July 7, 2015

U.S. Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113(a) &(b); 91.7 (a); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) &(b).

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Greg Morris, operator of an Unmanned Aircraft System (UAS) DJI PHANTOM 2 VISION PLUS AND INSPIRE I, hereby apply, on behalf of Morris Richardson Real Estate, for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outfined herein or as may be established by the FAA as required by Section 333. I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and photography real estate purposes and events. Applicant: Greg Morris, Owner Morris Richardson Real Estate 3148WM55 West Branch, MI 48661 Greg@Mrrehomes.com 989-329-4396 Commercial operation of an UAS, as described herein, which are equipped with camera and sensors, would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate and other related professional activities.
• Aerial video and/or photography for public and/or private use including public and private events. As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) willprovide safety enhancements to the already safe operations in the industry presently using

conventional aircraft Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation responsibilities to "....establish requirements for the safe operation of such aircraft systems in the national airspace system." As found in Exemption No. 11138 (Trudeau), the FAA recently approved similar use of a PHANTOM 2 UAS. We will operate a UAS, the DJI Phantom 2 VISION PLUS, which is comprised of an unmanned aircraft (UA or Phantom), an attached 4K camera and a transportable ground station. The PHANTOM 2 is a quad-copter with a gross weight of 2.8 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. It will be operated over various rural areas, primarily around West Branch, Michigan, to augment real estate listing videos, capture event areal video and photography, and related business operations. UAS Operating Parameters We will abide by the following additional operating conditions under this exemption, which ensures a level of safety at least equal to existing rules:

• operate UAS below 300 feet and within a radius distance of 1000 feet from the controller to aid in direct line of sight visual observation;

• obtain permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard;

• operate the UAS for 5-10 minutes per flight;

• land UAS prior to the manufacturer's recommended minimum level of battery power;

• operate UAS during daylight hours only within visual line of sight (VLOS);

• use the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if comrnunication with the remote control pilot is lost;

• conduct all operations under the flight safety protocols (including posting a warning sign reading: "Attention Aerial Photography in Progress - Remain Back 150 feet") contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance safety protocols;

• contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation; have procedures in place to abort flights in the event of safety breaches or potential danger;

• only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports and densely populated areas (defined by areas depicted in "yellow" on VFR charts and through obtaining inforrnation regarding congested areas from the local Flight Standards District Office (FSDO);

• conduct extensive preflight inspections and protocols, during which safety carries primary importance (reference PHANTOM Flying Flow Chart and User Manual). Regarding UAS operational training, we have flown numerous practice flights in remote areas as hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of the UAS' performance under different temperature and weather conditions.will not begin a flight unless (considering wind and forecast weather conditions) there is enough power

to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

Public Interest Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts and increase business success. The industry is not new. However, until recently it was conducted through the use of costly manned aircraft, a prohibitive business activity for small companies. By granting this exernption I would be able to provide affordable services. Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft Additionally, the operation of our UAS will minimize harm to the environment economic growth by providing information to companies and the public looking to relocate or build in the metro areas we service. Public and private events serviced by our business enhance vibrancy and add culture to the community and its citizens. 

### Summary We will comply with all of the following conditions and limitations should this exemption be provided: 1) Operations will be limited to the following aircraft described in the operating documents, which is a quad-rotor aircraft weighing 2.8 pounds: Phantom 2 and Inspire I Unmanned Aircraft System. 2) The UA will not be flown at an indicated airspeed exceeding 50 knots. 3) The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), AII altitudes reported to ATC must be in feet AGL. 4) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. 5) AII operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight The PIC will ensure that the VO can perform the functions prescribed in the operating documents. b) The operating documents will be accessible during UAS operations and made available to the Administrator upon request Any revisions to the operating documents will be presented to the Administrator upon request 7) Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight The Ground Control Station will be included in the preflight inspection. AII maintenance and alterations will be properly documented in the aircraft records. 8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight The PIC who conducts the functional test flight will make an entry in the aircraft records. 9) The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items, or equipment not already covered in the relevant sections of the operating documents. Zo) We will follow the UAS manufacturer's aircraft/component maintenance; overhaul, replacement inspection, and life limit requirements.Any PIC operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR

