Request for Section 333 Exemption.

Zachary Nathan Ingalls

1626 W. 21 st 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 ag ents, 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 cam era. The reason behind this is to provide a n alternative means of photography that is different from the more traditional stati onary camera from the ground. I t is also believed that providing video of a property provides a greater representation of the present cond itions 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 pub lic for my opera tion 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 i n. 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 cli m bing on to the roof or using a ladder when inspecting the present condit ions 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 perso ns, 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 weatherconditions to allow for continued safe flight. Th at 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 airc raft 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 rem oved via mechanical fasteners (screws).

3. The UAS maximum ascent speed is 5 m/s. It ’ s maximum descent speed is 3m/s. It s maximum speed is 16 m/s however it will never be flown at these maximums as I prefe r to have smooth flight for the purposes of my wo rk 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 thi s 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 mai ntained 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 ar e 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 a re 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 cond i tions 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 si gnal is 3.1 miles (unobstructed, free of interference) when FCC comp liant. 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. Th ey are also not for commerci al 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, pow er lines, or other obstructions that mi ghtnot 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. B locking 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

pro tection.

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 bysta nders 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 a n 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) , f or 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 t he 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 desi red 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 ismy intended speed and altitude, distance I plan to operate near the clouds isn ’ t appl icable

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 th e 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 o perator.

Compliance with VLOS and Preflight procedures

1. To comply with Visual Line of Sigh t 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. Du ring start up of the aircraft, the engines run at a lower speed prior to lift

- off speed.

T his allows for checking of the aircraft for anything that could potentially lead to problems during flight. Prior to initial start

- up, however, all mechanic al 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 w ill not fly until those issues are

taken care of.

The UAS will not be operated outside the United States.