Jacquelyn Lynaugh

404 Meadowmont Village Circle Chapel Hill, NC 27517 Jackie.Lynaugh@bhhsysu.com ( PH) 919

- 218

- 0915

September 8, 2015

U.S. Department of Transportation Docket Operations 800 Independence Ave., S.W

. Washington, DC 20591

**Subject :**  **Petition of Jacquely**  **n Lynaugh for Exemption**  **Pursuant to Section 333 of the**  **FA A**  **Modernization and Reform A ct of 2012 and 14 C.F.R. Part 11** 

**Follo wing the format of FAA**  **Exemption includ es**  **:**

1. Supplemental Response for Petition 2. Personal protocols and controls

- Safety/Flight concerns 3 . Copy DJI Phantom 3 Advance user’s manual

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, I, Jacquelyn Lynaugh (individual) hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) identified below, to allow civil operation of small unmanned aerial systems (“sUAS” or “UAS”) as part of daily business operations

.

**TA BLE OF CONTENTS**  I. Description of Petitioner II. Description of Proposed Operation III. Jacquelyn Lynaugh Proposed UAS Operations Meet the Requirements of Section 333 a. App roval is Wa rranted Based on the UAS's Size, We ig ht, Speed, and Operational Capability b. Approval is Wa rranted Based on the Operational Restrictions Set Forth in the included UAS Standard Operating Guide IV. Regulations From Which Exemption is Sought a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates b. 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft c. 14 C.F.R. §§ 45.23(b) and 45.27(a): Marking of the Aircraft d. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness e. 14 C. F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil Aircraft Flight Manual in the Aircraft 2 f. 14 C.F.R. § 91.103: Preflight Actions g. 14 C.F.R. § 91.109(a): Flight Instruction h. 14 C.F.R. § 91.119: Minimum Safe Altitudesi. 14 C.F.R. § 91.121: Altimeter Settings

j. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions k. 14 C.F.R. § 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections l. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitation s

**I. Description of Petitioner** Jacquelyn Lynaugh provides real estate services to clients that require photographs. My clients have requested aerial photographs that would require hiring an outsider to provide services related to taking said photographs.These photos are often utilized for marketing purposes.

*******Jacquely n Lynaugh**  **is an independent contractor working as a licensed North Carolina Real Estate Broker**  **. S ervices include real estate consultation and sales** 

**. I have completed**  **the NC State Division of A viation Unmanned A** **ircraft Systems (**  **UA S) Operators**  **Know ledge Test**  **and the NC Transportation UA** **S Commercial Operator Permit from the Division of A** 

**viation Permit No: C0000092, and**  **sponsored by Michael**  **John Lynaugh**  **wh ich is a commercial helicopter pilot**  **Certificated A irman's**  **number 3796489**

**.**

In accordance with 14 C.F.R. § 11.81(a), Jacquelyn Lynaugh provides the following information in support of its Petition for Exemption.

Name and Address fo r Petitioner and contact information is as follows : Jacquelyn Lynaugh 404 Meadowmont Village Circle Chapel Hill, NC 27517 Jackie.lynaugh@bhhsysu.com

**II. Description of Proposed Operation** Jacquelyn Lynaugh proposes to conduct the operation of a UAS, specifically the DJI Phantom 3 Advanced, within the parameters of providing aerial photographs of single family residences and or large acreage parcels of land as t he Pilot in Command (“PIC”) for each operation will, at a minimum, be Jacquelyn Lynaugh

. Jacquelyn Lynaugh ha s adopted and incorporated many of the AMA’s UAS Safety Code (the “Code”) and Operating Guide’s (the “Guide”) procedures into its own safety code and guide, which sets forth the mandatory standard operating procedures for its proposed UAS operations as detailed herein. The exception would be the location of operations that will take place at private residences with the authorization of the owner and not on property leased or owned by the AMA. These procedures provide a baseline to ensure that the Phantom 3 Advanced pilot possess sufficient knowledge of both airspace and the technology to operate safely in the National Airspace System (“NAS”). Any other assistant or photographer will operate with Jacquelyn Lynaugh as the PIC in each operation and will meet th e standards specified in the Guide, as well as any other additional requirement the FAA requires under this application.

**III. Proposed UA S Operations Meet the Requirements of Section 333**  Proposed operations in this Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied. **a. A pproval is Warranted Based on the UA** **S’s Size, Weight, Spee d, and**  **Operational Capability**Jacquelyn Lynaugh will employ the DJI Phantom 3 Advanced quadcopter for the

operations described in this Petition for Exemption. This UAS is classified as a small drone or hobby craft and is lawfully used for recreational operations. The Phantom 3 Advanced has a maximum take

- off weight of 5.53 pounds. The flight speed is limited to a maximum of 33.5 miles per hour and it will not be flown at an altitude that exceeds 200 feet AGL. All flights will be managed in such a way that t hey can be safely terminated with a reserve battery power of 25% of the battery's maximum charge. The DJI Phantom 3 Advanced does not carry any flammable propellant or fuel. The UAS also has an integrated GPS system that calculates the UAS's position and h eight and relays that information via a secure connection to the operator. Through use of this GPS system and the installed firmware, the user is able to set maximum height and radius in relation to a pre

- determined home point, restricting flight to a zone that is both approved by the FAA and the owner of the property being photographed. This system also automatically restricts flight within a range of airports that is greater than the 5 miles that the FAA requires. Additionally, the UAS contains a failsafe mode if its connection to the remote control is lost, and this system permits the UAS to return to a predetermined location and land without injury or damage.

**b. A pproval is Warranted Based on the Operational Restrictions**  **Set Forth in the UA** **S Standard Operating Guide**  Together, the Guide and the DJI Phantom 3 Advanced User Manual contain all of the procedures and limitations necessary to successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety ass essment of Jacquelyn Lynaugh ’s proposed operations, below is a summary of operational limitations and conditions wh ich will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The Phantom 3 Advanced weighs 5.53 +/

- pounds. 2. Flights will be operated within the VLOS of the PIC and or an observer, at a minimum. 3. Maximum total flight time for each operational flight will be limited to 25% reserve battery power remaining. 4. Flights will be op erated at an altitude of no more than 200 feet AGL. 5. All operations will be conducted in class G airspace. 6. Flights will be restricted to pre

- determined areas of the owner/clients property, which will always be located outside of 5 miles radius from an airport of any size or the necessary NOTAM will be filed for safe operation in advance of operations. 7. Flight zones will be located at the maximum distance away from persons, inhabited structures, and vehicles that is possible given the layout of the property. The flight zone in which operations occurs will be assigned based on the real

-time traffic, activities, and weather conditions. 8. Flights will be limited to a speed of 30 mph and vertical ascent will be limited to 15 mph. 9. The UAS will be operated and maintained in accordance with the requirements of the Phantom 3 Advanced User Manual and any manufacturer Safety Bulletins. 10. Prior to the operation, the flights will be fully preplanned and briefed, including possible contingencies and emergency procedures. 11. The UAS will have the capability to abort flight in the case of unpredicted obstacles or emergencies. 12. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.13. All UAS operations will occur in daylight, Visual Flight Rules ("VFR") conditions.

Instrument flight rules flights are prohibited and no flights will occur at night, or in adverse weather conditi ons. 14. The UAS will be controlled by the Phantom 3 Advanced Remote Control System and the radio frequency spectrum used for operation and control of the UA shall comply with the Federal Communications Commission ("FCC") or other appropriate government oversight agency requirements.

**IV. Regulations From Which Exemption is Sought** The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defi ned under § 40101 of the Act, including UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. Jacquelyn Lynaugh seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using UAS. Listed below are: (1) the specific sections of 14 C.F.R. for which exemption is sought, and; (2) reasons why the exemption would not adversely affect safety or provide a level of safety equivalent to the rule, including any operating procedures and safeguards that Jacquelyn Lynaugh has adopted which will ensure a level of

safety better than or equal to the rules from which exemption is sought.

**a. 14 C.F.R. Part 21, Subpart H: A** **irw orthiness Certificates**  Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness certificates. Jacquelyn Lynaugh requests exemption from this subpart to operate the Phantom 3 Advanced without the requirement for an airworthiness certificate. Based on the proposed UAS being limited in size, weight, speed, operating capabilities, and operating within VLOS, Jacquelyn Lynaugh believes that an airworthiness certificate is not necessary to ensure an equi valent level of safety to manned aircraft operations.