61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. The PIC will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations. In addition to the hour requirements, the PIC will accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes) prior to any flight Specific Exemptions Requested Given the size, weight speed, and limited operating area associated with the UA, we feel an exemption from 14 CFR part 21, Subpart H(Airworthiness Certificates) and § 91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333). We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement Regardless of this, we can mark the UAS in the largest possible (ettering by placing the word "ExperimentaP" on its fuselage as required by § 45.29(f) so that anyone will see the markings. We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness certii•Icate, since there is currently no certii'tcate applicable to our operation, this regulation is inapplicable. We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we will perform a preflight inspection of the UAS before each flight as outlined in the attached operating documents. We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station. We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus "providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes." Given the size, weight, maneuverability, and speed of the UAS, an equivalent or higher level of safety will be achieved. We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor. We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two Iow battery alerts are issued - per the operating documents, the UAV will be landed at the first alert Also, our flights will last only 5-10 minutes each, and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC11) We will carry out maintenance, inspections, and record keeping requirements, in accordance

with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 12) Each UAS operated will comply with all manufacturer Safety Bulletins. 13) An authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at least a current third-class medical certificate. The PIC will 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. 15) Prior to operations conducted for the purpose of aerial videography/photography and for real estate listing videos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. 16) Prior to operations conducted for the purpose of aerial videography/photography and for real estate listing videos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations. The PIC will accomplish 3 take-offs and landings in the preceding 90 days. 17) The PIC will not operate the UAS for the purpose of aerial videography/photography and for real estate listing videos and public and private events and similar operations, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 18) UAS operations will not be conducted during night; as defined in 14 CFR 1.1. AII operations will be conducted under visual meteorological conditions (VMC). 19) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart 20) The UA will 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. 21) If a UA loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. 24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 25) Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request27) The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times. 28) The UAS will not be operated by the PIC from any moving device or vehicle. 29) The UA will not be operated over congested or densely populated areas. 30) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

cl. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident We will 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 and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission 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, and;

C. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 31) AII operations will be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If you have questions or need additional information, please contact me at greg@mrrehomes.com or 989-329-4396.

Th n k yo u,

Greg Morris, Owner Morris Richardson Real Estate

## AGL Above Ground Level

AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard OperatingProcedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing

# 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.

Switch on the transmitter, and FailSafe then power on the PHANTOM. LED: Blink Yellow 000000000 Quickly Senser Error Too Big LED:Red+ 0000000i00000 System Start Green+Yellow ~ ®O

~ lO

~ ®O
& Self-check Compass Error Too Big

( LED:Red+Ye1low
IOC On & If Red LED appears in the last four 30s after power on LED : Mode +GPS Satellite I----- Number+6Yellow green flashes, the autopilot system 6Yello',i tniatts v,atttutty up Cannot work.
IRecording IOC Off & I LED : Blink is ok. ~ Warniing up is ok. Green Quickly Important: If PHANTOM is L► Record the — ~ LED : Mode +GPS Satellite

forward LED : Mode + Number+6Green rnoved after power on and GPS Satellite Number 6Green means motion detection. before tt i e motors start-up, direction. that is normal. Any GPS Satellite Number GPS Satellite Number>_6 If it is stationary on the ground, please try the IMU 

# ,F-- Basic Calibration. ATTI. Mode GPS ATTI. Mode

Iniportant: At any monient after power on, if the GPS Satellite number is less than 6 and last for at least 10s: even though you select the GPS ATTI. Mode and LED blinks in the GPS ATTI. Mode, the PHANTOIv1 will work in ATTI. Mode. 

### Method of Start Motor l 1

~ 

### . Oaa

~

W- ~

'I
GPS Satellite Number<6 Keep Leveling 000000000

~~ &Landing FailSafe Importarit: Wiien you switch to ATTI. Mode, the

rnain controller will disengage enhanced FailSafe mode, you can re-gain control of aircr

- aft. GPS Satellite Number?6 Return to the

Home Point 000000000

— ~ GPS Satellite Number>_6, in GPS ATTI. Mode,

Distance between the Home Point and

~ PHANTOM>10m. Home Lock GPS Satellite Number>_6 &IOC On

— — Start Motors

Mcord : Blink Green Quickly the Home Point

Home Point

~ Recording is ok ~
IOC StE

Flying —

♦ / Course Lock
First Level 000000000 Protection Alert A IOC Ending♦

Second Level 0400000000 Protection Alert

&Height Descent

' ED

Power off the PHANTOM, and then switch off the transmitter Green Part means normal procedures:

—♦ means regular situation.► means selectable or possible situation. Pink Text tells the details. Red Part means possible abnormal situation. Part is possible in normal or abnormal situation, require you to confirm by the i.

~ xt for details. Blue Part is the condition of the normal situation. Purple Part is the condition of the abnormal situation.

## Monthly Maintenance Log

UAS # Date Issue Mantainence Performed Initials
Firmware Check Frame En ines Pro ellers Camera Gimbal Landing Gear Vibration Other: