Request for Section 333 Exemption.

Zachary Nathan Ingalls

1626 W. 21st Street

Lawrence, KS 66046

Zachary.ingalls@yahoo.com

913-306-3424

I am seeking an exemption for my UAS, DJI Phantom 3 Professional, for the 

purposes of conducting aerial surveys of properties for real estate agents, as well as private 

property owners who wish to obtain my services. I am also seeking exemption so that I may use 

my UAS to document historic structures using the onboard camera. The reason behind this is to 

provide an alternative means of photography that is different from the more traditional stationary 

camera from the ground. It is also believed that providing video of a property provides a greater 

representation of the present conditions of the property and the built environment surrounding 

the property. I also wish to do aerial videography and photography for clients on a case by case 

basis as desired by the client who retains my services.

The benefits to the public for my operation of a UAS for the purposes of 

documenting historic structures and aerial surveying of properties is that it provides a different 

and more unique approach to learning about a property. Real estate agents, for decades, have 

used ground-level photography but this can sometimes hide elements that make these properties 

unique and special. With a UAS, this process is dramatically changed to allow the potential 

buyer of the property to see, not just the house or building, but the surrounding landscape, or 

built environment that the structure is located in. For the purposes of documenting historic 

structures, using a UAS will provide an opportunity to view the condition of the structure from a 

much safer location than one might obtain via climbing on to the roof or using a ladder when 

inspecting the present conditions of the structure. Some historic or old buildings in need of 

repair may not be very stable and the UAS provides the opportunity to closely view the upper 

levels of the structure without having to risk human life.

Operations of the Aircraft/Maintenance/Flight Checks.

1. Operation of the UAS or Phantom will be conducted in the safest possible manner to 

minimize risk to the National Air Space (NAS) and to persons and property on the 

ground. Measures will be taken to ensure that no persons, aside from those associated 

with the operation of the UAS, are underneath the aircraft during flight. We also plan to 

limit the height of flight to no more than 100 feet as this allows operation of the UAS 

within the Visual Line of Sight (VLOS) during flight. Should I require a secondary 

individual to assist during surveying and documentation, he or she will provide 

information as to potential obstacles should they exist and also monitor weather 
conditions to allow for continued safe flight. That being said, he or she will not be used 

to see the UAS if I can’t see it as I do not intend to have it leave my VLOS. 

2. The operational characteristics of the UAS is that it is a multi-rotor (4 engine) aircraft 

constructed of rigid plastic. The aircraft lands on fixed skids and is propelled by 4 

electric motors operated by an onboard battery. The aircraft also carries a 4K/12MP 

camera mounted to a gimbal on board. The gimbal and camera are permanently attached 

to the UAS and can only be removed via mechanical fasteners (screws).

3. The UAS maximum ascent speed is 5 m/s. It’s maximum descent speed is 3m/s. Its 

maximum speed is 16 m/s however it will never be flown at these maximums as I prefer 

to have smooth flight for the purposes of my work and what I am using this exemption 

for. The aircraft can reach a maximum altitude of 6,000 meters (19685 feet). However,

for my purposes and for the purposes of this exemption I do not intend to exceed 100 feet 

as I do not see a reason for exceeding this height during my work.

4. The aircraft will be operated from the ground at all times via Remote control. The 

camera footage is visible through an iPad or iPhone mounted to the transmitter. 

Stabilization and positioning of the aircraft during flight is maintained by an onboard 

GPS system that is integrated into the UAS electronics from the factory. No aftermarket 

system is or will be installed.

5. Prior to any flight, all prop blades are firmly tightened. Any chipped prop blades are 

replaced with new ones prior to take off. All systems are checked prior to take off. The 

UAS requires a warm-up period during which time the gimbal systems for the camera are 

checked as is the camera. All warning lights are checked to make sure they are not 

inactive and all software updates have been conducted prior to the flight. Weather

conditions are also checked. Wind, Rain, and Snow are conditions that will prevent a 

flight. I will not operate the aircraft in these conditions nor will I operate the aircraft in 

the dark. Should any systems or parts not be working, I will not operate the UAS as that 

would potentially endanger property, myself, or those around me.

RF 

1. The Radio Frequency (RF) spectrum used for this UAS is 2.400 GHz-2.483 GHz. 

Maximum distance for this signal is 3.1 miles (unobstructed, free of interference) when 

FCC compliant. For my purposes to to comply with VLOS, the aircraft will not fly to 

this distance. Video output from the aircraft is via USB to the mobile device mounted to 

the transmitter. Receiver sensitivity is -101 dBm +/- 2 dBm. Transmitter power is 20 

dBm per requirements of the FCC.

