James Huenergardt Reel Inspirations, Inc. 238 Wind River Drive Chehalis, WA 98532 July 22, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590 Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regu

lations from 14 C.F.R. Part 21, 42.27(a), 45.29(3)(c)(d)(e)(f)(g)(h), 61.113(a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151 Following the format of the FAA Exemption No. 11138 - Regulatory Docket No. FAA-2014-0481 I have includ

ed: 1. Phantom 3 Professional Operating Manual link here: http://www.dji.com/product/phantom-3/download The original PDF is too large to upload to the web site. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, James, a professional videographer and photographer as well as a licensed pilot with ratings of Airline Transport Pilot, Multiengine Land, Commercial Single Engine Land and Certified Flight Instructor , preparing this exemption re

quest myself, would like to apply for an exemption from the following Code of the Federal Regulations (C.F.R.) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (UAS) to obtain aerial images and video of real estate properties. I have over 30 years of experience flying fixed winged aircraft and recently have been flying a DJI Phantom 3 Professional. The maximum gross weight of the Phantom 3 Professional is approximately 1280 grams, or just under 3lbs. This aircraft is equipped with four rotors that are driven by electric motors with a maximum speed of approximately 35mph. The Phantom 3 has a return to home feature that enables the UAS to return to the launch point should the battery level reach a pre-determined level or a loss of control signal occur. My intent is to use the Phantom 3 Professional to augment real estate listings using aerial photography and video; following an exemption and approval by the FAA. My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control) in a predetermined area away from general public, airports, heliports and vehicular traffic, under 400 feet AGL, after carefully reviewing, inspecting and examining the area of aerial observation. This will enable me to obtain images and video in a safe manner to enhance real estate listings. I will abide by all FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe envi

ronment that is strictly controlled; and I will conduct extensive preflight inspections and protocols, during which safety carries primary importance. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 Given the size, weight, speed and limited operating area associate with the aircraft to be utilized, I am asking exemption from 12 C.F.R., Part 21 Subpart H (Airworthiness Certificates) and §91.203 (a) and (b) (Certifica

tions required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 C.F.R. Part 11 and Section 333 of P.L 112-95 (Section 333)14 C.F.R. 45.27 (a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3)(c)(d)(e)(f)(h): Size of Marks Furthermore, I request an exemption from §45.23 Marking of the Aircraft because my UAS does not and will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally, two inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering require

ment. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the word “Experimental” or assigned number or name 9based on a request or ruling by the FAA) on its fuselage as required by §45.29(f) so that anyone assisting the pilot of the UAS as a spotter will see the markings. 14 C.F.R. 91.103 (b)(1),(b)(2): Preflight Action If granted an exemption, I agree to additional safety procedure including, but not limited to: 1. Operate my UAS only within visual line of sight (VLOS) 2. Use the UAS’s global positioning system, GPS flight safety feature; it hovers at a selected altitude and returns to the point of origin and lands safely if communication is lost from the remote control unit. 3. Conduct all flight operations during the day and under visual meteorological conditions (VMC). 4. Contact respective airports if operation will be 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. 5. Always obtain all necessary permission prior to flight operations. 6. Log all flights in my UAS Pilot Log, along with any aircraft maintenance. 7. Always operate the UAS with a second person acting as spotter.

Public Interest Aerial videography for real estate marketing is currently available through manned fixed and rotor winged aircraft, but for most small businesses, the expense can be cost-prohibitive. Granting this exemption would al

low me to provide this service at a much lower cost. Further, I believe my small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. I also believe that the operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies and persons looking to relocate areas filmed. Sincerely,

James Huenergardt President/Director – Reel Inspirations