### Luiz Leone tti

– Asheville, NC

– Section 333 Exemption Petition 1 

## Luiz Leonetti, Asheville, NC.

- Section 333 Exemption Petition

September 19th, 2015

U.S. Department of Transportation

Federal Aviation Administration 800 independence Ave., S. W. Washington D.C 20591

Re: Docket No. FAA

- 2015

- 2418

Dear Brittany New ton:

Thank you for your letter dated September, 4th of 2015. The present petition has the intention to provide further explanations on the level of safety as well as arguments to support my request.

I, Luiz Leonetti am writing pursuant to the FAA Modern ization and Reform Act of 2012 and 14 C.F.R. Part 11 to request an exemption of the above referenced FARs to allow the operation of a small ultra lightwe ight unmanned aircraft system ( UAS) for commercial purposes in the National Airspace System (NAS) regul ated by the FAA.

The applicant, Luiz Leonetti is a licensed Realtor® in the State of North Carolina as well as a

Profes sional Real Estate Photographer and a UAS hobbyist since 2010.

As described more fully the granting of this exemption request would pe rmit the operation of a

small UAS for the primary purpose of providing low altitude aerial photography/videography in the

North Carolina area to th e general public, local government, educational institutions, non

- profit organizations, and individuals desir ing Real Estate and Land photography for Real Estate Listings

and similar uses.

Additionally, granting this exemption request would fulfill the Secretary of Transportation's (FAA Administrator's responsibilities to " ... establish requirements for the saf e operation of such aircraft systems in the National Airspace System" under Section 333(c) of the Reform Act.

Similarities to Granted Exemption No. 11138 Douglas Trudeau, Realtor®:

This exemption request is virtually the same as the Granted Exemption No .11138 in that the proposed usage of the UAS is for the same Real Estate purpose, it is a similar UAS model, and all of the FAA requirements set forth in Granted Exemption No.11138 will be meticulously complied with.

I. Contact Information:

Luiz Leonetti

24 Nevada Ave.
Asheville, NC. 28806

luiz@luizleonetti.com

828 575

- 4428

II. Regulations from which exemption is requested: 14 C.F.R. 61.113(a)&(b) 14 C.F.R. 91.7(a)

14 C.F.R 91.121 14 C.F.R 91.151(a)

14 C.F.R 91 .405(a) 14 C.F.R 91.407(a)(1) 14 C.F.R 91.409(a)(1)(2) 14 C.F.R 91.417(a)(b) 14 C.F.R 91.119(c)

Ill. Extent of Relief and Reason: The extent of relief I am seeking is the same as in the Granted Exemption No. 11138 for the

### Luiz Leone tti

– Asheville, NC

– Section 333 Exemption Petition 2 general purpose of Real Estate a nd similar aerial photography/videography. I am asking that the FAA grant the amount of relief from each regulation as is deemed appropriate for the safe operation of the small UAS and its inclusion into the NAS.

The reason for the exemption request is be cause it is currently unlawful to fly UAS's in the NAS for commercial purposes thereby denying the general public the advantages associated with their

use.

IV. Benefit to the Public as a Whole: Aerial photography/ videography for real estate marketing and similar purposes has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial photography/videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to

absorb such an expense thereby d epriving non

- luxury homeowner s and lower budget Realtors of a valuable marketing tool. Manned aircraft pose a threat to the public through potential
catastrophic acci dents and by carrying combustible fuel

. UAS ’ s pose no such threat since their size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public's best interest to integrate commercial ly flown UAS's into the national airspace system, hence the passing of the Reform Act. The lightweight UAS is battery powered and creates no emissions that can harm the environment. The consequences of an ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

V. This Exemption would increase safety due to the fact that all Flight Safety and Operational requirements as set forth in the Granted Exemption No. 11138 will be complied with.

The UAS to be flown is the IRIS +, which is a similar aircraft to the UAS in the previously approved Exemption No. 11138.

As set forth by the FAA in the Granted Exemption No. 11138 the fol lowing Conditions and Limitations will be complied with:

1) Operations will be conducted using only an IRIS+ unmanned aircraft.

2) The UA may not be flown at an indicated airspeed exceeding 30 knots.

3) The UA must be operated at an altitude of no more than 300 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC

must be in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

- issued airman medical certificate.

5) All operations must utilize a visual observer (VO). The UA must be oper ated within the visual line of sight (VLOS) of the VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be de signated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents.

