Drone/UAS Practice Group

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave S.E. Washington D.C. 20590 Jeff Lape 4456 Altadena Dr Bay City, M148706 {989} 475-3867 Jeffery. Lape@Century21.com July 24, 2015

Re: Request for Exemption under section 333 of the FAA Modernization and Reform Act of 2012 and part 11 of the Federal Aviation Regulations from Certain Provisions of 14 CFR. Dear Sir or Madam, This petition is being submitted on my own behalf, and serves as a request to utilize an unmanned aircraft to obtain aerial video and still images for Real E state business marketing activities for myself and for hire . The reque s ted exemption would permit me to service my own marketing and promotional needs in the Real Estate Industry, a s well as those of people who choose to hire me for similar photography needs utilizing a small unmanned aircraft in the following areas:

- Real Estate Marketing/Inspection

- Community and Event Marketing

- Surveying/Mapping Allowing this exemption would be in the public's best interest, because it will allow property sellers to have their property and homes marketed from the bes t possible angles. This will also remove barriers for buyers to see areas of the properties /homes that they may not otherwise be able to s ee due to physical handicaps and other restricting factors such a s roof accessibility. Therefore, utilizing the advanced technology and lightweight nature of th e UAS will result in lower emission s, less noise, and less danger to obtain thes e close proximity images /video compared to traditional aerial photography techniques. In ess ence, current low cos t technology allows me to use an extremely lig htweight, gyroscopically balanced model aircraft {UAS) to perform beneficial tasks in both promoting real estate, and overcoming s afety obstacles for a wide variety of clients , including those with disabilities to view areas th a t would normally be inaccessible to them . I am as king for exemptions based on the fact that with such an inexpensive way for handicapped, as well as non-handicapped individuals to obtain superior viewpoints from a device that is designed for a respon sible 14 year old to safely operate without any significant danger to nearby bystanders, there should be no reas on to withhold that opportunity from them . With the Syma X5C only wei g hing 3.7 ounces with batteri es and camera, it should pose virtually no threat of danger to the publi c, even up close .

### UAS Pilot in Command (PIC) Under 61.113 (a) and (b), private pilots are limited to non-commercial operations . Under 61.315 (a), sport pilots may not fly for compensation or hire and must not fly for the purpose of furtherance of a business . Also under 61 . 101 (e) (4) and (5), recreationa l pilots may not fly for compensation or hire . They must also not fly in the furtherance of a business, but this aircraft will not carry any pilots or passengers, because it only weighs 3. 7 ounces fully loaded. Furthermore, a private pilot' s license will not ensure remote control piloting skills, so I am asking to be exempt from having to possess a pilot license to fly this 3.7 ounce model aircraft that can be safely flown by most people 14 years old or older due gyroscopic stabilization technology. I will have a current driver's license and real estate license in my possession at all times while operating the UAS for business purposes. I received pilot training from Peter J 

### Kamarainen, CFI with Grand Air Aviation in Grand Ledge, Ml and have legally soloed in a Cessna 152 aircraft, but do not currently possess a private pilot' s license. I also flew radio controlled aircraft, and was considered an expert in that field while I worked selling, servicing and designing radio controlled ai rcraft at Rider' s Hobby Shop in Lansing, MI. This unique background has put me in a position to explain the difference between flying a manned aircraft and an unmanned aircraft. In addition, this 3 .7 ounce aircraft is not capable of doing any significant damage when operated responsibly, especially when equipped with bumpers designed to create a buffer zone between the moving parts and any potential obstacle. Under 61.23, a person must hold a medical certificate, and although that would be justified in a majority of cases for most pilots who fly manned aircraft and some larger, more sophisticated unmanned aircraft, it should not be necessary to fly a 3.7 ounce UAS that will only be flown for 3-5 minutes at a t i me. Unmanned Aircraft System Syma X 5C E xplorers (Instruction Manual Attached) 4 channel 2.4G Remote Control Quadcopter with HD camera, 6 axis gyroscopic stabilization system , for indoor or outdoor flight, and rat ed for ages 14+ . Equipped with blade protecting frames that act as bumpers that shield objects from moving propellers. Fuselage size of approximately 12 W' x 12 W' x 3" . Weighs 3.7 ounces with battery and came ra. Equipped with colored lights that help the PIC perceive the aircrafts orientation in flight . This aircraft also has an over-current protection system designed to stop the moving blades if they collide with an object and are jammed in any way. Equipped with flashing light to indicate low battery life . Automatically return s to level and smooth hover when you let go of the control s ticks . 91.1 2 1 altimeter regulations were designed for a completely different flight application than this ultralight UAS will ever see under the terms of this ex emption.

