Drone/UAS Practice Group 

U.S. Department of Transportation 

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 Estate business marketing activities for 

myself and for hire. 

The requested exemption would permit me to service my own marketing and promotional needs 

in the Real Estate Industry, as 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 best possible angles. This will also 

remove barriers for buyers to see areas of the properties/homes that they may not otherwise be 

able to see due to physical handicaps and other restricting factors such as roof accessibility. 

Therefore, utilizing the advanced technology and lightweight nature of the UAS will result in lower 

emissions, less noise, and less danger to obtain these close proximity images/video compared to 

traditional aerial photography techniques. 

In essence, current low cost technology allows me to use an extremely lightweight, gyroscopically 

balanced model aircraft {UAS) to perform beneficial tasks in both promoting real estate, and 

overcoming safety obstacles for a wide variety of clients, including those with disabilities to view 

areas that would normally be inaccessible to them. I am asking 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 responsible 14 year old to safely 

operate without any significant danger to nearby bystanders, there should be no reason to 

withhold that opportunity from them. With the Syma X5C only weighing 3.7 ounces with batteries 

and camera, it should pose virtually no threat of danger to the public, 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), recreational 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 aircraft 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 time. 

Unmanned Aircraft System 

Syma X5C Explorers (Instruction Manual Attached) 

4 channel 2.4G Remote Control Quadcopter with HD camera, 6 axis gyroscopic stabilization 

system, for indoor or outdoor flight, and rated 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 camera. 

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 returns to level and smooth hover when you let go of the control sticks. 

91.121 altimeter regulations were designed for a completely different flight application 

than this ultralight UAS will ever see under the terms of this exemption. 
Under 91.1S1 (a} (1}, fuel requirements for a completely different type of aircraft are 

established, but do not take 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 typical 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 achieve. 

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 of these homes are suburban areas we will have to be much closer than the 

SOO feet away that is typically prescribed for 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 prior 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 limited 

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 

see 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 should 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 training in the past and am aware of 

airspace rules and regulations. When I was considered an expert in radio controlled aircraft 

for Rider's Hobby Shop of Lansing, 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 and line the 

licensed pilots up with the appropriate training programs. Some of the 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 normal operation, I will need to fly this camera (UAS} around houses that 

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 

mortar joint, 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 people, 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~ 4CH 2.4G 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 screwdriver to remove the screw on the back of transmitter, than open the battery 

cover(Figure 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 sideward 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. 

13. Power shows:According 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 the 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 quad copter than restart the transmitter and 

quad copter. 

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 charging 

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 

quad copter. 

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 if the 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 should 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 will be stopped power 

supply.As the quadcopter control systemwill protected battery automatically. 

Over-current protection: 

When the quadcopter's rotating blade is col lided or 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 disorder or sideward flight, restore factory default settings by the 

following methods: 

1:~~0 

(r£1 

~~ ~ 

CD. Press the power switch to turn on 

the transmitter. 

(2).Press the power switch to turn on the quadcopter. 

@.When the quadcopter indicator quickly flashing 

to slowly flashing , please push the throttle lever to 

the highest position,and then pull it back to the 

lowest position. Then the quadcopter indicator 

changed from slowly flashing 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 the 

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 aircraft to a height of more than 

3 meters, press the 3D Eversion switch 

on the rear right side of the 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~~~ ~ T 
Thanks 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 light on. 

If the 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 pull 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 transmitter. 1.Replace the battery. is slow to respond 2.Transmitter of the same frequency is 2.Use the helicopter out of the range of or difficult 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 Quantity 

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-