Request	for	Section	333	Exemption January	31 ,	2016

Christi	M	Conroy

1945	Windy	Leaf	Court Virginia	Beach,	VA	23456

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I ,	Christi M Conroy	am petitioning	the	Federal	Aviation	A dministration	for exemption	in	accordance	with Section	333	of	the	FAA	Modernization	and	Reform Act	of	2012	for	Aviation	Unmanned	to	perform	Aerial	Photography	by/for	Chr isti	M Conroy

, Associate	Broker	representing	Conroy	Homes	of	Berkshire	Hathaway	Home Services	Towne	Realty .	The	main	use	of	the	UAS	wo uld	be	taking	real

- estate videos and	photos for	marketing	purposes .	The	UAS systems	that	I	will use; is the Yuneec Typhoon	Q500	4K and	will	be referenced	in	this	document

.

Discussion :

The	exem ption	will	allow	me	to	operate	my Yuneec	Q500	4K	quad

- copter unmanned	aircraft	system	(UAS)	to	conduct	aerial	photography	and	videography	in Hampton	Roads,	Virginia,	to	augment	real	estate	listings to	show	boundaries of properties	as	they	relate to	the	natural	and man	made	surroundings

.

Granting	an	exemption	will	not	adversely	affect	safety. I	will	be conducting operations	over	client	owned	or	controlled	land,	solely	during	daylight	hours,	at altitudes	well	below	that	which	would	pose	a	risk to	other	aircraft

. The	safe operations	of	this UAS

, weighing	less	than	55	lbs

., will	be conducted	in	the	strict

conditions	outlined	as	follows and will	provide	an	equivalent	leve l	of	safety supporting	the	grant of the	exemptions	requested ,	including	333	Air craft	Exemption

Status. My lightweight	aircraf t will operate	at	slow	speeds,	close	to	the	ground,	and

in	a	controlled	environment. All	operations	will	be	within	visual	line

- of

- sight	(i.e. ,	no more	than	approximately	0.2 miles	from	the	manipulator	of	the	cont rols,	or	pilot	in command	(PIC) and	less	tha n	400	ft	above	ground	and	never	directly	above	persons or	public	are a s. Additional	safety	features	on	the	Yuneec	Typhoon	Q500	include return	to	home	and	low	battery	auto	return	and	landing.

Pre

- flight	inspection	would	be	conducted	in	accordance	with	the	o wner’s	manual	as well	as	surveying	the	local	area	for	hazards	to	flight	and	weather	conditions.

The	PIC	will	be	myself	and	I	have	a	minimum	of	30	hours	of	experience. I	have personally	obtained	ten	hours	of	flight	time	in	a	civilian	aircraft. In	addition, my UAS flight	and	safety training	has	been	provided	by	my	husband,	Kevin	Conroy,	who	is	a retired	Marine	Corps	helicopter	pilot.	He	has	flown	over	4500	mishap	free	flight dotloop signature verification: www.dotloop.com/my/verification/DL-141341498-2-1S2Ahours	and	was	designated	an	Instructor	Pilot,	training	over	150	new	pilots	in

helico pter flight	during	his	career .		He	is	an	expert	in	FAA	flight	regulations	and flight	safety. He	is	currently	a	government	civilian	service	employee	at	the	Naval Safety	Center,	Norfolk,	Virginia,	providing	safety	analysis	for	the	Navy.

Sections	for	request ed	Exemption: Responses	provided	in	italics

Section	91.7(a) prescribes	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in an	airworthy	condition. There	are	no	specifications	on	what	makes	a	UAS	airworthy,	during	the	preflight checks	all	propellers	and	mountings	are	checked	for	damage	and	operation.

Section	91.7(b) prescribes	that	the	pilot	in	command	of	a	civil	aircraft	is responsible	for	determin ing	whether	that	aircraft	is	in	condition	for	safe	flight	and that	the	PIC	shall	discontinue	the	flight	when	un

- airworthy	mechanical,	electrical,	or

structural	conditions	occur. Preflight	checks	shall	be	completed	before	lift	off	and	continuous	monitoring of	in

flight	systems	shall	be	performed	from	the	ground	station	from	the	moment	of powering	up	for	preflight	until	shutting	down	at	the	end	of	the	operation.

Section	91.9(b)(2) prohibits	operation	of	U.S.

- registered	civil	aircraft	unless	there

is	availab le	in	the	aircraft	a	current	approved	Airplane	or	Rotorcraft	Flight	Manual, approved	manual	material,	markings,	and	placards,	or	any	combination	thereof. Supplemental	materials	will	include	equipment	and	flight	manuals	issued	with	the

UAS.

Section	91.119 prescribes	that,	except	when	necessary	for	takeoff	or	landing,	no person	may	operate	an	aircraft	below	the	following	altitudes:

(a)	Anywhere.	An	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing without	undue	hazard	to	persons	or	property	o n	the	surface.

(b)	Over	congested	areas.	Over	any	congested	area	of	a	city,	town,	or	settlement,	or over	any	open	air	assembly	of	persons,	an	altitude	of	1,000	feet	above	the	highest obstacle	within	a	horizontal	radius	of	2,000	feet	of	the	aircraft.

(c )	Over	other	than	congested	areas.	An	altitude	of	500	feet	above	the	surface, except	over	open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft	may not	be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.

