July 17, 2015

Federal Aviation Administration (FAA) U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12 - 140 Washington, DC 20590 RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT Dear Sir or Ma’am: This petition is being submitted on our behalf without legal counsel or counseling services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Helena Real Estate Solut ions, INC (HRES, INC), a full service independent real estate business, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft Systems (sUAS) commercially in airspace regu lated by the FAA so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit HRES, INC to pursue its commercial interests in providing aerial data capture to clients using a small advanced sUAV in the following areas:

- Real Estate

- Marketing

- Mapping

- Surveying

- Special Events

- Agriculture

- Inspection

- General Photography Regulations from which exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. 91.401 – 91.417I, Tobie L. McDonnell, am a licensed Real Estate Broker/Supervisor . I have been flying sUAV’s for over a

year. My most recent experience is with a DJI Phantom 3 Professional. I have been flying as a hobbyist and now ready to bring my skills to a professional leve l. In doing so, I consider all safety precautions and regulations as foremost with each flight. My request to operate commercially is primarily to record digital video data and other aerial photography data for privately owned fee simple real estate whic h will assist in the promotion and marketing of their real estate for ultimate disposition and sale. Montana is a sparse and remote mountainous environment with spread -out parcels of residential, ranch, and farming communities. These properties cannot eas ily be accessed by foot and providing an aerial view of all boundaries and topography of the land would prove to be highly desired and essential when negotiating buying/selling transactions on properties often exceeding millions of dollars. Arial cinematog raphy in the housing market has been around for a long time through manned fixed wing aircraft and helicopters. For a small budget real estate company and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies a nd high end Realtors or luxury homeowners can afford such expense. Depriving non - luxury homeowners and lower budget Realtors from a valuable marketing tool. Also, using my sUAV service avoids the high risks in a helicopter and/or fixed wing aircraft with fuel and persons on board. The reduced noise and size creates a much smaller environmental impact which promotes public and environmental safety. I, Tobie L. McDonnell, will act as HRES, INC Pilot in Charge (PIC). My Observer will be a retired United Sta tes Navy Weather Forecaster. The Observer is intimately familiar with FAA flight rules and regulations as he has briefed thousands of pilots over the course of 20 years in safest flight paths (altitude and routes) , communication protocol with Air Traffic Control, emergency flight procedure’s, and of course weather along a given route which met the minimum established FAA regulations for safety to flight. He also launched hundreds of weather balloons in restricted and unrestricted air space working closely w ith air traffic control with timing of release, ascension time, flight path (trajectory) of the balloon, and safety protocol for possible early termination of flight potentially resulting in descent over populated areas. The observer will eventually progre ss to PIC after 20 hours of simulated flight time with the DJI Phantom 3 Professional, 20 hours of actual flight time while supervised in a controlled environment and 5 hours of supervised flight time in the field. To make sure the operation will be safe ly conducted, the PIC and observer will survey the flight area for any mobile phone base stations, radio transmission towers, power lines, or any other electromagnetic interference that could disrupt flight. The PIC and observer will scan the area for any large buildings or trees that may affect with GPS accuracy or flight. Both PIC and Observer will verify the weather is safe for flight to avoid wind speed exceeding 10 m/s, snowfall, rainfall, and restricted environmental visibility . Additionally, the PIC and Observer will go through the PREFILGHT CHECKLIST/maintenance and FLIGHT TEST PROCEEDURES in a secure area safe from persons and property. The DJI Phantom 3 Professional is equipped with a built - in stabilized HD camera and GPS safety features. These s afety features include the ability to restrict the maximum altitude they operate above ground level (AGL), to limit the radial distance from the operator and to exclude them from operations within designated Class B, C and D airspace including “no -fly zone s”. This model has a failsafe function that is automatically engaged in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safely . If the connection is restored, the PIC can regain control of flight and land manually.These specifications meet or exceed the Model Aircraft Operating Standards as set below:

- The petitioner will only operate its sUAS in line -of- sight of a PIC and/or Observer and will opera te at sites that are “sufficient distance” from populated areas within the sterile area described in the FOPM. Such operations will ensure the sUAS will “not create a hazard to users of the national airspace system or the public.”

- When flying the sUAS within three (3) miles of an airport, airport operators will be notified and the operator will give the right - of-way to avoid flying in the proximity of full -scale aircraft.

- Maximum flight time for each operation will be 30 minutes.

- Flights will be termi nated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS.

- The sUAS will be pre - programmed so it will not be operated at an altitude that will exceed 200 feet AGL, and not more than 100 feet above an elevated pla tform from which videography is planned.

- Minimum crew for each operation shall consist of: sUAS PIC and a visual Observer.

- The sUAS operated by the Petitioner weighs less than 25 pounds, including all payload.

- The sUAS will operate at speeds not to excee d 50 knots, can hover and can simultaneously move vertically and horizontally.

- Given the small size of the sUAS and the restricted sterile environment within which it will operate, Helena Real Estate solutions, INC operations adhere to the reform Act’s sa fety requirements. We respectfully request exemption under Section 333 to enable Helena Real Estate Solutions, INC (HRES, INC) to operate efficient, limited, low- risk commercial sUAS operations for the activities stated respecting at all times the space and privacy of citizens and property while keeping airspace safe.
Respectfully, //s// Tobie L. McDonnell Helena Real Estate Solutions, INC 1169 East Riggs St. East Helena, Montana 59635