### Under 91 . 1S1 (a} (1}, fuel requirements for a completely different type of aircraft are established , but do not ta ke into account the reserve fuel requirements of a UAS that will always be within 1S seconds from a safe landing at any given time during it' s intended use. 91.40S (a} requires maintenance requirements that do not apply to this type of aircraft . 91.407 (a} (1} does not apply to this type of aircraft . 91.409 (a} (1} and (2} are maintenance requirements that do not apply to this aircraft . 91.417 (a} and (b) should not apply to this type of aircraft. UAS Operating Parameters The choice of this smaller than typ ical lightweight, stable, quiet, and easy to control UAS was to be able to safely take photos and videos relatively close to the exterior of homes as well as take videos of interiors from perspectives that may otherwise be unsafe to ach ieve. I 

### will: Always make safety our number one concern and will take appropriate precautions to assure the safety others, as well as myself. Never operate in a manner that poses danger to others, nor myself. Never operate in any fashion that would potentially damage objects or structures . Never operate in low visibility conditions or fog . Post no less than three highly visible signs around the property we are filming , for business purposes, notifying people that aerial photography is in progress. Stay as far as reasonably possible from neighboring structures and any bystanders, but since many ofthese homes are suburban areas we will have to be much closer than the SOO feet away that is typically prescribed fo r much larger UAS's. Operate UAS only within visual line of sight (VLOS} . Never operate above SO feet AGL when within Smiles of an airport without prio r consent from that airport. Since the purpose of this exemption is to photograph residences, there should be no air traffic even close to the SO feet AGL ceiling in locations where this flying camera (UAS} will be operated . Operate without a visual observer (VO} . Due to the extremely small size and lim ited capabilities of this tiny UAS, it is too small to see from the kind of distances that would put it into the airspace in which there may be a conflict with any other aircraft that the VO 

### would be watching for. In addition, this tiny UAS is so small it would be difficult for aVO 

### to s

ee from too many angles other than the pilot's perspective, making the VO's 

### job redundant at such close proximity.

### Always observe the aircraft for the low battery indicator status light and land immediately after it is activated, which will be less than the prescribed 5 minutes, because the total flight time of this tiny UAS is barely over 5 minutes. Under 91.119 (b) and (c), there are limitations on how close you can fly to objects and structures. The UAS we will be using was designed to be flown indoors and outdoors, as opposed to most aircraft that were not designed to be flown indoors, so if I am to utilize this UAS in a manner it was designed for and is stated in the user manual, I shou ld have no barriers in distance from buildings or objects. Summary I am requesting this exemption, because due to current technology growing much faster than the legislation needed to regulate it, we are caught in a time period where I am required to operate under the same rules that were put in place to regulate air traffic for passenger aircraft that operate above 500 feet AGL, even though I am just essentially using a 3. 7 ounce stabilized flying camera, designed for indoor and outdoor use, that will allow me to reach shot angles that will be within 100 feet from me most of the time. The most current rules affecting UAS even address a completely different group of aircraft than I will be using, and in far different applications than I am requesting. A Private Pilot's license would do very little in qualifying me to fly this aircraft under the conditions I am requesting. I have received flight tra ining in the past and am awa re of airspace rules and regulations. When I was considered an expert in radio controlled aircraft for Rider's Hobby Shop of Lan sing, I had many private and commercial pilots purchase aircraft from me. Most of them thought they would be able to fly those aircraft, because they were pilots. I had to explain the difference in skills required to fly them an d line the licensed pilots up with the appropriate training programs. Some ofthe pilots did not follow my recommendations, and most of those came back after they crashed an aircraft or two to get information on the appropriate AMA sanctioned training programs. Due to the limitations of such a tiny UAS, most of what I will be using this for is to reach further than I can currently reach with a camera on a stick, by climbing trees, getting on roofs, or setting up scaffolding, and this 3. 7 ounce device packed with many safety features is a much safer and less damaging option for everyone around. Safety is my number one priority. During norm al operation, I will need to fly this camera (UAS} around houses th at may be 30 feet away from a neighbor's home, located in populated areas within 5 miles from an airport, and I may need to fly close enough to a chimney to take a photo of a mortarjoint, or of a chimney flu. This UAS does not pose the same hazards as a 50 pound drone flying under those conditions, nor does it present the same hazards as a 2,000 pound passenger aircraft flying under those conditions either. Therefore, there would be no need for a 3 mile visibility requirement when flying line of sight up close, no need to stay within 500 feet of neighboring structures, or non-participating peop le, and due to this UAS's unusually small range and slow speed, there would be no need for aVO to be used to spot for this UAS. Thank you for your consideration

