The Green Gavel LLC. – Section 333 Exemption Petition

December 16th, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation

Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(a); 91.9(b) (2);

91.103(b); 91.109; 91.119(a)(b), 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a)

(1); 91.409(a) (2); 91.417(a)&(b); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(2); and 14

C.F.R. 417(a)&(b)

Attn: to whom may concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the

“Reform Act”) and 14 C.F.R. Part 11, The Green Gavel, LLC, the owner and operator of the DJI Phantom 2 

quad-copter Unmanned Aircraft System (UAS), seeks an exemption from the Federal Aviation 

Regulations.

(“FARs”) listed below so that The Green Gavel, LLC can operate our small ultra-light weight UAS 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

(Pilot in Charge [PIC]) and a visual observer (VO) that can perform the functions prescribed in the 

operating manual for all flights under this Exemption, if granted.

The requested exemption would support an application for a commercial Certificate of Authorization to 

use the system to perform aerial mapping to enhance academic community awareness, augment real 

estate listing videos, filmmaking, golf course, mapping, agricultural mapping, and photogrammetry for 

various industries.

Use of the DJI Phantom 2 UAS for aerial mapping reduces the need to operate conventional aircraft for 

the same purpose and provides very high quality imagery at a fraction of the dollar cost and danger to 

human life of using conventional aircraft. Note; the VO will not be operating the UAS.

By approving these exemptions, the FAA will create benefits through safer survey methods by UAS, 

resulting in decreased potential for loss of life and enhanced efficiency and productivity for the affected 

activities, as well as environmental benefits, which are all ultimately in the public interest.

Committed to safety with each flight, The Green Gavel, LLC’s, exemption request would permit 

operation of ultra-light weight, unmanned (piloted by remote control) and comparatively inexpensive 

UAS in tightly controlled and limited airspace. Currently, similar lightweight, remote controlled UAS's are 

legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent 

catastrophe. In addition, Douglas Trudeau (Exemption No. 11138) and Slugwear, Inc (Like On A Tree; 
Exemption No. 11157) were granted exemptions for these types of surveys with the DJI Phantom 2. The 

Green Gavel, LLC has created and will follow its UAS Flight Protocols and Controls for safe operation to 

avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further 

safety protocols exclusive to lightweight UAS's specific video and photography usage as The Green 

Gavel, LLC records flight data and other information gained through permitted flight operations to share 

with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting The Green Gavel, LLC’s request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace 

system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real 

estate/Realtor purposes. Further, The Green Gavel, LLC, will conduct its own operations in compliance 

with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, The Green Gavel, LLC, respectfully requests the grant of an exemption 

allowing The Green Gavel, LLC to operate ultra-light weight, remote controlled UAS’s for community 

awareness, enhance real estate listing videos for homeowners, filmmaking, golf course, mapping, 

agricultural mapping, and photogrammetry for various industries. All of which will promote local 

economic growth through increased employment and increased tax base. Both with public safety in 

mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public 

hazard.

I Contact Information:

Richmond Frasier

The Green Gavel, LLC

109 N. Hill Top Dr.

Boerne, TX 78006

Mobile: (830) 377-0901

Email: richmond.frasier@gmail.com

II The Specific Sections of Title 14 of the Code of Federal Regulations From Which The Green Gavel, LLC

Requests Exemption are:

14 CFR part21;

14 CFR 45 23 (b);

14 CFR 91, et seq;

14 CFR 407 (a)(1)

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).
III The Extent of relief The Green Gavel, LLC seeks and the Reason The Green Gavel, LLC Seeks Such 

Relief:

The Green Gavel, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-

334, seeking relief from any currently applicable FARs operating that prevent The Green Gavel, LLC from 

performing commercial cinematic, academic and other flight operations within the national airspace 

system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems 

into our national airspace system as it is in the public’s interest to do so. The Green Gavel, LLC's, ultralight weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of The Green Gavel, LLC's ultra-light weight UAS is expressly contemplated by 

the Reform Act.

The Green Gavel, LLC would like to operate its ultra-light weight UAS prior to the time period by which 

the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct 

experience and valuable information for formal regulation that can be administered uniformly to all 

agriculture, mapping, and real estate related UAS aerial video and photography. The Reform Act guides 

the Secretary in determining the types of UAS's that may operate safely in our national airspace system. 

Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS 

will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line 

of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for The Green Gavel, 

LLC.

The Green Gavel, LLC’s UAS utilizes four (4) counter-rotating propellers for balance, control and stability. 

Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with 

gimbal. The Green Gavel, LLC’s UAS is equipped with a compass, GPS, auto return safety technology if 

communication is lost between the UAS and the controller, Real-Time Fight Data Display, and a No Fly 

Zone software default setting to force the device to abide by International Civil Aviation Organization 

regulations.

The Green Gavel, LLC considers safety as foremost with each flight. The Green Gavel, LLC’s small UAS is 

designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability 

and fear of financial loss, The Green Gavel, LLC will not fly in winds exceeding 16 kph (10 mph) nor 

exceed an indicated airspeed of 29 knots (15 m/s). DJI’s “No Fly Zone”: Two classes in this mode limit the 

DJI Phantom 2’s ability to fly near restricted airport air space. Class A will not allow the UAS to take off 

within 1.5 miles of the GPS location of an airport. Class B will has incorporated an increasing height limit 

from 35 feet AGL at 1.5 miles from an airport, increasing to 400 feet at 5 miles an airport. The UAS 

control system will also automatically warn the PIC when the UAS has approached within 330 feet of the 

5-mile buffer zone around an airport. This software will also not allow the user to set GPS waypoints 

within 5 miles of the 5-mileNo Fly Zone around an airport. For further details, visit 

http://www.dji.com/fly-safe/category-mc

Built-in safety Real-Time Flight Data includes UAS flight height, horizontal speed, vertical speed, and 

distance from the PIC.

Built-in safety systems include a GPS mode that allows The Green Gavel, LLC’s UAS to hover in place 

when radio controls are released. With three modes to choose from, The Green Gavel, LLC will utilize 

the Smart Mode for aerial videography/photography. This is the safest, most reliable and stable mode to 
prevent accident and hazard. When PIC communication is lost, The Green Gavel, LLC’s UAS is designed 

to slowly descend to point of take-off (Return to Home). The Green Gavel, LLC will not operate the UAS 

near Airports, Hospitals, nor Police heliports, and will not operate near areas where general public is 

within fifty to one hundred (50-100) yards depending on location, conditions and weather. The Green 

Gavel, LLC’s PIC and VO will be on constant alert for any manned aircraft (Police/Medical helicopters, 

etc.) or other UAS, and prepared to land/abort immediately to the nearest and safest ground point 

should a manned aircraft or UAS approach The Green Gavel, LLC's location, or The Green Gavel, LLC

suspects manned aircraft or UAS may approach near our location. The Green Gavel, LLC’s UAS is capable 

of vertical and horizontal operations, and is only flown within the line of sight of both the PIC and VO. 

Utilizing battery power rather than combustible fuels, flights with The Green Gavel, LLC’s UAS generally 

last between five (5) to seven minutes, with an altitude under 400 feet.

The Green Gavel, LLC will utilize a fresh fully charged battery with each flight as a safety precaution; full 

flight time limit for each battery is nine (9) to 12 minutes as tested. The Green Gavel, LLC will not 

operate our UAS at or below manufacturer recommend minimum charge levels for operation; preferring 

to remain well within a safe operating range to insure adequate communication between radio control 

and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with 

each exercise to insure replacement for sufficient safe level of operation. The Green Gavel, LLC does not 

believe in taking risk that may cause a crash that could create hazard to the public/property/manned 

aircraft, and have no desire to lose an investment. The Green Gavel, LLC has clocked numerous practice 

flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization 

with the characteristics of this specific UAS's performance under different temperature and weather 

conditions. The Green Gavel, LLC also practices computerized simulated flights to maintain adequate 

skills and response reflex time, for the sake of safety. The Green Gavel, LLC is extremely cautious when 

operating any UAS and will not “create a hazard to users of the national airspace system or the public.” 

112 P.L. 95 § 333 (b).

Given the small size and weight of The Green Gavel, LLC’s UAS, it falls well within Congress’s 

contemplated safety zone when it promulgated the Reform Act and the corresponding directive to 

integrate UAS's into the national airspace system. The Green Gavel, LLC UAS, used in hobby flight, has a 

demonstrable safety record and does not pose any threat to the general public or national security.

IV. How The Green Gavel, LLC’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness in real estate, filmmaking, golf course, mapping, 

agricultural mapping, and photogrammetry for various industries has been around for a long time 

through manned fixed wing aircraft and helicopters. For small budget companies, farms and average 

homeowners, the expense of manned aerial videography is cost prohibitive. Only large companies can 

afford to absorb such expense, this depriving the remainder of the public from a valuable marketing and 

mapping tool.