6) The operating documents and the grant of exemption mu st be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between

the conditions and limitations in the exemption and the procedures outlined in the operating

documents, the conditions and limitati ons herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The
operator may update or revise its operating documents. It is the operator's responsibility to track

such revisio ns and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if he petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption.

### Luiz Leone tti

– Asheville, NC

– Section 333 Exemption Petition 3 7) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If

th e inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from operating until the necessary maintenance has been performed and the UAS is

found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft

records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight criti cal component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

9) The pre

- flight inspection section in the operating documents must account for all discrepancies,
i.e. inop erable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit require ments.

11) The operator must carry out its maintenance, inspections, and record keeping requirements,

in accordance with the operating documents. Maintenance, inspection, and alterations must be

noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.

12) Each UAS operated under the exemption must comply with all manufacturer Safety Bulletins.

13) The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

1 4) UAS operations must be conducted by a PIC possessing at least a current third

- class medical

certificate.

15) Prior to operations conducted for the p urpose of aerial photography/videography and augmenting real estate listing videos (or similar operations), the PIC must have accumulated and
logged , in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experien ce

- building flights c an also be

conducted under the grant of exemption to accomplish the required flight time. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights the PIC is r equired to operate the UA with appropriate

distances in accordance with 14 CFR 91.119.

16) Prior to operations conducted for the purpose of aerial photography/videography and augmenting real estate listing videos (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot
operating the make and model of the UAS to be used in operations under the exemption; 5 hours

make and model time may be included in the 10 hours of mul ti

- rotor time prescribed above. The

PIC must accomplish 3 take

- offs and landings in the preceding 90 days (for currency purposes).
Training, proficiency, experience

- building, and take

- off and landing currency flights can be

conducted under this grant of ex emption to accomplish the required flight time and 90 day
currency. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119.

17) The operator may not permit the PIC to operate the UAS for the purpose of aerial photography/videography and augmenting real estate listing videos (or similar operations), unless

the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropr iate distances from people, vessels, vehicles and structures.

18) UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations

must be conducted under visual meteorological conditions (VMC}.

### Luiz Leone tti

– Asheville, NC

– Section 333 Exemption Petition 4 19) The UA may not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA

- published aeronautical chart.

20) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute m iles from the PIC.

21) If the UA loses communications or loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents.

22) The PIC must abort the f light in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

23) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruis ing spee d to the intended landing point

and land the UA with 30% battery power remaining.

24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this gran t of exemption. This COA

will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in
advance, but not less than 48 hours prior to the operation.

25) AII aircraft operated in accordance with this exemption must be identi fied by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

26) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

27) The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is ope rating. These documents must be

made available to the Administrator or any law enforcement official upon request.

28) The UA must remain clear and yield the right of way to all manned avi ation operations and

activities at all times.

29) The UAS may not be operated by the PIC from any moving device or vehicle.

30) The UA may not be operated over congested or densely populated areas.

31) Flight operations must be conducted at least 500 fe et fro m all nonparticipating persons,

vessels, vehicles, and structures unless: a. Barriers or structures are present that suffici ently

protect nonparticipating persons from the UA and/or debris in the event of an accident. The

operator must ensure that no nparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, ve hicles

or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard , and; c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a).

32) AII operations shall be conducted over private or controlled

- access property with permission

from the la nd owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries

of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:
www.ntsb.gov

. Unless otherwise specified in the grant of exemption the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts45, 4 7, 61, and 91.

### Luiz Leone tti

– Asheville, NC

– Section 333 Exemption Petition 5 VI. A Summary the FAA May Publish in the Federal Register:

The applicant, Luiz Leonetti is a Licensed Realtor® and Professional Real Estate Photographer. Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviati on Regulations from 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.121; 91.151(a); 91.40S(a); 91.407(a)(1);
91.409(a)(1)(2); 91.417(a)(b); 91.119(c).

Similarities to Granted Exemption No. 11138 Douglas Trudeau, Realtor®:

This exemption request is virtually the sam e as the Granted Exemption No.11138 in that the proposed usage of the UAS is for the same Real Estate purpose, it is similar UAS model, and all of the FAA requirements set forth in Granted Exemption No.11138 will be complied with.

- End of Summary

In clo sing, I, Luiz Leonetti respectfully request that I be granted an exemption as set forth above for the purpose of aerial photography/videography and augmenting real estate listing videos (or

similar operations).