(d)	Heli copters,	powered	parachutes,	and	weight

- shift

- control	aircraft.	If	the operation	is	conducted	without	hazard	to	persons	or	property	on	the	surface

— (1)	A	helicopter	may	be	operated	at	less	than	the	minimums	prescribed	in paragraph	(b)	or (c)	of	this	sect ion,	provided	each	person	operating	the	helicopter	complies	with	any routes	or	altitudes	specifically	prescribed	for	helicopters	by	the	FAA;	and dotloop signature verification: www.dotloop.com/my/verification/DL-141341498-2-1S2A(2)	A	powered	parachute	or	weight

- shift

- control	aircraft	may	be	operated	at	less than	the	minimums	prescribed in	paragraph	(c)	of	this	section.

Due	to	altitude	limitations	and	the	desire	to	avoid passenger

- carrying aircraft	it	is requested	to	maintain	a	maximum	ceiling	of	400’	with	typical	heights	being	below	that dependent	on	angles	and	shots	for	photographic	use.

Section	91.405(a) requires,	in	pertinent	part,	that	an	aircraft	operator	or	owner

shall	have	that	air craft	inspected	as	prescribed	in	subpart	E	of	the	same	part	and shall,	between	required	inspections,	except	as	provided	in	paragraph	(c)	of	the	same section,	have	discrepancies	repaired	as	prescribed	in	part	43	of	the	chapter.

T

here	are	no	current maintenance	requirements	for	UAS	of	this	type.

Section	91.151(a) prescribes	that	no	person	may	begin	a	flight	in	an	airplane	under VFR	conditions	unless	(considering	wind	and	forecast	weather	conditions)	there	is enough	fuel	to	fly	to	the	first	point	of	i ntended	landing	and,	assuming	normal cruising	speed,	(1)	during	the	day,	to	fly	after	that	for	at	least	30	minutes	[emphasis added].

Section	91.203(a) prohibits,	in	pertinent	part,	any	person	from	operating	a	civil aircraft	unless	it	has	within	it	(1)	an appropriate	and	current	airworthiness certificate;	and	(2)	an	effective	U.S.	registration	certificate	issued	to	its	owner	or,	for operation	within	the	United	States,	the	second	copy	of	the	Aircraft	registration Application	as	provided	for	in	§	47.31(c).

Section	91.203(b) prescribes,	in	pertinent	part,	that	no	person	may	operate	a	civil aircraft	unless	the	airworthiness	certificate	or	a	special	flight	authorization	issued under	§	91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	t o

passengers	or	crew.

Section	91.407(a) (1)	prohibits,	in	pertinent	part,	any	person	from	operating	an aircraft	that	has	undergone	maintenance,	preventive	maintenance,	rebuilding,	or alteration	unless	it	has	been	approved	for	return	to	service	by	a	person authorized under	§	43.7	of	the	same	chapter.

Section	91.409(a) (2)	prescribes,	in	pertinent	part,	that	no	person	may	operate	an aircraft	unless,	within	the	preceding	12	calendar	months,	it	has	had	an	inspection

for	the	issuance	of	an	airworthiness	certif icate	in	accordance	with	part	21	of	this chapter. There	are	currently	no	airworthiness	certificates	for	the	UAS	to	be	used	and	also	as there	is	no	cabin	cockpit	or	passenger	compartment	on	the	UAS	it	is	not	possible	to store	certificates	on	board	the	craf t.

Public	Interest

Aerial	photography	and	videography	for	geographical	awareness	and	for	real	estate marketing	has	been	around	for	a	long	time	through	manned	fixed	wing	aircraft	and dotloop signature verification: www.dotloop.com/my/verification/DL-141341498-2-1S2Ahelicopters,	but	for	small	business	owners,	its	expense	has	been	cost

- prohibitive. The	cost	p rohibition	does	not	permit	seasonal	or	repeated	over	flights	for	many institutions,	which	could	mean	several	years	between	a	regions	being photographed.	Small	areas	of	study	could	be	repeatedly	photographed	permitting	in depth	study	of	an	areas	change	in	g eomorphology	through	the	seasons	and	after storm	events.	Granting	this	exemption	would	allow	this	service	to	be	provided	at	a much	lower	cost,	allowing	for	a	much	greater	utilization.	Further,	this	small	UAS	will pose	no	threat	to	the	public	given	its	smal l	size	and	lack	of	combustible	fuel	when compared	to	larger	manned	aircraft.

Supporting	Information :

The	following	information	is	provided

– contained	in	this	petition	and	supporting documentation	including: dotloop signature verification: www.dotloop.com/my/verification/DL-141341498-2-1S2AThank	you	in	advance	for	your	time	and consideration	of	my	petition.

Warm	regards,

Christi	Conroy,	Associate	Broker
ABR,	CRS,	GRI,	SFR,	REALTOR

Berkshire	Hathaway	HomeServices	Towne	Realty

2117	General	Booth	Boulevard Virginia	Beach,	VA	23454

Office:	757

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- 1130	x118

Fax: 757

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Cell: 757

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www.ChristiConroy.com

Email: ConroyHomes@gmail.com

Licensed	in	the	Commonwealth	of	Virginia dotloop verified 01/31/16 1:15PM EST 4WN5-45GK-XIOX-8LM9 

### Christi Conroy dotloop signature verification: www.dotloop.com/my/verification/DL-141341498-2-1S2A