Equivalent Level of Safety The UAS indicated is safe when taking into account its size, weight, speed, and operational capability. As set forth above, the Phantom 3 Advanced weighs less than 7 pounds and will be flown at less than 30 mph and completely outside controlled airspace. Additionally, the craft carries pilots nor passengers, carries no explosive materials and or flammable liquid fuels, and operates exclusively within the parameters stated in the Guide. Operations conducted under this exemption will be closely controlled and monitored by the PIC and will be conducted in compliance with local public safety requirements, to provide security fo r the area of operation. In all cases, the UAS operate d under the proposed conditions, will be at least as safe as, or safer than conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations. Further, the Phantom 3 Advanced does not need a means to communicate with other aircraft or ATC, because those capabilities will be possessed by the PIC and Observer, who are not onboard the UAS. See Grant of Exemption, Docket FAA

- 2014

- 0352 at 13. In addition , the UAS will be operated at all tim es in visual line

- of

-sight and in VFR conditions. Id

. **b. 14 C.F.R. Part 27: A irwo**  **rthiness Standards for Normal Category Rotorcraft**  Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent Jacquelyn Lynaugh UAS would otherwise require certification under Part 27, it seeks an exemption from Part 27's airworthiness standards fo r the same reasons identified in the request for exemption from 14 C.F.R . Part 21, Subpart H. **c. 14 C.F.R. §§ 45.23(b) and 45.27(a): Marking of the A ircraft**  Jacquelyn Lynaugh seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 45.23(b) and 45.27(a).14 C.F.R. § 45.23(b), Marki ngs of the Aircraft, states:

Wh en marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must als o display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," " light

- sport, "experimental," or "provisional," as applicable. 14 C.F.R . § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the Phantom 3 Advanced is by definition “unmanned” and so has no entrance to a cabin, cockpit, or pilot station on which the above stated words can be placed. Given the size of the UAV, two

- inch lettering may be impossible. Th e word “Exempt” can be placed on the fuselage in compliance with 14 C.F.R. § 45.29(f). Equivalent Level of Safety The equivalent level of safety will be provided by having the Phantom 3 Advanced marked on its fuselage as required by 14 C.F.R. § 45.29(f) where the pilot, observer and others working with the UAS will see the identification of the Phantom 3 Advanced as “Exempt” if so desired. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. **d. 1 4 C.F.R. § 91.7(a): Civil A** **ircraft A irw**  **orthiness**



### . e a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the Phantom 3 Advanced, the description of proposed operations above, an equivalent level of safety will be provided. **e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil A ircraft Flight Manual in the**  **Ai rcraft**  14 C .F.R. § 91.9(b)(2) states: (b) No person may operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. 14 C.F.R. § 91.203(a) and (b) state: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cab in or cockpit entrance so that it is legible to passengers or crew. Given the small size and configuration of the Phantom 3 Advanced, it would be impossible to keep airworthiness documents and other aircraft manuals on board the UAS because there is simply no room. Also the UAS has no cabin or cockpit.

Equivalent Level of Safety In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b)and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight

manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved be ensuring that the pilot has access to the documents at the ground control station or point of control from which he or she is piloting the Phantom 3 Advanced. **f. 14 C.F.R. § 91.103: Preflight A ctions**  This regulation requires each pilot in command to take certain actions before flight to

ensure the safety of flight. As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed.

Equivalent Level of Safety An equivalent level of

safety will be provided through the PIC following the procedures set forth in the Gu ide and Manufacturer’s User Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. The PIC will account for all relevant site

- specific conditions in the preflight procedures. The FAA has granted exemption from this regulation to other small UAS operators. See Exemption No. 11109. **g. 14 C.F.R. § 91.109(a): Flight Instruction** Jacquelyn Lynaugh seeks an exemption from flight instruction requirements contained within 14 C.F.R. § 91.109(a). This section provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual cont rols.