### ® AGES 14+

# X5CIJfllliJW~ 4CH2.4G REMOTE CONTROL QUADCOPTER 

# b.. INSTRUCTION MANUAL IMPLEMENT STANDARD: GBIT26701-2011

## PREFACE

iillii 

### -1-

### GET TO KNOW YOUR TRANSMITTER 

### Introduction of transmitter .----Antenna --Yf--r:l\.r-- Indicator High/Low speed switch \ Left control --;1..--''4 / 30 Eversion/photo and video (this function for item no. XSC) 

## .......----=.... Right control lever lever (Accelerator)

**~~~\\**

Power ON/OFF 

### Remote control Installing the battery

Figure 1 Figure 2 4XAA(LR06) 1 .5V Batteries 1. Use a screwdrive r to remove the screw on the back of transmitter,than open the battery

cover(Fig ure 1) . 2.1nstall 4 "AA" batteries (not included) into the back of transmitter than replace battery

cover and reinstall the screw (Figure 2). 

### 1.1nstall batteries with correct polarity. 

# A 2 .0o not mix old and new batteries . 3.0o not mix different types of batteries . REMOTE CONTROL KEYPAD AND LCD MANUAL



### -2-01 . Sideward Fine-tuning : Power-on start in the centering .(Be turn LefURight Fine -tuning in Mode2) 02 . Forward/Backward fine-tuning:Power-on start in the middle . 03 .Turn Left/Right fine-tuning :Power-on start in centering . (Be Sidewoard Fly Fine -tuning in Mode2) 04 .Throttle lever fine-tuning: Power-on start in middle . OS. Throttle show: Power-on start in lowest levei.(Left and Right throttle shows at one time) 06. Forward shows : Power-on start in the lowest levei.(At the center spuare) O? .Backward shows: Power-on start in the lowest levei.(At the center spuare) 08 . Right sideward fly shows:Power-on start in the lowest levei.(At the center spuare) 09 . Left s ideward fly shows: Power-on start in the lowest levei.(At the center spuare) 10.Turn left: Pull left function lever to left, it will be higher, than quad copter turn left faster. 11 .Turn right: Pull left function lever to right , it will be higher, than quad copter turn right faster. 12 . High/Low speed : Press button "A" for seconds to switch between high speed mode or low speed mode. "H " means high speed and " L" means low speed . 1 3.Power shows:Accord ing to the battery's energy for the controller. 14 . Default mode when power-on .When change to MODE 2 , please keep pressing button " B" to right than return on the power of transmitter, the MODE on LCD displayer will be changed . Same steps to change to MODE 1 again . 15.Signal shows :Normally to full frame . 

### READY TO FLY YOUR QUADCOPTER

Step 1 : Press the ON/OFF Step2 : Open the battery Step 3: Close th e battery cover and turn on the quadcopter. power switch up . cover and insert the



# $~c [MJ battery into power port. Step 4:Push the throttle lever to the highest position , and then pull it back to the lowest position . There will be one clear sound from the transmitter, this shows that the quadcopter has entered into the pre-fly state .

TIPS :When syncing your quadcopter keep it in a horizontal position to start to a stable flight. 

### -3-1 .When the indicator of transmitter keep light on but the indicator of quadcopter is blinking slowly, it means signal matching was not successful. Please turn off the power both of transmitter and quadcopter than restart the transmitter and quadcopter. 2 . 1f the quadcopter is till flying to on side dramatically or spinning while hovering ,

please switch off the power of both the quadcopter and transmitter and then repeat the pre-flying steps . 3 .When the indicator of the quadcopter keeps flashing slowly, it means that the

quadcopter has entered into the low battery state . This time you need to charge the quadcopter with the USB cable provided . 

### CHANGE BATTERY OF QUADCOPTER

1 . Push the on/off switch of quadcopter

to OFF position than open the battery cover.

