA Exemption No. 11138 -Regulatory Docket No. FAA- 2014 -0481 I have included: 1) Supplemental Response for Petition 2) PHANTOM Flying FlowchartV1.0 (Simplified Version), 3) PHANTOM Quick Start Manual v1.7 4) PHANTOM PilotTraining Guidev.1.1 5) PHANTOM 2 Vision+ User Manual v1.8 6) Personal protocols and controls

- Safety/Flight concerns

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, I, LawrenceToth preparing this exemption request myself, would like to applyfor an exemption from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging and video ofAnn Arbor Michigan Area Landmarks and homes I listfor sale. I have experience in flying hobby quadsfor recreational purposes durin·g the past4 years without incident. I have added a hobbygrade DJI Phantom 2 Vision+ quad-copter (maximum gross weight 3 pounds, equipped with four rotors that are driven by electric motors powered by batteries, the UAS has a maximum airspeed of30 knots) to my inventory equipped with an integrated camera with intentfor aerial videography/cinematographyto enhance academic community awareness and augment real estate listing videos/photos; following an exemption and approval bythe FAA. Myexemption requestwould permit operation of ultra-lightweight, unmanned (piloted by remote control) in predetermined areas awayfrom general public, airports, heliports and vehiculartraffic, under400 ft. and after carefully reviewing, inspecting and 

### TothPetition Page 1examining the area ofaerial observation. This would allowfor communityvideos/photos within property boundariesfor indivioual homeowner real estate listing videos/photos. Iwill abide by all FAA requirements to ensurethis exemption will provide a level ofsafety at leastequal to existing rules and will only. operate in a safe environmentthat is strictly controlled, are awayfrom power lines, elevated lights, airports and actively populated areas; and Iwill conduct extensive preflight inspections and protocols, during which safety carries primary importance. 

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR 

### § 91.203 Giverlthe size, weight, speed, and limited operating area associated with the aircraftto be utilized, I

## am asking exemption from 14CFRpart21,Subpart H(Airworthiness Certificates)and§91.203 (a) and (b) (Certifications required),subject to certain conditions and limitations, is**warrant~d** and meets the requirements for an equivalent level of safety under14CFRpart 11 and Section 333 of

### P.L. 112-95 (Section 333). 

### 14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3) 

### (c)(d)(e)(f)(h): Size of Marks

Furthermore I request an exemption from §45.23 Marking of

### t!'-:3 aircraft because my UASwill not have a cabin, cockpit or pilot station on which to markcertain words or phrases. Additionallytwo -inch lettering is difficultto place on such a small aircraftwith dimensions smallerthan the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the word "Experimental" orassigned numberor name (based on a request or ruling bythe FAA ) on its fuselage as required by §45.29(f) sothat anyone assisting as a spotterwill see the markings. I also askfor an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be required and should be granted since they only applyto aircraftwith an airworthiness certificate. But, as a safety precaution Iwill perform a preflight inspection ofmy UAS before each flight as outlined in the operating documents. 

### 14 CFR 61.113 (a) & 

### (b): Private pilot privileges and limitations: Pilot in command.
Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, However, I can achieve an equivalent level ofsafety as achieved by current**regul~tions** because my UAS does not carry any pilots or passengers. While helpful, a pilot's ' license will notensure remote control piloting skills. The risks ofoperating a UAS arefar less than the risk levels inherent in the commercial activities outlined in 14 CFR part61 ,et seq., I request an exemption from §61.113 Private Pilot Privileges and Limitations. A side note, I have already explored getting my pilot's license, atthe· direction ofthe FAA, Iwould gladly begin education and eventual licensing.



### TothPetition Page2
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### Regarding UAS operational training, as stated previously I have fouryears experience flying numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics ofthe UAS' performance underdifferenttemperature and weather conditions. I also own and practice on a computerized simulated flight software to maintain adequate skills and response reflextime. I'm also aware ofa thre_e-day dronetraining course in Las Vegas Nevada and would gladly attend if required bythe FAA. 