Equivalent Safety Protocol For student training purposes the PIC and student may use a "buddy box" system that utilizes two transmitters when applicable. The transmitter of the student is connected by a trainer cable to another transmitter (master t ransmitter) controlled by the PIC instructor. The PIC Instructor is able to control the UAS with his or her transmitter then flip a switch to turn control

over to the student and flip the switch again to reclaim control. In this way, the PIC Instructor

can easily demonstrate how to fly the UAS or rescue the UAS if the student makes a poor aeronautical decision without passing the same transmitter back and forth to preserve safety to the NAS and manned aircraft operations. Given the size and speed of the UAS that the Jacquelyn Lynaugh intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required by the Guide, all persons will be a safe distance away in the event that any difficulties during flight instruction occurs. Moreover, Petitioner will conduct training in a controlled and sterile environment. As required by the Guide, training and instruction will be conducted in a sterile area on property that is owned and controlled by the Jacquelyn Lynaugh ncher . These facilities will not be open to the public during UAS operations, and access will be restricted to authorized business personnel involved with the company. **h. 14 C.F.R. § 91.119: Minimum Safe A lt**  **itudes** Jacquelyn Lynaugh requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating thehelicopter complies with any routes or altitudes specifically prescribed for helicopters by the

FAA." An exemption is required because the proposed UAS operations will occur at under 200 feet AGL. Further, while the Phantom 3 Advanced will never be flown in or over congested areas, due to the nature and location of the proposed operations, the PIC, Observer(s), Instructors and/or Students may at times be less than 200 feet away from the UAS.

Equivalent Safety Protocol Compared to flight operations with rotorcraft weighing far more than the maximum

we ights proposed herein, and given the lack of flammable fuel onboard the Phantom 3 Advanced, any risk associated with thes e operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the Phantom 3 Advanced, as well as the controlled and sterile location where the operat ions will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 200 feet AGL or below. As set forth in the Guide, the Phantom 3 Advanced flight height and radius restrictions will be set according to each operator’s level of experience which will be judged by the PIC. The Phantom 3 Advanced will be operated in an area that is owned by the client and closed to the public when in use. These restrictions will ensure that the proposed UAS operations are performed in a man ner that protects the safety of participants, nonparticipants, the UAS, and other property.

**i. 14 C.F.R. § 91.121: A ltimeter Settings**  This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the Phantom 2V does not have a barometric altimeter, but rather a GPS

a ltitude read out.

Equivalent Safety Protocol The Guide requires compass calibration prior to each operation of the Phantom 3 Advanced to ensure the GPS functions correctly. The Phantom 3 Advanced User Manuel contains instructions for achieving this and th e manufacturer, DJI, will provide additional support if necessary. **j. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** Jacquelyn Lynaugh requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Se ction 91.151 states: (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the fi rst point of intended landing, and assuming normal cruising speed

– i. During the day, to fly after that for at least 25 minutes; or ii. At night, to fly after that for at least 45 minutes. Here, the technological limitations on the energy capabilities of the 5200mAh LiPo battery used in the Phantom 3 Advanced means that no meaningful flight operations can be conducted with the Phantom 3 Advanced while still maintaining a 30 minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore requi red.

Equivalent Safety Protocol The batteries powering the Phantom 3 Advanced provide approximately 25 minutes of flight time. Training operations will be limited to a minimum voltage to ensure appropriate reserve battery to maintain an equivalent level of safety at all times. The UAS will notify theoperator when they are approaching and they are required to land at their home point and either

switch out the battery or pause operations for recharging. If both the operator and PIC fail to land the UAS prio r to the allotted minimum voltage, the UAS will autonomously return to its original launch position. **k. 14 C.F.R. §§ 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections** Jacquelyn Lynaugh seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R., sections 91.405, 91.407, 91.409, and 91.417. These rules specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See

, e.g. , 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected

as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as described in part 43 of this chapter.”) Exemption from these rules is requested because these sections of Title 14 require the aircraft to be maintained and inspected in accordance with Part 43, which only applies to aircraft with an airworthiness certificate. Therefore, based on the exemptions sought, these sections do not apply to Jacquelyn Lynaugh propose d UAS operations.