3.Take out the USB charging cable ,

and insert the battery power port to the small end of it (Make sure the ports connect tight and correct ) .

5.Reconnect the battery wire to

power port than close the battery cover. 2.Pull out the battery wire from the power port.

4.To charge battery, please insert the

USB port of provided USB charg ing cable to anyone USB port of computer. The indicator on USB cable will light ON during charging battery, than it will light OFF when battery fully charged . Caution : When using the computer for charging , please remember to pull out the charging cable before shutting down the computer.Take the battery cover , and close the battery cover on the quadcopter. Charging t1me about 75 mmutes- Fly1ng time · about 7 minutes I 

### -4-1 .When charging, please put this product on a dried or ventilated area and keep it far away from heat source or explosive product. 2 .When charging , please remove the batteries from the quadcopter . Then charging process should be supervised by an adult so as not to cause an accident. 3.After flying , please do not charge the battery ifthe surface temperature is still

not cool. Otherwise it may cause a swollen battery or even a fire hazard. 4 . Piease make sure that you use the original USB charging cable provided.When

the battery has been used for a long time , or appears to be swollen , please replace them . 5.A battery when not in use for a long time will lose its charge automatically.

Charging or discharging too often may reduce the life of the battery. 1 . Battery shou ld be put in the dried or ventilated place with enviroment

temperature about 18-25·c . 2 .1n order to enhance the using life of the battery, please avoid repeat charging

or excessive discharging . 3.When the battery needs to be stored for a long time ,please charge the battery

first.That is to say, charge the battery for about 50-60% of the volume and then well store it. 4. 1f you do not use it for more than 1 months , it's highly recommended that you

need to check the battery voltage every month so as to make sure the voltage no less than 3V. Otherwise please do by following No .(3) mentioned . 

### INSTALL LANDING SKIDS 

## & BLDAE PROTECTING FRAME

Figure . 1 Figure.2 1 . 1nstall the landing skids to the bottom of quadcopter (Figure 1 ). 2 . 1nstall the blade protecting frame to every corner than lock screws (Figure 2) . 

### CONTROLLER MODES & 

### INSTRUCTIONS



### -5-

## MODE1 Operating direction Hover up and down 

# l Push the throttle up or down , the quadcopter flies upward or downward. 

## Turn Left and Right

Pull the throttle left or right, the quadcopter turns to left or right. 

## Fine-tuning operation Forward and backward

Push the direction lever up or down , the quadcopter flies forward or backward .

Pull the direction lever left or right , the quadcopter flies to left side or right side .

Forward/Backward fine-tuning Sideward fly fine-tuning Turn left/right fine-tuning

When the quadcopter keeps flying forward I backward , you can correct it by pressing fine-tuning button down I up . When the quadcopter keeps flying to left I right side , you can correct it by pressing the Fine-tuning button right /left . 

### -6- 

# .~~~· 

# • When the quadcopter keeps rotating to left /right , you can Correct it by pressing the fine-tuning button right /left .

## MODE2 

## Operating direction Hover up and down 

# t 

# t

Push the throttle up or down, the quadcopter flies upward or downward. 

## Turn Left and Right

Pull the direction lever left or right, the quadcopter turns to left or right. 

## Fine-tuning operation Forward and backward

Push the direction lever up or down , the quadcopter flies forward or backward. 

## Sideward fly

Pull the throttle left or right , the quadcopter flies to left side or right side. Forward/Backward fine-tuning Sideward fly fine-tuning Turn left/vright fine-tuning

When the quadcopter keeps flying forward I backward , you can correct it by pressing fine-tuning button down I up . When the quadcopter keeps flying to left I right side , you can correct it by pressing the fine-tuning button right /left . 

### -7- When the quadcopter keeps rotating to left /right , you can Correct it by pressing the fine-tuning button right /left .

### INTRODUCTION TO QUADCOPTER FUNCTIONS Low-voltage protection: When the quadcopter battery is not enough , the rotors wi ll be stopped power supply.As the quadcopter control systemwill p rotected battery automatically. 

### Over-current protection: When the quadcopter's rotating b lade is col lided o r jammed , the control system will stop supplying power for the rotors automatically, Then please re-match the signal for flying . 

