### To Whom It

### May Concern: I have filed a received an exemption earlierthis year. However, I nowhave a second UAS that I need an exemption for. I have updated my request with details ofthe new UAS and have also included mypreviously granted exemption. Thank you!



# ~ Rick Robinson

1'"•,U.S.Department ofTransportation Federal Aviation Administration

May 8, 2015

Mr. Richard Robinson Robinson Capital, LLC 21 06 East 1000 North Sugar City, ID 83448 Dear Mr. Robinson: Exemption No. 11511 800 Independence Ave

.. SW. Washington, D.C. 20591

Regulatory DocketNo. FAA-2015-0444

This letter is to inform you that we have granted your request for exemption. Ittransmits our decision, explains its basis, and gives you the conditions and limitations ofthe exemption, including the date it ends. By letter dated February 18, 2015, you petitioned the Federal Aviation Administration (FAA) on behalfofRobinson Capital, LLC (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct aerial photography and videography for real estate. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption. The FAA has determined that good cause exists for not publishing a summary ofthe petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner. 

### Airworthiness Certification The UAS proposed by the petitioner is a Dll Phantom 2 Vision+. The petitioner requested relieffrom 14 CFRpart 21, 

### Certificationprocedures forproducts andparts, Subpart H-Airworthiness Certificates. In accordance with the statutory criteriaprovided in Section 333 ofPublic Law 112-95 in reference to 49 U.S.C. § 44704, and in consideration ofthe size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary ofTransportation has determined that this aircraft meets the conditions ofSection 333. Therefore, the FAAfinds that the requested relieffrom 14 CFRpart 21, Certificationprocedures forproducts and parts, Subpart H-Airworthiness Certificates, and any associated noise certification and testing requirements ofpart 36, is not necessary. The Basis for Our Decision 2

You have requested to use a UAS for aerial data collection. The FAAhas issued grants of exemption in circumstances similar in alLmaterial respects to those presented in your petition. In Grants ofExemptionNos. 11062 to Astraeus Aerial (see DocketNo. FAA:-:2014-0352), 11109 to·Clayco, Inc. (see DocketNo. FAA-2014-:-0507), 11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see D.ocket No. FAA-2014-0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described 

### by the petitioner and carrying no passengers or crew, rather than a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that-.

• They are similar in all material respects to reliefpreviously requested in Grant of Exemption Nos. 11062, 11109, 11112, and l1213; • The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and • A grant ofexemption is in the public interest. Our Decision In consideration ofthe foregoing, I find that a grant ofexemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Robinson Capital, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 9L151(a)(1), 91.405(a), 91.407(a)(l), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below. Conditions and Limitations In this grant ofexemption, Robinson Capital, LLC is hereafter referred to as the operator.3 Failure to comply with any ofthe conditions and limitations ofthis grant ofexemption will be grounds for the immediate suspension or rescission ofthis exemption. 1. Operations authorized by this grant ofexemption are limited to the 

### Dll Phantom 2 Vision+ when weighing less than 55 pounds including payload. Proposed operations ofany otheraircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose ofclosed-set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (1 00 miles per.hour). the · exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater thanthe maximum 

## uA! operating airspeed recommended by the aircraft manufacturer. · · · · 4. The UA must be operated at an altitude

# orno· rtwre than 400 feet above ground level (AGL). Altitude must be reported in feetAGL. · 5. The UA must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective

**lenses~** as specifi'ed on the PIC's FAA-issued ahman medical certificate or U.S. driver's license. 6. All operations must utilize a visual observer (VO). The UA mustbe operated within the visual line ofsight (VLOS) ofthe PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the VO can perform the duties required ofthe VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. Theoperator must also present updated and revised documents ifit petitions for extension or amendment to this grant ofexemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator mustpetition for an amendment to its grant ofexemption. The FAA's UASIntegration Office (AFS-80) may be contacted ifquestions arise regarding updates orrevisions to the operating documents. 4

