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 Who m 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 ho m eowners with photography, m arketing and design services. Showcase seeks to use UAS for the purpose of conducting aerial photography, videography, m apping and inspection services for the real estate industry. The Co m pany e m ploys two partners, one of who m serves as pri m ary ca m era operator and director of photogra

phy. 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 F AA Rules & Regulations. The work generated will provide a m ajor source of all inco m e. The contact infor m ation for the Petitioner is as follows: Abel Hernandez 2131 SW Janette Ave. Port St. Lucie, Florida 34953 e m ail: 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 perm ission to operate fro m the landowner, controller or authorized representa

tives 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, 20162131 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) con

trolled. The proposed exe m ption, if granted, would allow Showcase to conduct co mm ercial operations of s m all 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 servic

es 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 li m ited to weddings, private or public parties/events, business advertising, pro m otional events, education and research, geological surveying, and environ m ental studies. By utilizing the UAV/UAS we can provide our clients with the point of view they’re looking for at a m ore rea sonable price and in a safer m ethod than using helicopters, larger aircrafts or by other m eans. 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 a m ounts of fuel. It is i m portant to note that the use of sUAV in this area will be safer and m ore cost effective. This UAV will be operated with extre m e care and responsibil

ity 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 dur

ing operation. For exa m ple, 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 m iles), with the height m axi m u m 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 perform ed before each use and we will follow all UAS safety guidelines. Inform ation of this drone can be found here: http://xirodrone.co m /support Specifications of the XIRO Xplorer V Di m ensions: 14.8 x 13.9 x 6.4 inches Weight : 12.6 pounds Maxi m u m Ascent Speed: 2 m /sec (4.5 m ph)* Maxi m u m Speed: 2 m /sec (4.5 m ph)* Maxi m u m Distance: 100 m (328 ft)* Maxi m u m Height: 50 m (164 ft)* Battery: 5,200 m Ah, 11.1V Lithiu m Flight Ti m e: @25 m in * These m axi m u m s are set in Pri m ary Mode on the controller. This is the m ode 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 per m ission. 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 li m itations. 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 Regula

tions (“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 fro m which exe m ption 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 sa m e application. These criteria are m et, and therefore no exe m ption is needed. If, however, the FAA deter m ines 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 capabil

ity. 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 UA V 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, Peti

tioner 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 “provi

sional,” 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, Sub

part C if the m arkings 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 exe m ption fro m 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 ac

cordance with the Manufacturer’s Manual and safety checks will be perfor m ed regularly. Spare co m ponents 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 co m petency of any PIC m atches the airspace in which the PIC will be operat

ing, 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 co mm ercial operation, it carries neither passengers nor cargo. Equivalent Level of Safety Showcase will operate on private property away fro m persons and property not involved in the operation. Show

case 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 require

m ents. 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 avail

able in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, mark

ings, and placards, or any co m bination 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 m anuals on board the UAV because there is si m ply no roo m 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 equiv

alent level of safety will be achieved by ensuring that the pilot has access to the docu m ents at the ground control station fro m 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 F AA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemp

tion 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 ti m es 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 re m otely 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 require

ments 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 perfor m ed 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 m ini m u m safe altitudes under which aircraft m ay 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 m ini m u m 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 F AA.” An exemption is required because the proposed UAS operations will normally need to occur below 400 feet AGL. In circu m stances where the UAV is used to inspect a structure whose height exceeds 400 feet AGL, the UAV will not be operated m ore than 100 feet above the highest point on the structure, and within 50 feet hori

zontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or Observers(s) m ay need to be less than 500 feet away fro m 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 inspect

ing 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 co m pro m ising 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 main

tain 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 alti m eter, 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 inform ation is relayed in real ti m e 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 (consider

ing wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assu m ing norm al 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 re m aining is trans m itted to the PIC, which downlinks fro m 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 m ay safely land, while still m aintaining a m ini m u m 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 fro m which exe m ption is sought.2131 SW Janette Ave. Port St. Lucie, Florida 34953 professionals@showcaseservice.com www.ShowcaseService.com 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 al

leviating 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 deter m ined 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 exe m ption will enhance safety by reducing risk to the general public and property owners fro m the substan

tial hazards associated with performing equivalent real estate aerial photography and inspection with conven

tional 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 e m ail: professionals@showcaseservice.com web: www.ShowcaseService.com phone: 772.202.8484