2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

RE: Petition of UAS for Exemption Pursuant to Section 333 of the FAA Reform Act (2012)

To Whom it May Concern:

Showcase Photography & Design Services LLC, (“Showcase”) is based in St. Lucie County, FL working in the 

real estate industry. It provides realtors, architects, builders, and homeowners with photography, marketing and 

design services. Showcase seeks to use UAS for the purpose of conducting aerial photography, videography, 

mapping and inspection services for the real estate industry.

The Company employs two partners, one of whom serves as primary camera operator and director of photography. The other Company’s Principal has expereince in sUAVs and has been certified by National Drone Schools, 

passing their final exam requireing Flying,Controlling, Maneuvering and FAA Rules & Regulations. The work 

generated will provide a major source of all income. 

The contact information for the Petitioner is as follows:

Abel Hernandez

2131 SW Janette Ave.

Port St. Lucie, Florida 34953

email: professionals@showcaseservice.com

web: www.ShowcaseService.com

phone: 772.202.8484

Showcase seeks an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Showcase Photography & Design Services LLC, (“Showcase”) operator of 

Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography and videography, hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 

of its sUASs, so long as such operations are conducted under tightly controlled conditions on private property 

where Showcase has received permission to operate from the landowner, controller or authorized representatives outlined herein or as may be established by the FAA as required by Section 333.

U.S. Department of Transportation, Docket Operation

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

January 20th, 2016
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

The requested exemption would permit Showcase the operation of small, unmanned and relatively inexpensive 

sUAS (XIRO Xplorer V) under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Showcase to conduct commercial operations of small 

unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety requirements set 

forth in Section 333. The requested exemption is to operate a Xiro Xplorer V aircraft, in order to provide services for profit to include aerial photography, aerial cinematography, aerial filming and photography for real estate, 

construction and architectural firms, agricultural modeling, crop monitoring operations, aerial mapping, special 

events to include but not limited to weddings, private or public parties/events, business advertising, promotional 

events, education and research, geological surveying, and environmental studies. 

By utilizing the UAV/UAS we can provide our clients with the point of view they’re looking for at a more reasonable price and in a safer method than using helicopters, larger aircrafts or by other means. Conventionally, 

using helicopters and fixed-wing aircraft in low level operations present very high risks with vehicles weighing 

thousands of pounds, carrying passengers and large amounts of fuel. It is important to note that the use of sUAV 

in this area will be safer and more cost effective. This UAV will be operated with extreme care and responsibility as we do with all of our production equipment.

The XIRO Xplorer V includes many built in safety functions and notifications to ensure safety before and during operation. For example, this UAS has a built-in safety feature that will not allow the UAV to function within 

3km (1.8 miles) range from airports and the flight height is restricted in areas from 3km (1.8 miles) to 7km (4.3 

miles), with the height maximum increasing with distance. There are also visual cues on the UAS and on the 

XIRO APP and sensory cues on the controller to notify when the battery level is low. At a critical state, the UAS 

is designed to land where it has taken off from using GPS. In addition to the built in safety features, a pre-flight 

safety inspection will be performed before each use and we will follow all UAS safety guidelines. Information 

of this drone can be found here: http://xirodrone.com/support

Specifications of the XIRO Xplorer V 

Dimensions: 14.8 x 13.9 x 6.4 inches 

Weight: 12.6 pounds 

Maximum Ascent Speed: 2m/sec (4.5 mph)*

Maximum Speed: 2m/sec (4.5 mph)*

Maximum Distance: 100m (328 ft)*

Maximum Height: 50m (164 ft)*

Battery: 5,200 mAh, 11.1V Lithium

Flight Time: @25 min

* These maximums are set in Primary Mode on the controller. This is the mode used in areial photography and 

videography. Other maxiums are set in other modes which will not be used.
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

Flights will not take place over densely populated areas or private property without the owners permission. The 

UAS will only be operated within visual line of sight, during daylight hours and correct weather conditions.