### 14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action Ifgranted an exemption I agree to additional safety procedures including, but not limited to: 1) Keeping my USAwithin a radius distance of 1000feetfrom the controllerto aid in direct line ofsightvisual observation. 2) Operate the UAS for 3-7 minutes perflight; land my UAS according to the manufacturer's recommended minimum level of battery power. 3) Operate my UAS onlywithin visual line ofsight (VLOS). 4) Use the UAS' global positioning system(GPS) flight safetyfeature; it hovers and then slowly lands ifcommunication with the remote control is lost. 5) Conduct all operations under my own personal and flight safety protocols (including posting a warning sign reading: "Attention Aerial Photography in Progress -Remain Back 150feet"). 6) Iwill operate and will actively analyze flight data and othersources of information to constantly update and enhance mysafety protocols. 7) Contact respective airports ifoperationswill be within 5 miles to advise them of estimated flight time, flight duration, elevation offlight and other pertinent information (maintaining UAS software and firmware updatesfor "no fly" zone restrictions). 8) Always obtain all necessary permissions priorto operation. 9) Have procedures in place to abortflights in the eventofsafety breaches or potential danger. Aerial videography/photograpyfor geographical awareness of real estate marketing has been around for a long time through manned fixed winged aircraft and helicopters, butfor small business owners, its expense has been cost-prohibitive. Granting this exemption would allow meto provide this service at a much lower cost. Further, mysmall UAS, when used properly, will pose nothreatto the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The operation ofthis UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in theAnnArbor Michigan area. One final comment, the use ofa UAS has already proven to increase the marketability ofa home. Forexample please reviewthe article published January 7, 2015 in the San Diego source entitled, "Drone use in real estate may increase". The article cites the FMs exemption given to Douglas Trudeau, but also describes a record high price for an area homethat used a drone for aerial photography. 'When broker KurtWannebo added an aerial video to the listing for a Carmel Valley house, located on a large corner lot overlooking canyons on two sides, he sawWeb traffic noticeably increase."


### TothPetition Page3

## PHANTOM Flying Flowchart V1.0 (Simplified Version) This flowchart is aiming at help you to get familiar with the flying procedures of PHANTOM, please read the Manual carefully to get the operation details. Its corresponding Firmware Version is V3.0.

IOC On & Switch on the transmitter, and then power on the PHANTOM.

30s after power on**~-----** LED : Mode +GPS Satellite Number+6Yellow 6Yellow means warming up 

### 1 

## I**-.=~~-:-...Recording**

## I LED : Blink is ok. IOC Off& Warming up is ok. Green Quickly 1.-. )> Record the forward direction.

Important: At any moment after power on, ifthe GPS Satellite number is less than 6 and last for at least 1Os; even though you select the GPS ATTl. Mode and LED blinks in the GPS ATTl. Mode, the PHANTOM will work in ATTl. Mode.



## I Home Point Recording is ok 

# ____ _,. ___ F_a_ii_S_at_e

__,.1LED: BlinkYellow

, Quickly 000000000
Senser ErrorToo Big LED:Red+ Green+ Yellow Compass ErrorToo Big!,------, 1-------+f LED:Red+Yellow
If Red LED appears in the last four --------Hgreenflashes, the autopilot system cannotwork.

LED : Mode +GPS Satellite Number+6Green 6Green means motion detection. Important: If PHANTOM is moved after power on and before the motors start-up, that is normal.

FailSafe If it is stationary on the ground, please try the IMU Basic Calibration.

GPS Satellite

____ _ ,N_u_m_b_e_r_<6-H Keep**Le~eling** 000000000 &Landmg Important: When you switch to A TTl. Mode, the main controllerwill disengage enhanced FailSafe mode, you can re-gain control of aircraft. GPS Satellite,_

____ , Number<::6 Return to the Home Point 000000000 

### 1 GPS Satellite Number<::6, in GPS ATTl. Mode, 1 Distance between the Home Point and T PHANTOM>10m.**(_.Ho...:m~e:....;..Lo;.,;;c;..;;k;..;,)**



## - _] 

# •••••••••

Second Level ••••••••• Protection Alert &Height Descent IOC Ending

Power offthe PHANTOM, and then switch offthe transmitter Green Part means normal procedures:**--~~** means regularsituation.

- - )> means selectable orpossible situation. Pink Text tells the details. Red Part means possible abnormal situation. Part is possible in normal orabnormal situation, require you to confirm bythe Text for details. Blue Part is the condition ofthe normal situation. Purple Part is the condition ofthe abnormal situation.

# H 

# N
2013.09.25 Revision

For NAZA-M Firmware Y3.l2 &Assistant Software Y2.l2 

# M Quick

# Start Manualv1

Thank you for purchasing our product. Please visit the DJI website, PHANTOM section to confirm if the printed manual is the latest one according to the manual version. If not, please download and refer to the latest manual.

Please read the entire manual strictly and follow these steps to use you product. The manual will get you ready to fly by doing simple operations. You can get an advanced manual from DJI website to learn more about PHANTOM, for example, configuring parameters by connecting to assistant software, changing the transmitter to Model, matching frequency between the transmitter and the receiver, etc.

Make sure to use the NAZA-M assistant software of 2.0 version (or above 2.0) to carry out firmware upgrade and parameter configuration. DO NOT use the NAZA-M assistant software bellow 2.0 version. Note: The built-in autopilot system is NAZA-M; you can obtain the current NAZA-M Firmware Version according to the Assistant Software. If you ever upgrade your NAZA-M Firmware, please carefully read the corresponding NAZA-M release note and NAZA-M quick start guide.



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