V. Reasons Why The Green Gavel, LLC’s Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

The Green Gavel, LLC’s exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated, permitting The Green Gavel, LLC to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow us to contribute to the innovation and implementation of new 
and novel techniques for realtors, filmmaking, golf courses, agricultural mapping, and photogrammetry 

for various industries as well as continuing to educate the public through publishing articles. In addition, 

The Green Gavel, LLC submits the following representations of enhancements to current aerial 

videography and photography for real estate, filmmaking, golf courses, agricultural mapping, and 

photogrammetry for various industries:

The Green Gavel, LLC’s UAS weighs less than 5 pounds complete with a small ultra-light weight high

quality GoPro 4 Black camera; The Green Gavel, LLC will only operate this UAS below 400 feet, as 

recommended by the FAA Modernization and Reform Act of 2012; The Green Gavel, LLC’s UAS will only 

operate for 10 minutes per flight; The Green Gavel, LLC will land this UAS prior to manufacturer 

recommended minimum level of battery power, 30% battery power remaining. Also, The Green Gavel, 

LLC’s UAS has an automated function which results in immediate landing when a low battery is 

detected; The Green Gavel, LLC will pilot this UAS through remote control by line of sight; The Green 

Gavel, LLCs UAS has GPS-controlled autopilot system to maintain UAS stability and control, The Green 

Gavel, LLC's UAS has an Auto Return-to-Home & Landing function to increase safe return of the UAS to 

the ground, A pre-programmed flight safety feature whereby The Green Gavel, LLC’s UAS automatically 

hovers and then slowly lands if communication with the remote control pilot is lost; The Green Gavel, 

LLC will actively analyze flight data and other sources of information to constant update and enhance 

safety protocols; The Green Gavel, LLC will only operates in reasonably safe environments that are 

strictly controlled and are away from: power lines, elevated lights, airports and actively populated areas; 

The Green Gavel, LLC will conduct extensive pre-flight inspections and protocol review, during which 

safety carries primary importance; Any maintenance or alterations of The Green Gavel, LLC’s UAS that 

could affect operation or flight characteristics will require a functional test flight before returning to 

work; The Green Gavel, LLC will always obtain all necessary permissions prior to operation, Including 

issuing a notice to airmen(NOTAM)prior to operations; and, The Green Gavel, LLC will have procedures 

in place to abort flights in the event of safety breaches or potential danger.

In recognition of the FAA’s Exemption No. 11062, and specifically Exemption No. 11138 for the same 

UAS model (DJI Phantom 2); prior to conducting operations for the purpose of aerial 

photography/videography, The Green Gavel, LLC’s PIC will have accumulated 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours as a UAS pilot with a multi-rotor UAS. Prior to operations, 

The Green Gavel, LLC’s PIC must also have accumulated a minimum of 5 hours as a UAS pilot operation 

the DJI Phantom 2. In addition to the hour requirements, the PIC must accomplish 3 take-offs and 

landings in the preceding 90 days (for currency purposes). The Green Gavel, LLC’s, safety protocols 

provide a level of safety equal to or exceeding existing rules. It is important to note that absent the 

integration of commercial UAS into our national airspace system, helicopters are the primary means of 

aerial video and photography for community awareness and real estate. While the safety record of such 

helicopters is astounding, there has been local incidents involving loss of life as well as extensive 

property damage; it is far safer to operate a battery powered ultra-light weight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board and The Green 

Gavel, LLC will only operate its UAS in specific areas away from mass populations.

Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished.
Third, the small size and extreme maneuverability of The Green Gavel, LLC’s UAS allow the PIC to 

remotely pilot away from and avoid hazards quickly and safely . Lastly, given its small size and weight, 

even when close enough to capture amazing images, The Green Gavel, LLC’s UAS need not be so close to 

the objects they are focused on through the technology and use of post editing software allowing pan 

and zoom. Accordingly, The Green Gavel, LLC’s UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above current safety levels. 

Furthermore, The Green Gavel, LLC’s PIC has accumulated 25 hours of total time as a UAS multi-rotor 

pilot. The Green Gavel, LLC’s PIC has also accumulated more than 5 hours as a UAS pilot operation the 

DJI Phantom 2.

VI A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.14 C.F.R. Part 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational 

area of The Green Gavel, LLC’s UAS permits exemption from Part 21 because The Green Gavel, LLC’s UAS 

meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. The Green Gavel, LLC’s 

current UAS meets or exceeds each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 

However, The Green Gavel, LLC’s PIC will still ensure that the UAS is in an airworthy condition based on 

compliance with the operating documents prior to every flight.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or 

passengers, and given the size of the UAS, this Regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining a safety/flight manual delineating areas where safety can be defined

. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A,10602, 10700 and 32827. However, The Green Gavel, LLC’s UAS 

operations manual will be kept in a location accessible by The Green Gavel, LLC’s PIC.