The specific sections of 14 C.F.R from which I am seeking exemption are as follows:

14 C.F.R. Part 21; Airworthiness Certification, 21, Subpart H Certification procedures for products and parts

14 C.F.R. 45.23(b); Display of marks; general.14 C.F.R. 61.101(e)(4), & (5); Recreational pilot privileges and 

limitations.

14 C.F.R. 61.113(a) & (b); Private pilot privileges and limitations: Pilot in command.

14 C.F.R. 61.133 (a); Commercial pilot privileges and limitations.

14 C.F.R. 61.23(a) & (c); Medical certificates: Requirement and duration.

14 C.F.R 91.7(a); Civil aircraft airworthiness.

14 C.F.R. 91.9(b)(2); Civil aircraft flight manual, marking, and placard requirements. 

14 C.F.R. 91.109(a); Flight instruction; Simulated instrument flight and certain flight tests. 

14 C.F.R. 91.103 (b)(2); Preflight action.

14 C.F.R. 91.119; Minimum safe altitudes: General. 

14 C.F.R. 91.121; Altimeter settings. 

14 C.F.R. 91.151(a); Fuel requirements for flight in VFR conditions. 

14 C.F.R. 91.203(a) & (b); Civil aircraft: Certifications required. 

14 C.F.R. 91.405(a); Maintenance required. 

14 C.F.R. 91.407(a)(1); Operation after maintenance, preventive maintenance, rebuilding, or alteration. 

14 C.F.R. 91.409(a)(2); Inspections. 

14 C.F.R. 91.417(a) & (b). Maintenance records. 

Showcase seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal Regulations (“14 C.F.R”) Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. 

Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating 

procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal 

to the rules from which exemption is sought.
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act 

that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the 

same application. These criteria are met, and therefore no exemption is needed. If, however, the FAA determines 

that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an 

exemption is requested.

Equivalent Level of Safety

Showcase’s use of the UAS is safe when taking into account their size, weight, speed, and operational capability. The XIRO weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess 

of 50 knots. It is also equipped with safety features that will allow the Petitioner to operate UAV safely after 

experience certain in-flight contingencies or failures.

14 C.F.R. Part 27 Airworthiness Standards: 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 that Company’s small UASs would otherwise require certification under Part 27, Petitioner 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,

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Showcase seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. 

§§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 

of this chapter.

● 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 two 

inches nor more than six 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.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted 

provided that the aircraft “have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable.”
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

Equivalent Level of Safety

All UA flown by Showcase will bear N-number markings that are as large as practicable in accordance with 14 

C.F.R. Part 45, Subpart C.

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

Showcase seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations 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 “shall have the aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter”). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Manufacturer’s Manual and safety checks will be performed regularly. Spare components and 

tools are on hand for any necessary repairs. Further, the PIC will conduct pre-flight inspections of the UAS. No 

flights will occur unless, and until, all flight critical components of the UAS have been found to be airworthy 

and in a condition safe for operation. A functional test flight will be conducted following the replacement of any 

flight-critical components.

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Showcase seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying 

aircraft for compensation or hire, and would also require a second class medical certificate. The purpose of Part 

61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for hire. In this case, 

while the UASs will be operated as part of a commercial operation, it carries neither passengers nor cargo.

Equivalent Level of Safety

Showcase will operate on private property away from persons and property not involved in the operation. Showcase has been in contact with local ATOs and can obtain an ATO issued COA prior to conducting any operations 

under this Grant of Exemption if needed. All operations will be conducted in accordance with airspace requirements.

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

Although there will be no airworthiness certificate issued for the UASs, Showcase seeks an exemption from 

14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has 

stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are 

waived or found inapplicable. Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in 

accordance with Section V (A).
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 03(a) and (b): Carrying 

Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness documents and 

other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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 UAVs, it would be impossible to keep airworthiness documents 

and other aircraft manuals on board the UAV because there is simply no room and the UAV has no cabin or 

cockpit.

Equivalent Level of Safety

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 by ensuring that the pilot has access to the documents at the ground control 

station from which he or she is piloting the UAV.