### Restart function: In case of flight d isord er or sideward flight , restore factory default setti ngs by the following methods:



# 1:**~~0**

**~~ ~**  (r£1 

## CD. Press the power switch to turn on the transmitte r. (2) . Press the power switch to turn on the quadcopter. @.When th e quadcopter indicato r quickly flashing to slowly flashing ,please push the throttle leve r to the highest position ,and then pull it back to the lowest position.Then the quadcopter indicator changed from slowly flash ing to normal lights up . @. Place the quadcopter on a horizontal postion , then push transmitter both left and right lever to lowest right conner for about 2-3 second , indicator on the quadcopter changed from normal lights up to quickly flashing ;After 2-3 second ,the indicator changed to normal lights,it means t he quadcopter restarted /reset successfully. 

### 30 EVERSION AND THROWING FLIGHT INSTRUCTIONS When you are familiar with the basic operation , you can do some awesome & exciting tricks and stunts ! First of all , fly the ai rcraft to a height of more than 3 meters , press the 3D Eversion switch on the rear right side of th e transmitter, then push the right rudder(in any direction) to make 360 degree flip. Tips:3D eversion goes better when battery power is enough. 

### -8- 

# ry~



# r~~~

**~** TThanks to the 6 axis gyroscope, you can throw the quadcopter and push the throttle right up, it will automatically level out and hover smoothly in the sky, This can also be done when the quadcopter isrolling. 

### INSTALL CAMERA

1. Push the camera into a hold on the battery cover (Figure 1). 2. Open the battery cover with camera (Figure 2) . 3. Lock screws to add-on the camera tight (Figure 3) . 4 . Close the battery cover with camera than insert the 3-pin plug to the hold in side (Figure 4). 

### PHOTOGRAPHY 

## I VIDEO INSTRUCTIONS: 1 . Methods : 

## CD Make sure the 3-pin plug of camera is inserted to the quadcopter. @Turn the quadcopter power on, the camera works normally when the RED indicator change form flashing to green and keep l ight on. Ifthe RED indicator just light on and light off seconds later, it means the SD card is not in the camera. Please insert the SD card, than the indicator light on GREEN . 2. Get to know take photo and video:



## CD Turn on the transmitter and pu ll left lever up and down ..,....----, to connect signal between quodcopter and transmitter. ,_"'""..,. @ Take Photo: Make sure camera normally work, press the button on top right corner one time, camera will take a photo after a beep from transmitter when the GREEN indicator on camera flash one time in RED. @ Take Video : Make sure camera normally work, press the button on top right corner for seconds, camera start take video when a beep from transmitter and the GREEN indicator on camera change to RED and keep flashing. Press the button slightly again , another beep means video stopped and the RED flashing indicator on camera will keep light on GREEN .



### -9-

### TROUBLE SHOOTING Problem Reason Solution No response 1 .Quadcopter battery power not enough. 1 .Charge the

**quadco~ter** 2.Transmitter battery power not enough. 2.Charge or replace t em if required. from the 3.The band of the transmitter does not 3.Adjust the band on the transmitter and quadcopter correspond to the decoding of the keep it the same as the quadcopter. quadcopter. If the quadcopter 1.1nsuffcient power with the tran smitter. 1.Replace the battery. is slow to respond 2 .Transmitter of the same frequency is 2 .Use the helicopte r out of the range of or d ifficult to used nearby. other RC quadcopter. manoeuver 

### SPARE PARTS

All the sare parts below can bought from local distributor. 

# CCJDD X5C-01 Body cover



### X5C-05 Motor holder



### X5C-09 Light boards



### X5C-13 Camera 

### X5C-02 Main blades



### X5C-06 Lampshades



### X5C-10 Receiver board



### X5C-14 Transmitter 

### -10- 

### X5C-03 Protecting frames



### X5C-07 Motor A



### X5C-11 Battery 

### X5C-04 Landing skids



### X5C-08 Motor B



### X5C-12 USB charging cable

### BREAKDOWN & DIAGRAM

04

# 13**-04**

Code Description Quantity Code Description Quantity Code Description Q uantity 

### 01 Upper body 

### 08 Receiver motor 

### 2 15 Gear 

### 4 02 Lower body 

### 09 Motor holder 

### 4 16 Landing skids 

### 2 03 Rotating blade 

### 2 10 Lampshades 

### 4 17 Camera 

### 04 Reversing blade 2 

### 11 Light boards 

### 4 05 rotecting frame 

### 4 12 Receiver board 

### 06 Battery cover 

### 4 13 Battery 

### 07 Rotating motor 2 

### 14 Battery cover 

### -11-