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 Jacquelyn Lynaugh for Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

Following the format of FAA Exemption includes:

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.

TABLE OF CONTENTS

I. Description of Petitioner

II. Description of Proposed Operation

III. Jacquelyn Lynaugh Proposed UAS Operations Meet the Requirements of Section 333

a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational

Capability

b. Approval is Warranted 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 Altitudes
i. 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 Limitations

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.

*Jacquelyn Lynaugh is an independent contractor working as a licensed North Carolina

Real Estate Broker. Services include real estate consultation and sales. I have completed 

the NC State Division of Aviation Unmanned Aircraft Systems (UAS) Operators 

Knowledge Test and the NC Transportation UAS Commercial Operator Permit from the 

Division of Aviation Permit No: C0000092, and sponsored by Michael John Lynaugh

which is a commercial helicopter pilot Certificated Airman'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 for 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 the Pilot in Command (“PIC”) for each operation will, at 

a minimum, be Jacquelyn Lynaugh. Jacquelyn Lynaugh has 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 

the standards specified in the Guide, as well as any other additional requirement the FAA 

requires under this application.

III. Proposed UAS 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. Approval is Warranted Based on the UAS’s Size, Weight, Speed, 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 they 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 height 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. Approval is Warranted Based on the Operational Restrictions Set Forth in

the UAS 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 assessment of Jacquelyn 

Lynaugh’s proposed operations, below is a summary of operational limitations and conditions 

which 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 operated 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 conditions.

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 defined

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: Airworthiness 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 

equivalent 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 for the area of operation. In all cases, the UAS operated 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 times in visual line-of-sight and in VFR conditions. Id.

b. 14 C.F.R. Part 27: Airworthiness 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 for 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 Aircraft

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), Markings of the Aircraft, states:

When 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 also 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. The 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. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

.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 Aircraft Flight Manual in the

Aircraft

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 cabin 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 Actions

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 Guide 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 controls.

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 transmitter) 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 Altitudes

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 the 
helicopter 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

weights proposed herein, and given the lack of flammable fuel onboard the Phantom 3

Advanced, any risk associated with these 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

operations 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 manner that protects the safety of participants,

nonparticipants, the UAS, and other property.

i. 14 C.F.R. § 91.121: Altimeter 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 

altitude 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 the 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. Section 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

first 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 required.

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 the
operator 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 prior 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

proposed UAS operations.

Equivalent Safety Protocol

Maintenance 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

immediately 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 required 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 

airspace 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 

educational 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 outside of controlled airspace 
did 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 equivalent 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 on 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 depiction 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 are 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