August 14, 2015

Exemption No. 12468

Regulatory Docket No. FAA–2015–2212

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 aircraft system (UAS) to conduct aerial 

videography and cinematography.

See Appendix A for the petition submitted to the FAA describing 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, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public 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 aircraft 
2

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

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 Labs, 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 

addition 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 relief 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 (particulate 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 exemption 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-issued 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated 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 duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions 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 between the conditions and 
4

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 its 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. The 

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 FAA’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 alterations 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 conducted 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 

potential 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 is 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 must 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 Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC 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 and 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 the operator’s PICs and VOs 

(training, 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 exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate 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 symbol 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 with 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 statute miles from the PIC.

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

pre-determined location within the private or controlled-access property.

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

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 conducted 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 

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.

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 enforcement 

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 

that 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 nonparticipating 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 controlled-access property with 

permission from the property 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 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.
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 to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area 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 the 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 permission 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, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Dear 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 

Realtor®, 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 

operational approach (closer than 500’) and equipment being utilized (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 from 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 aircraft 

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 

operations 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) 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 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, Realtor® 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 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: 

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 the 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 relief Travis Campbell Realtor® seeks and the reason they 

seek such relief: 

Travis Campbell Realtor® submits this application in accordance with the Reform 

Act, 112 P.L.95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent commercial 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 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 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. Weighing 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 smallunmanned aircraft 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 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 pilot
communication 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 

hundred (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 aircraft approach their location or should they 

suspect manned aircraft 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 (200) 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 

UAS/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 and 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 Campbell 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 their 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 minimizing ecological and 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 space 
furthers economic growth. Granting their exemption request substantially 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 Realtor® 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 aerial 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 Campbell, Realtor® will only operate their UAS below 200 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 will land their UAS prior to manufacturer recommended 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 flight 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 will 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 will 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 rules. The potential loss of life 

is diminished because UAS's carry no people on board and only operates in 

specific areas away from mass populations. There is No fuel on board a UAS 

and thus the potential for fire or explosions is greatly diminished. The small 

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 permits 

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 of 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 32827. 

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 

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 Travis Campbell Realtor®. 

14 C.F.R. § 45.23: Marking of the Aircraft. 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. Further, 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” on 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 altitude greater than 200 AGL; in 

accordance with the standard of 400 AGL. Travis Campbell Realtor® will 
operate 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 prescribed 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 inspect 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 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 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