14 C.F.R. § 91.103 regarding preflight action. The Green Gavel, LLC’s PIC will take certain actions before 

flight to ensure safety of the flight. These will include reviewing weather, flight battery requirements, 

landings, and takeoff distances and aircraft performance data before initiation of the flight.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as The Green Gavel, LLC’s UAS 

utilizes electronic GPS with a barometric sensor. According to the manufacturer of The Green Gavel, 

LLC’s UAS, the GPS sensor is accurate to 2.6 feet Vertical and 8.2 feet Horizontal. These accuracies are 

adequate for The Green Gavel, LLC to safely operate the UAS for its exempted purposes.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations.

They are inapplicable for the same reasons described above. The equivalent level of safety will be 
achieved by maintaining any such required certifications and registrations by The Green Gavel, LLC in a 

location accessible by The Green Gavel, LLC’s PIC.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

The Green Gavel, LLC’s UAS, by definition, is unmanned. Therefore the UAS does not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult 

to place on such small aircraft with dimensions smaller that minimal lettering requirement. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700.C. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119(a) and (b) prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. The Green Gavel, LLC’s UAS will never 

operate at an altitude greater than 400 AGL; safely within the standard 400 AGL as recommended by the 

FAA Modernization and Reform Act of 2012. The Green Gavel, LLC will however operate its UAS in safe 

areas away from areas depicted in “yellow” on VFR charts, providing a level of safety at least equivalent 

to or below those in relation to minimum safe altitudes. The Green Gavel, LLC will conduct all operations 

under The Green Gavel, LLC’s Protocols and Controls , including posting a warning sign reading: 

“Attention Aerial Photography in Progress – Remain Back 150 Feet”. The Green Gavel, LLC will operate 

its UAS in accordance with Exemption No. 11109, which may require the UAS be operated closer than 

500 feet to essential persons. Non-participating persons must remain at appropriate distances (500 feet) 

from the UAS, and if they need to be closer than 500 feet, non-participating persons will remain behind 

barriers or structures that can sufficiently protect them from the UAS debris in the event of an accident. 

Given the size, weight, maneuverability and speed of The Green Gavel, LLC’s UAS, an equivalent or 

higher level of safety will be achieved

D. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 

aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except 

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply 

to The Green Gavel, LLC’s UAS. However, as a safety precaution The Green Gavel, LLC’s PIC and VO will 

inspect The Green Gavel, LLC’s UAS before and after each flight.

A Summary the FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart 

H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a) (1).The size, weight and enclosed operational 

area of The Green Gavel, LLC’s UAS permits exemption from Part 21 because The Green Gavel, LLC’s UAS 

meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and 
proximity to areas such as airports and dense populations. The Green Gavel, LLC’s UAS meets or exceeds 

each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As 

there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved.

In summary, The Green Gavel, LLC seeks an exemption from the following

Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 

C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119 (a)(b); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 

14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 

14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate The Green Gavel, 

LLC’s small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, real 

estate operations, filmmaking, golf course mapping, agricultural mapping, and photogrammetry for 

various industries and to develop economic platforms for real estate and golf courses. Currently, area 

awareness, filmmaking, real estate aerial videography/photography, golf course mapping, agricultural

mapping, and photogrammetry for various industries relies primarily on the use of larger aircraft 

running on combustible fuel, posing potential risk to the public. Granting The Green Gavel, LLC’s request 

for exemption will reduce current risk levels and thereby enhance safety. The Green Gavel, LLC’s UAS 

craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than 

conventional real estate video and photographic aircraft with much less flight time. Further, The Green 

Gavel, LLC will operate at lower altitudes and in controlled airspace eliminating potential public risk 

flying to and from established air fields. The Green Gavel, LLC has been informally analyzing flight 

information and will compile safety protocols and the implementation of a flight operations manual for 

real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection 

of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for 

complying with the FAA Modernization and Reform Act of 2012.

There are no personnel on board The Green Gavel, LLC’s UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. The Green Gavel, LLC’s operation of its UAS, weighing 

less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of 

safety as that achieved under current FARs. Accordingly, The Green Gavel, LLC respectfully request that 

the FAA grant The Green Gavel, LLC’s exemption request and The Green Gavel, LLC is willing to 

cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at 

large.

Respectfully submitted

Richmond Frasier

109 N. Hill Top Drive

Boerne, TX 78006
Mobile: (830) 377-0901

Email: richmond.frasier@gmail.com