14 C.F.R. § 91.103: Preflight Action

Showcase seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific 

information before each flight, including information contained in the FAA-approved Flight Manual on board 

the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Manufacturer’s Manual. The PIC will perform 

a series of checklists designed to identify any defects or inoperable components. The PIC will also be required 

to review weather, flight requirements, battery charge, landing and takeoff distance, UAV performance data, and 

contingency landing areas—before initiation of flight. The Manufacturer’s Manual will be kept at the ground 

control station and will be accessible to the PIC at all times while operating the UAV.
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

14 C.F.R. § 91.109(a): Flight Instruction

Showcase seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part 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.” UASs and remotely piloted aircraft, by their design, do not have functional 

dual controls. Instead, flight control is accomplished through the use of a device that communicates with the 

aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UAV that Showcase intends to use, an equivalent level of safe training can still 

be performed without dual controls because no pilot or passengers are aboard the UAV. All persons will be a 

safe distance away in the event that the UAV experiences any difficulties during flight instruction.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Showcase requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c).15 

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 normally need to occur below 400 feet 

AGL. In circumstances where the UAV is used to inspect a structure whose height exceeds 400 feet AGL, the 

UAV will not be operated more than 100 feet above the highest point on the structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or Observers(s) 

may need to be less than 500 feet away from the UAV.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, 

and given the lack of flammable fuel with the UASs, 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 UASs, as well the controlled location where the operations will occur. In order to 

avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest point on that structure 

and 50 feet horizontally of the structure. Adherence to these restrictions will ensure operations can be conducted 

without compromising safety.
2131 SW Janette Ave. Port St. Lucie, Florida 34953

professionals@showcaseservice.com

www.ShowcaseService.com

772.222.7592

14 C.F.R. § 91.121: Altimeter Settings

Showcase 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 UASs do not have a barometric 

altimeter, but rather a GPS altitude read out.

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be achieved 

in circumstances where: (1) the UASs will be operated below 400 feet AGL or below17, (2) within VLOS, (3) 

where GPS based altitude information is relayed in real time to the operator at a ground-based on-screen display 

and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy 

of the onboard GPS. The XIRO UAV that Showcase intends to use for the proposed operations will meet all 

these operational characteristics. This will ensure that an equivalent level of safety will be achieved, and a Grant 

of Exemption to the requirements of § 191.121 is therefore appropriate.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Showcase requests an exemption from 14 C.F.R. § 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 –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be 

conducted 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 Level of Safety

The UAV includes a low battery warning system (lights will blink RED as a warning) and the amount of battery 

reserve power remaining is transmitted to the PIC, which downlinks from the UAV to a ground-based-on-screen 

display. Also, the controller has a sensory feature where it will provide the PIC with a low battery warning. The 

PIC will promptly fly the UAV back to the home launch location or pre-determined abort location where the 

UAV may safely land, while still maintaining a minimum of 25% reserve battery power.This procedure will 

ensure that the proposed operation will provide an equivalent or higher level of safety to that provided by the 

regulations from which exemption is sought.
2131 SW Janette Ave. Port St. Lucie, Florida 34953

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772.222.7592

The Public Interest will be served by granting Showcase’s Petition for Exemption. Showcase’s Petition for 

Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 2012 including weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within VLOS and national security. 

The proposed UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger. This Petition for Exemption provides the FAA with more than adequate 

justification for granting the requested exemptions allowing Showcase to provide it’s services and an addtional 

tool for the real estate industry.

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 rules in Title 14 of the Code of Federal Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103(b)(2); 91.109(a);

91.119(c); 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 from the substantial hazards associated with performing equivalent real estate aerial photography and inspection with conventional fixed-wing aircraft, rotorcraft, or other methods. 

Should you have any questions, or if you need any additional information to support the requested exemptions, 

please contact the undersigned.

We thank you for your prompt consideration of our requested exemptions.

Respectfully Submitted,

Abel Hernandez

Showcase Photography & Design Services

2131 SW Janette Ave.

Port St. Lucie, Florida 34953

email: professionals@showcaseservice.com

web: www.ShowcaseService.com

phone: 772.202.8484