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) will 
provide 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 PIC 
11) 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 request 
27) 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.comor 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: