July 7th, 2015

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12­140 1200 New

Jersey Avenue, SE.,

Washington, DC 20590

Shane J. Renard Coldwell Banker The Real Estate Group, Broker Associate

Green Bay, WI 54311

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.

R. Part 11, Shane J. Renard, seeks an exemption from Federal Aviation Regulations ("FARs") detailed

below for the following described Unmanned Aerial System called in this application the ME System, which

includes an Unmanned Aircraft (UA) and ground station­based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

A lightweight (20 lb gross weight with all on-board equipment), manufactured by DJI, DJI Phantom 3

Professional Quadcopter Drone with 4K UHD Video Camera

An on­board flight computer with GPS navigation and location ability that receives signals for flight controls

from a ground­based transmitter/controller;

An on­board camera capable of capturing imagery in the form of full color, high definition still photos and

video;

An on­board telemetry system that delivers flight data from the on­board flight computer to the on­board

radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and

direction back to its launch site;

● 4k UHD video recording with fully stabilized 3­axis gimbal; Vision Positioning system allows

stable flight indoors
● Lightbridge digital streaming allows live viewing of 720p video (full resolution video is

simultaneously recorded on the internal microSD card)

● Included flight battery and rechargeable remote controller means this system is ready to fly out

of the box

● DJI Pilot app for iOS and Android allows live viewing and complete camera control (phone/tablet

sold separately)

● Fying this product is restricted within 15 miles radius of the White House

A 2.4GHz on­board radio transmitter that transmits live video from the on­board camera plus all the flight

data from the telemetry system described above;

THE GROUND STATION ­BASED PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls

the UA while in the air;

2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight; A radio receiver

receiving live video and flight data from the on­board camera and computer projects it all together onto a

screen for the PIC to view during flight;

A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while in

flight.
The requested exemption would support an application for a commercial Certificate of Authorization to use

the above described ME System to support Production of promotional materials (video and/or still images)

for Real Estate sales Production of promotional materials, (video and/or still images) for marketing and sales

of properties in the state of Wisconsin ONLY. This would be (video and/or still images) for commercial

businesses, Photography and videography of marketing, such as video feeds for displaying the properties

for sale or lease. Never operating over persons not directly involved with the ME system.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on

combustible fuel, it operates at lower altitudes under 100’ with no people on board and will thereby reduce

current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury.

With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national

security.

Low level oblique photos and video from several angles are far more effective than ground­ based imagery

for displaying the characteristics of large, complex properties with several buildings and large trees. The

alternative could be to charter a full­sized helicopter for this purpose, which has proven more costly than

many potential clients are able to afford. The benefits of reduced cost and improved quality of presentation

from the UA will be valuable to and benefit many buyers and sellers of real property and marine property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby who might

require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all

limitations cited in this application as we do so.
The ME System will be operated in the field with both a PIC and aVO in accordance with FAA Policy N

8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an

airspeed of no more than 50 knots and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice

at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the property owner; e) The PIC

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours

logged as a UA pilot with a similar UA type;

f) All required permits will be obtained from state and local government prior to operation;

g) The ME System will not be operated over densely populated areas;

h) The ME System will not be operated at air shows;

i) The ME System will not be operated over any open­air assembly of people;

j) The ME System will not be operated over heavily trafficked roads;

k) The ME System will not be operated within 5 NM of an airport or heliport;

I) Operations will be restricted to day only and weather conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each

new location;

n) No flight may be made without a Pre­Flight Inspection by the PIC before each operation to ascertain that

the UA is in a condition safe for flight (see Appendix A).
The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a

course of maintenance instruction as part of their initial training.

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight

crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a)

through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or

greater level of safety than manned aircraft performing the same mission.

The name and contact information of the applicant are:

Shane J. Renard Coldwell Banker The Real Estate Group: Shane J. Renard Ph: 920­606­4436

Email: srenard@coldwellhomes.com or srenard2004@yahoo.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is

the page of the attached Addendum upon which each may be found together with our proposed equivalent

level of safety for each regulation:

­ 14 CFR Part 21 .................................Addendum Page 1

­ 14 CFR 91.203.................................Addendum Page 1

­ 14 CFR 45.23, 45.29..........................Addendum Page 2

­ 14 CFR 91.9....................................Addendum Page 2

­ 14 CFR 61.113, 61.133.......................Addendum Page 2

­ 14 CFR 91.109, 91.119, 91.121 .............. Addendum Page 3

­ 14 CFR 91.151 .................................Addendum Page 3

­ 14 CFR Subpart E (91.401 ­ 91.417) ......Addendum Page 3

­ FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) ...Addendum 1

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of

safety. Please contact us at any time if you require additional information or clarification. We look forward to

working with your office.

Sincerely,

Shane J. Renard

Shane J. Renard Coldwell Banker Broker Associate

Addendum containing Exemption Requests and Equivalent Level of Safety Appendix A ­ Flight Manual's

Appendix B ­ Owner's Manual for UA
ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Shane J. Renard requests an exemption from the following regulations as well as any additional regulations

that may technically apply to the operation of the ME System:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an
experimental certificate be issued for the ME System under either or both of the following provisions: 21.191

Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft

installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance

with the airworthiness regulations including flights to show compliance for issuance of type and

supplemental type certificates, flights to substantiate major design changes, and flights to show compliance

with the function and reliability requirements of the regulations. Since the experimental certificate can be

used for commercial purposes such as market surveys, sales demonstrations, and customer crew training,

we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational

requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic,

we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft

performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an

exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general,

citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft

and a registration certificate must be aboard the aircraft. Additionally, subparagraph

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is

legible to passengers or crew."

At a maximum gross weight of 6.5 pounds, the UA is too small to carry documentation, does not have an

entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and

meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will

be co­located with the crew at the ground control station and available for inspection upon request. In order

to identify the aircraft, we propose that the information found on airworthiness and registration certificates be

permanently affixed to the aircraft via placard containing the following information plus the word

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23, which follows immediately after the

proposed placard description below:
Appendix A

EXPERIMENT AL

Manufacturer: DJI Phantom 3 Professional Quadcopter Drone with 4K UHD Video Camera

14th Floor, West Wing, Skyworth Semiconductor Design Building, No.18 Gaoxin South 4th Ave, Nanshan District,

Shenzhen, China, 518057.

Tel: ​+86 0755 26656677

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

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These regulations provide that each aircraft must display N'' and the aircraft's registration number in letters

at least 3 inches high. Additionally, the aircraft must display the word

EXPERIMENTAL​in letters at least 2 inches high near the entrance to the cabin, cockpit, or
pilot station. The UA does not have an entrance in which the word EXPERIMENTAL​can be placed, and

may not have a registration number assigned​to it by the FAA.

We propose to achieve an equivalent level of safety by including the word

in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the

vicinity of the aircraft while it is preparing for launch will be able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous paragraph will

provide the aircraft's registration information at the ground station. Finally, we will display at the

ground station a high contrast flag or banner that contains the words UNMANNED​Aircraft or UAV

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Ground Station in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground

station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point

of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in

the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is

available to the aircrew while operating the aircraft. We request an exemption to this requirement since the

aircraft is not only too small to carry documentation, the documentation would not be available to the crew

during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA

Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or

preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot

privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an

aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an

aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Our proposed operations require that the PIC must either

1. Hold a Sport Pilot Certificate issued by the FAA, and have logged 25 hours of flight experience in this type

of UA, or

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2. Meet the requirements of 8900.227 para 16(c)(2)(c) 0perations without a pilot certificate in which the PIC

is required to complete FAA private pilot ground instruction and pass the FAA

Private Pilot written examination Since there are currently no means available for the pilot of a UAS to gain

the experience in an equivalent category and class in order to apply for a commercial pilot's license, we

propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA

commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition

Appendix A

to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel

we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a

business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that No person may operate a civil aircraft that is being used for flight instruction

unless that aircraft has fully functioning dual controls."

The ME System ground­based control station consists of a small hand­held radio transmitter

and while it does not offer a second set of COntrols ,both the student and instructor can, and

will, operate the single set of controls simultaneously. With both student and instructor having

hands­On the controls during flight, we feel that this technique meets the intent 91.109 and provides an

equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet

to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet

AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety we will only fly over private property with a size of at least

two acres with the permission of the owner of the property flown over. The aircraft will not be operated over

congested areas or over any open air assembly of persons. The property owner will be briefed on the

expected route of flight and the associated risks to persons and property on the ground. The aircraft will be

operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface.

Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is

minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting

available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent

conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is

transmitted via radio from the UA on­board computer to the display screen held by the PIC, providing a

constantly updated AGL readout.
14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day­VFR conditions unless

there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a

safety buffer for delays to landing. The UA is battery operated and the maximum duration of flight from a

single battery charge is 18 minutes with a 20°/o reserve. Since the aircraft will never fly more than 314 NM

from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve

energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent

interpretation with the word "energy".

14 CFR Subpart E (91.401 ­ 91.417) ­ Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy

condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft

be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to

approve the aircraft for return to service." As provided in the Pre­Flight Checklist in Appendix A, the PIC will

ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed

inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small

cracks, replacing a propeller, checking electrical connections and updating software and firmware for the

on­board computer. All other maintenance will be performed by the manufacturer or their designated repair

facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size,

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second­class medical certificate

issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 6.5

pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO

are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically

incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land

without crew intervention.

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying

passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a

valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see

and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.
APPENDIX A ­ FLIGHT MANUAL

FLIGHT RESTRICTIONS

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed of no more

than 50 knots and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally

at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the property owner; e) The PIC

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours

logged as a UA pilot with a similar UA type;

f) All required permits will be obtained from state and local government prior to operation; g) The ME System

will not be operated over densely populated areas;

h) The ME System will not be operated at air shows;

i) The ME System will not be operated over any open­air assembly of people;

j) The ME System will not be operated over heavily trafficked roads;

k) The ME System will not be operated within 5 NM of an airport or heliport;

I) Operations will be restricted to day only and weather conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each

new location;

n) No flight may be made without a successful Pre­Flight Inspection by the PIC before each operation to

ascertain that the UA is in a condition safe for flight.

PREFLIGHT CHECKLIST

1. Remote controller, aircraft battery, and mobile device are fully charged.

2. Propellers are mounted correctly and firmly.

3. Micro­SD card has been inserted if necessary.

4. Gimbal is functioning as normal.

5. Motors can start and are functioning as normal.

6. DJI Pilot app connected to the aircraft.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT

If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is activated

and will bring the UAV back to the PIC.

Thank you for taking the time to review my request of the UAV per section 333 of the FAA guidelines.

Sincerly,

Shane J. Renard

Broker Associate

Coldwell Banker The Real Estate Group

1203 Kellogg St. Green Bay, WI 54303

(920)606­4436

srenard2004@yahoo.com

srenard@coldwellhomes.com