David Brenton Petition for FAA Exemption Page 1 o f 4

David Brenton DAVID BRENTON’S TEAM 4741 E Stop 11 Road Indianapolis, IN 46237 (Office) 317

- 882

- 7210 (Fax) 317

- 888

- 7201 October 16 , 2015 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Avenue SE Washington, DC 20590 Subject: E xemption Request Section 333 of the FAAReform Act and Part 11 of the Federal Aviation Regulations for 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151 Following the format of FAA Exemption No. 11138

–Regulatory Docket No. FAA

– 2014

– 0481 I have included: 1. Supplemental Response for Petition 2. Inspire 1 User Manual 3. Inspire 1 Maintenance Manual 4. Inspire 1 Quick Start Guide Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I , David Brenton, a licensed Realtor since 1992 , preparing this exemption request m ys elf, would like to apply for an exemption from the following Code of Federal Regulations (C.F.R.) for my self and/or properly trained personnel repre senting m y brokerage to be allowed commercial operation of lightweight Unmanned Aircraft Sy stems (UAS) for aerial imaging and video of central Indiana landmarks and homes that are marketed to sell. I have experience in fl yi ng drones for recreational purpo ses during the past 2 years without incident. Ihave now acquired a DJ I Inspire 1 quad

- copter (maximum gross weight 6.5 pounds, equipped with four rotors that are driven b y electric motors powered by batteries, with a maximum airspeed of 43 knots) to my i nventory

that is equipped with a built

- in camera . With an exemption and approval from the FAA, m y intention is to captur e aerial photography and videography

for the purpose s o f enhancing real estate listing marketing and to create a resource for those who can not ph ys icall y visit the property or central Indiana and wish to learn more about the area. My exemption request would permit operation of a lightweight, unmanned aircraft controlled by

remote in predetermined areas away from the general public, airpo rts, heliports and vehicular traffic, at an altitude of less than 2 00 feet and onl y after carefull y researching and examining the area of intended flight. This would allow for communityDavid Brenton Petition for FAA Exemption Page 2 o f 4

videos and photos within property boundaries for individual homeowners real estate listin gs. If granted exemption, I(or a properly trained representative from m y brokerage) will adhere to all FAA requirements to ensure that this exemption will provide a level of safety equal or greater than the existing rules and will only operate in a safe, strictly controlled environment away from power lines, elevated lights, airports, heliports and areas of dense population. Additionally , all necessary preflight inspections and protocols will be followed accordingl y. Furthermore, once airborne the UAS will remain within line of sight of the operator at all times until safely grounded.
**14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR §**  **91.203** Given the size, weight, maximum speed, and limited operating area associated wi th the aircraft to be utilized, I

am requesting exemption from 14CFRpart21, 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 14CFRpart11 and Section 333 of P.L . 112

- 95 (Section 333).
**14 C.F.R. 45.27(a): Location of marks; non fixed**
**- wing aircraft. 14 C.F.R. 45.29 (3)**  **(c)(d)(e)(f)(h): Size of Marks** Furthermore I request an exemption from §45 .23 Marking of the aircraft because m y UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally , the lettering would be nearly impossible to place on an aircraft with dim ensions smaller than the minimum le ttering requirement. Understanding the need for markings , I am willing to mark my UAS in the largest possible lettering by pl acing an assigned number or name , based on a request or ruling by the FAA , on its fuselage as required b y §45.29(f) so that an yone assisting the operator as a spotter can identify the craft by

these markings.
I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be required and should be granted since they onl y apply to aircraft with an airworthiness certificate. A s a standard safet y protocol, the operator will perform a preflight inspection of the UAS before each flight as outlined in the operating documents.
**14 CFR 61.113 (a) & (b): Private pilot privileges and lim itations: Pilot in command.**  Under §61.113 (a) and (b) private pilots are limited to non

- commercial operations. However, as the UAS would carry neither passengers nor pilots I feel strongl y that we would be able to reach an equivalent level of safety as is achieved b y current regulations.David Brenton Petition for FAA Exemption Page 3 o f 4

While useful in providing a more expansive knowledge of flight, a pilots’ license will not necessarily

enhance the skills need to operate a quad copter remotel y. As the risks of operating a UAS are far less than those inhe rent in the commercial activities outlined in 14 CFR part61,et seq., I request an exemption from §61.113 Private Pi lot Privileges and Limitations. Concerning operational training of the UAS, as stated above I have a preexisting knowledge gained from operating various unmanned, recreational quad copters in locations, weather conditions and flight patterns similar to those that would be utilized for our real estate needs. Any representatives from my

brokerage who would be authorized as operators of a UAS wou ld only be given such authorization after proving their ability to safel y perform all duties involved with operation. An operator would be required to prove capable of performing an y and all necessary inspection s in addition to following all safe flight protocols as described in the user manuals.
**14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action** If granted an exemption we agree to additional safety procedures including, but not limited to: 1) Maintaining a 1000 foot radius between the operator and the UAS at all times while airborne to aid in direct line

- of

- sight visual observation. 2) Limiting operation of the UAS to 5

- 8 minutes per flight and landing the UAS according to the manufacturer’s recommended minimum level of battery power. 3) Operating the UAS only wi thin visual line of sight (VLOS). 4) Using the UAS’ global positioning sy stem (GPS) flight safety feature allowing the UAS to hover and slowly land if communication is lost between the remote control and the UAS. 5) Conducting all operations under a set of pre

- determined flight safety protocols, including posting a warning sign notifying civilians that aerial photography is in progress and advising to only observe from a safe distance. 6) Actively

anal yz ing flight data and other sources of information to constantly update and enhance our safety protocols. 7) Contacting respective airports if operations will be within 5 miles to advise them of estimated flight time, duration, elevation and any other relevant information. 8) Alway s obtain ing all necessary permissions prior to operation. 9) Having procedures in place to abort flights in the event of safety breaches or potential danger.
While the real estate market has been no stranger to utilizing aerial photography in the past, brokers have been limited to hiring piloted fixe d

- wing aircraft and helicopters which is ty picall y an expense of both time and finances that most small business owners can simply not afford. With this exemption, my office would be able to provide this service to a larger client base at minimal cost as c ompared to previous methods. The properl y trained usage of a small UAS would pose no public threat in comparison to a mannedDavid Brenton Petition for FAA Exemption Page 4 o f 4

aircraft which would be significantl y larger and contain combustible fuel. Furthermore, the use of an electric

- powered UAS instead of more traditional meth ods could aid in the limitation of ecological strain by reducing carbon emissions. Lastl y, I strongl y believe this ty pe of aerial photography

could assist in stimulating economic growth in m y community by providing a greater means for companies and individuals intending to relocate to learn more about Central Indiana from afar. By encouraging new businesses and individuals to locate to our area , the general public would reap the socioeconomic benefits afforded by an expanding and ev olving business sector. When marketing real estate , first impressions are paramount and w ith 90% of homebuyers searching online before purchasing, the ability to provide extensive digital marketing is essential in today ’s marketplace. With this exemption, we hope to become a public resource for an y individuals or businesses that consider relocating to Central Indiana b y providing a library of digital media that showcases our local area.