August 14, 2015

Exemption No. 12468 Regulatory Docket No. FAA

– 20 15

– 2212

Mr. Travis Campbell

Realtor 10925 Blair Forest Drive, #117 Houston, TX 77042

Dear Mr. Campbell :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated May 22, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption

. You requested to operate an unmanned ai rcraft system (UAS) to conduct aerial videography and cinematography

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3 Advanced

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Sec tion 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft2

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirem ents of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition.

In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in

ad dition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to rel ief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Travis Campbell, Realtor is granted an exemption

from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data

collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Mr. Travis Campbell, Realtor is hereafter referred to as

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exempt ion are limited to the DJI Phantom 3

Advanced when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the 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

- issue d airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and 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 ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot tra nsfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the condition s and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists be tween the conditions and4

limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in it s operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. Th e operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alt erations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be cond ucted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potentia l discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS i s found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption mus t comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a
state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive a nd emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training th e operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemp tion. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must o perate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP , the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement w ith the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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 st atute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or em ergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial

num ber, 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 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 aircraft is operating. These documents must be made available to the Administrator or any law enforcem ent official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure

tha t nonparticipating 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 in a manner ensuring the safety of nonparticipa ting persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the prop erty owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vert ical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

containe d on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities t o the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permissio n must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this 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,

parts 45, 47, 61, and 91.8

This exemption terminates on August 31, 2017 , u nless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresDear Sir or Madam,

Travis Campbell Realtor® seeks exemption pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, from the Federal Aviation Regulations (“FARs”) listed below so that Travis Campbell

Real tor® , may operate their small ultra

- light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

This petition is, in most regards, similar to granted exemption No. 11138 both in operatio nal approach (closer than 500’) and equipment being u tilized (DJI Phantom

3 Advanced ).

As described herein Travis Campbell Realtor® real estate agent licensed within the

State Texas has added a UAS to their inventory equipped with a DJI camera with

intent for aerial videography/cinematography to enhance community awareness for those individuals and companies unfamiliar with the geographical layout of real estate listings in the state of Texas , and augment real estate listing videos; following exemption and approval by the FAA.

Travis Campbell Realtor® exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS in tightly controlled and limited airspace. Predetermined in areas away f rom general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing. Travis Campbell

Realtor® has instilled safety and prevent public hazard, as well as manned airc raft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as Travis Campbell

Realtor® records flight data and other information gained through permitted flight

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

Protocols and Controls

Travis Campbell

, Realtor® request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibi lities 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 t o the use of UAS's for real estate/Realtor purposes. Further Travis Campbell

, Realtor® will conduct their operations in compliance with the protocols described herein or as otherwise established by the

FAA.

For the reasons stated below Travis Campbell

, Re altor® respectfully requests the grant of an exemption allowing operation of ultra

- light weight, remote controlled UAS’s for community awareness to benefit/stimulate attraction to the Indiana real estate market and to enhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of which will promotelocal economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containin g combustible fuel that that poses potential public hazard.

I. Contact Information:

Travis Campbell, Realtor® 10925 Briar Forest Dr #1107 Houston, TX 77042 Mobile: (832 ) 463

- 8333

Email: travis.tamu12@gmail.com

II

. The Specific sections of Title 14 of th e Code of Federal Regulations from

which Travis Campbell, Realtor® requests exemption:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The extent of re lief Travis Campbell Realtor® seeks and the reason they

seek such relief:

Travis Campbell Realtor® submits this application in accordanc e with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent co mmercial cinematic 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. Travis Campbell Realtor® , ultra

- light weight UAS

meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of their ultra

- light weight UAS is expressly contemplated by

the Reform Act. Travis Campbell Realtor ® would like to operate their ultra

- light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely i n 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 are in favor of an exemption for Travis Campbell Realtor® . Their UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. Their UAS is equipped with GPS and auto return safety technology. We ighing less than ten (10) pounds (far below the maximum 55 pound limit); including camera.

Travis Campbell Realtor® , considers safety as foremost with each flight. Their small

unmanned aircraft is designed to hover in place via GPS and operate in less tha n a 24

- knot (15 mph) wind. For safety, stability and fear of financial loss they will not fly in winds exceeding16 kph (10 mph). Built in safety systems include a GPS mode that allows their UAS to hover in place when radio controls are released. When pilotcommunication is lost UAS is designed slowly descend to point of takeoff. Travis Campbell Realtor ® will not operate their UAS near airports, Hospitals nor Police heliports, and will not operate near areas where general public is within fifty to one

hundre d (50

- 100) yards depending on location, conditions and weather. Travis Campbell Realtor ® will be prepared to land/abort immediately to the nearest and safest ground point should a manned aircra ft approach their location or should the y suspect manned aircra ft may approach near their location. Travis Campbell,

Realtor® UAS is capable of vertical and horizontal operations, and will only be flown within line of sight of the operator. Utilizing battery power rather than combustible fuels, flights generally last between ten (10) to fifteen (15) minutes, with an altitude

under two hundred (2 00) feet. Travis Campbell Realtor® will utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is twenty

- five (25 ) minutes. Travis Campbell Realtor ® will not operate their UAS at or below manufacture 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 will be at hand with each exercise to insure replacement for sufficient safe level of operation.

Travis Campbell Realtor® will exercise extremely caution when operating of their

U AS/ultra

- light weight unmanned aircraft 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 their 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. Travis Campbell Realtor® 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 Travis Campbell Realtor® request will benefit the public as a whole:

Aerial videography for geographical awareness and for real estate marketing 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 videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense, depriving non

- luxury

homeowners a nd lower budget Realtors from a valuable marketing tool..

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting Travis Cam pbell Realtor® , exemption request furthers the public interest through visual awareness of the geographical benefits in Indiana.

Their ultra

- light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of thei r 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. The public’s interest is furthered by minimi zing ecological an d crash threat by permitting aerial video/photo capture through their battery operated ultra

- light weight UAS's. Permitting Travis Campbell Realtor® to immediately fly within national air spacefurthers economic growth. Granting their exemption request sub stantially furthers the economic impact for the Houston, TX community for companies looking to relocate or build in the area as well as individuals looking to relocate, both of which serve as a stimulus to the community.

V. Reasons why Travis Campbell Rea ltor® exemption will not adversely affect safety or how the exemption will provide a level of safety at least equal to existing rule:

Travis Campbell Realtor® exemption will not adversely affect safety. The following represents enhancements to current aer ial videography and photography for real

estate:

Their UAS weighs less than 10 pounds complete with a small ultra

- light weight high quality DJI Long Range V2.0 camera;

• Travis Campbe ll, Realt or® wil l only operate their UAS below 2 00 feet (within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);

• Their UAS only operates for 10

- 15 minutes per flight;

• They wil l land their UAS prior to manufacturer re commended minimum level of battery power;

• They will pilot their UAS through remote control only by line of sight;

• Cobblestone Realty will utilize a private pilot with experience in manned and radio controlled aircraft operation;

• Their UAS has GPS a flig ht safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

• Their pilot will actively analyze flight data and other sources of information to constantly update and enhance safety protocols;

• They wil l only operate in reasonably safe environment, away from power lines, elevated lights, airports and actively populated areas;

• They will conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance;

• They will obtain all necessary permissions prior to operation; and,

• They wil l have procedures in place to abort flights in the event breaches or potential danger of safety Travis Campbell Realtor® safety protocols provide a level of safety equal to or exceeding existing r ules. The potential loss of life is diminished because UAS's carry no people on board and only operates in specific are as away from mass populations. T here is No fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. The s mall size and extreme maneuverability of the UAS allows for it to be remotely piloted away from and avoid hazards quickly and safely.

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. 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 and weight of Travis Campbell Realtor® UAS pe rmits exemption from Part 21 because their 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. Travis Campbell Realtor® , UAS meets or

exceed 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 on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level o f safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 3 2827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as the UAS utilizes electronic global positioning systems with a barometric sensor.

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

an d 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 Travis Campbell Realtor®

.

14 C.F.R. § 45.23: Marking of the A ircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Fur ther, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, Travis Campbell Realtor® will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” o n its fuselage as required by 14 C.F.R. §45.29 (f) so that the pilot, or anyone assisting the pilot as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

1. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Their UAS will never operate at an alti tude greater than 2 00 AGL; in

accordance with the standard of 400 AGL. Travis Campbell Realtor® willoperate their UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher level of safety will be achieved.

2. 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 pres cribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Travis Campbell Realtor® , UAS. However, as a safety precaution Travis Campbell Realtor® pilot will ins pect their 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 fort h requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size and weight of Travis Campbell Realtor® UAS permits exemption from Part 21 because Travis Campbell Realtor® , UAS meets an equivalent level of safety pursuant to

Section 333 of the Reform Act.

Respectfully Submitted,

Travis Campbell, Realtor ®

10925 Briar Forest Dr. #1107 Houston, TX 77042