Pilot & Observers

1. I have logged many hours in other UAS prior to the operation of my present UAS or 

Phantom. These were mostly toy aircraft in nature and were not as advanced as the 

present UAS I am operating. They are also not for commercial use whereas this present 

one will be used for such reasons.

2. An observer will only be on site for property surveys that may require an extra set of 

eyes. Reasons for this could mean, trees, power lines, or other obstructions that might 
not be noticed by the pilot. Prior to all flights however, a site survey will be done on foot 

to check for potential aerial obstacles. His or her job will also be to monitor present 

weather conditions for wind, rain, or snow or other conditions that could make operation 

of the UAS dangerous.

Intended Operations

1. The UAS will be used for property surveying for real estate companies/agents as well as 

for private property owners of their personal properties. Steps will be taken for safety 

during these flights. These will include:

a. Full walk-around of the property to check for potential flight hazards

b. Blocking off of flight equipment, where the ground station will be located and 

where the pilot will be present. This may involve orange cones or other means of 

protection. 

c. As the pilot will be maintaining visual contact with the UAS at all times, I will be 

wearing a reflective bright colored safety vest or other means of identifying that I 

am working on something and to avoid being close by for the safety of bystanders 

who may be curious as to what is going on. If issues with too many bystanders 

become an issue, I will immediate cease flight and if necessary, land the UAS 

until I feel I can continue without risking bystanders. 

d. Caution tape and other signage will be employed as needed depending on the size 

and scope of the project.

e. If the property is occupied, as in the case of a landlord owned property, I will ask 

that the landlord notify their tenants at least a week in advance that a UAS will be 

operating around the property.

2. The UAS will be used for surveying and documenting historic buildings/structures for 

clients, organizations that hire me, property managers, etc. Steps will be taken for safety 

during these flights. These will include the same safety steps as above, except in these 

instances I will have an extra spotter as well as the client on hand with me during the 

surveying. The extra spotter and the client will be reviewing the video feed from the 

UAS during flight while the first spotter will be watching the UAS and I will be 

maintaining visual contact with the UAS as the pilot in charge (PIC).

3. The UAS will be used for aerial videography and photography. These services may not 

be done as frequently as the primary reasons for the exemption request are the surveying 

of properties and the documenting and surveying of historic structures.

Proposed Maximum operating speed & altitude

1. While the UAS is capable of speeds of 16 m/s (35 mph), for my purposes I will more 

than likely never exceed half that speed. My speed will be more of the pace of an 

average walk as the purposes of my work are to document and survey and slower speeds 

allow for better clarity of the videos and photographs. Operating altitude is expected to 

be around 100 feet maximum though I don’t plan to go much higher than 150 feet should 

I exceed my desired maximum height of 100 feet. The likelihood of me going to 100 feet 

during my work will not be likely though but it does allow for some leeway. As this is 
my intended speed and altitude, distance I plan to operate near the clouds isn’t applicable 

though I don’t intend to operate the UAS in fog either. Therefore visual contact with the 

UAS will always be maintained and if the situation doesn’t allow for that, the aircraft will 

not fly.

Proximity to population

1. Since the UAS will be used to document and survey properties, the possibility of 

encounter with bystanders is high. To prevent this, as stated in previous sections of the 

exemption request, I will mark off the area that the ground station will be located and 

provide myself as the pilot, and my observer should I require one, with appropriate 

reflective or brightly colored gear so as to identify that a UAS is in operation. Caution 

tape, signage, and orange cones will also be used as needed to mark off the location that 

the UAS is operating.

2. The UAS will not operate near an airport. As it is not planned to operate to operate much 

higher than a maximum of 150 feet, risk to aircraft will be minimal. That being said, if a 

potential client wants me to document or survey a property that borders an airport, I will 

obtain further authorization from the FAA, or refer the client to another UAS operator.

Compliance with VLOS and Preflight procedures

1. To comply with Visual Line of Sight or VLOS, the UAS will be flown in clear weather 

conditions with the PIC maintaining visual contact with the aircraft during flights and, if 

required, a spotter present to watch for potential obstacles and to watch the aircraft as 

well.

2. During start up of the aircraft, the engines run at a lower speed prior to lift-off speed. 

This allows for checking of the aircraft for anything that could potentially lead to 

problems during flight. Prior to initial start-up, however, all mechanical components as 

well as the prop blades will be checked for potential debris inside the motors and for 

potential damage to the motors, prop blades, as well as fuselage. If any issues exist that 

could adversely affect the flight of the aircraft, the UAS will not fly until those issues are 

taken care of.

The UAS will not be operated outside the United States.