Equivalent Safety Protocol Ma intenance will be accomplished by authorized operators, staff, and/or contracted labor pursuant to the Guide and the Manufacturer’s User Manual. An equivalent level of safety will be achieved because a UAS like the Phantom 3 Advanced or like craft and its platform are very limited in size, will carry a small payload, and will operate only in defined areas for limited periods of time. If mechanical issues arise the Phantom 3 Advanced will be able to land imme diately on property owned by the client and or owner of the craft to receive immediate maintenance. As provided in the Guide and Manufacturer’s User Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform requi red maintenance, and will keep a log of any maintenance performed.

**l. 14 C.F.R. Part 61, 14 C.F.R. §§ 61.3, 61.113: Private Pilot Privileges and Limitations**  Jacquelyn Lynaugh will serve as the PIC for all flight operations and the instructor/coinstructor of any course including an element of drone flight. This should qualify persons with a private pilot’s certificate, among other qualifications, to instruct drone operation education when necessary. However, as is the nature of the proposed operations , introductory flight instruction using the Phantom 3 Advanced UAS will be provided to staff who will likely not have a private, or any type of, pilot’s license. Accordingly, Jacquelyn Lynaugh seeks exemption from 14 CFR Part 61, including 14 CFR § 61.3 to the extent that these regulations are interpreted as requiring a student receiving UAS operation instruction to have a private pilot's certificate. All student instruction flights will be conducted under closely controlled circumstances, outside of navigable ai rspace and away from persons or property not involved in the instruction

. In addition , the student instruction flights will be conducted under the close supervision of an instructor acting as PIC.

In addition , to the extent that Jacquelyn Lynaugh **may** be employing persons with a private pilot’s license to operate its UAS, an exemption is also sought from 14 C.F.R § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also require a second class medical certificate. The purpose of this section is to ensure the skill and competency of any PIC where the aircraft is carrying passengers or cargo for hire. In this case, while instructors acting as PIC during UAS operations will be doing so for ed ucational purposes as part of Jacquelyn Lynaugh staff, the Phantom 3 Advanced or like craft carries neither passengers nor cargo. Moreover, in the Astraeus Aerial Grant of Exemption The FAA determined that the unique characteristics of UAS operation outsid e of controlled airspacedid not warrant the additional cost and restrictions attendant with requiring the PIC to have a

Commercial Pilot Certificate and Class I or II Medical Certificate.

Equivalent Level of Safety Jacquelyn Lynaugh will ensure an equiva lent level of safety to the regulatory requirements of 14 C.F.R. Part 61, including 14 C.F.R. §§ 61.3 and 61.113 by following the safety procedures provided in the Guide. In addition to training and experience requirements and limitations, Jacquelyn Lynaugh has placed additional restrictions on its proposed UAS operations to ensure an extra margin of safety. The UAS will only operate in a controlled and sterile area away from persons and property not involved in the operation . It will be flown based o n VLOS at no more than 200 feet AGL. Collectively, these procedures ensure that the proposed UAS operations can be conducted safely.

**V. Public Interest** Because the technology to provide photographs that can better facilitate clients desires to market real estate for the purchase of real estate has advanced to a degree that is not possible from traditional photography the public will be well served by offering aerial photographs that

can better produce the desired results. Some of which include the depictio n of the beauty and aesthetics of a property for marketing purposes or the location of a property to surrounding adverse conditions that may affect the decision process of an institutional lender when making a loan for a particular property.

**VI. Privacy** All of Jacquelyn Lynaugh ’s UAS operations shall be conducted in accordance with applicable federal, state, or local laws regarding privacy. Jacquelyn Lynaugh will not conduct flight operations over property that it does not own or control without the prior consent and knowledge of the property owner. Moreover, Jacquelyn Lynaugh will not capture or use images from restricted areas requiring privacy and or confidentiality under any circumstance. This does not mean, however, that images may not be taken that a re permitted by law and do not require a level of privacy that is an exception to the norm.

**VII. Federal Register Summary** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER, should it be determined that publication is needed: Petitioner seeks an exemption from the following sections in Title 14 of the Code of Federal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.3; 61.113; 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners by (a) ensuring that the operations of the UAS described above are recognized by the FAA in the form of an exemption (b) how to safely operate small UAS in furtherance of career objectives and to the benefit of public safety while providing a valuable service as it relates to the real estate business provided by Jacquelyn Lynaugh

.

Thank you for your consideration

,

Jacquelyn Lynaugh