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation ot flight characteristics, e.g., replacement ofa flight critical component, must undergo a functional test flight prior to conducting further operations under·this exemption. Functional test flights may only be conducted by a PIC with aVO and must remain at least 500 feet from other people. The functional test flight must be conducted in such ·a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. ; 10. Prior to each flight, the PIC must conductapre-flight inspection and determinethe UAS is in a condition for safe flight.. The pre'-flight inspection mustaccount .for all potential discrepancies, e.g., inoperable components, items, or equipment. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS,the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer's maintenance; overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. · · 13. Under this grant ofexemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes oftraining the operator's PICs and VOs

### 5 (training, proficiency, and experience-building) artd determining the PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under theterms ofthis exemption. However, training operations may only be conducted during dedicated training sessions
.. During training, proficiency, and

**experience~building** flights, all persons. not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not·authorized. 16. The UA may not operate within 5 nautical miles ofan airp01i reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe aiuport symbol as.denoted on the current FAA-published aeronautical chart, unless a letter ofagreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter,ofagreement with the airport management must be made available to the Administrator,or any law enforcement official upon request. 17. The UA maynot be operated less than 500feet belowor less than 2,000 feet

· ·horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-detennined location within the private or controlled-access property. 19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind andforecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer ifgreater. 21. Air Traffic Organization (ATO) Certificate ofWaiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA ifit intends to conduct operations that cannot be conducted under the terms ofthe attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings must be as large as practicable.6 23. Documents used by the operator to ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made. available to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. AllFlight operations must be eonducted at least 500 feet from all nonparticipating persons, vessels, ·vehicles; and strucl:tlres unless:



### a. ·Barriers or structures are presentthatsufficiently protect nonparticipating persons from the UA and/ordebtis ih the event ofan accident.'The operator must ensure that nonparticipating persons remain under suchprbtection. If

## asituation arises
· where nonpartiCipating personsleave such protection and are within 500 feet of

the UA, flight operations must cea·se immediately ih a manner ensuring the safety ofnonparticipating persons; and · b. The owner/controller ofany vessels, vehicles or structures has granted permission

.for operating closer to those objects and the PIC has made a safety assessment of the risk ofoperating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or 'essential persons are not considered nonparticipating persons under this exemption. · 27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Ifthis exemption permits operations for the purpose ofclosed-set motion picture and television filming and production, the following additional conditions and limitations apply. 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant ofexemption.7 30. At least 3 days before aerial filming, the operator ofthe UAS affected by this exemption must submit a written Plan ofActivities to the local Flight Standards District Office (FSDO) withjurisdiction over the area ofproposed filming._ The 3-day

.notification may be waivedwith the. concurrence ofthe FSDO. The plan ofactivities must include at least the following:

a. Dates and times for all flights; b. Name and phone number

**ofth~** ope:t;ator for the UAS aerial filming conducted under this grant ofexemption; c. Name and phone number ofthe person responsible for the on-scene operation of the UAS; d. Make, model, and serial orN-Number ofUAS to be used; e. Name and certificate number ofUAS PICs involved in the aerial filming; f. A statement that the operator has. obtajned permission from property owners and/or local officials to condu9t

**th~.fj.lming,production** event; the list ofthose who gave permission must be. made

**~vaiJa"Qle** to the inspector upon request; g. Signature of.exemption hold.er 

## or reyres,entative; and h. A

**d~scription ofth~**  tJight activity, inqluqing maps or diagrams ofany area, city, town, county, &nd/or state

**overwhi~h** filming will be conducted and the altitudes essential to accomplish the operation. :

. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting.to be. involved and necessary forthe filming production, as specified in the exemption holder's MPTOM. Unless otherwise specified in this grant ofexemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on May 31, 2017, unless. sooner superseded or rescinded. Sincerely, /s/ John S. Duncan. Director, Flight Standards ServiceRichard Robinson Robinson Capital, LLC 2106 E 1000 N Sugar City, ID 83448 

### February 18th, 2015 U.S Department ofTransportation Docket Management System 1200New JerseyAve, SE Washington, DC 20590 

## .. . - •

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### ·

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### Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations from 14 C.F.R. §21, subpartH; 14 C.F.R 45.23(b};14 C.P.R.§§ 61.113( a) & 

### (b);91.7 (a); 91.9 (b) (2);91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & 

### (b) to operate commercially for buyer education purposes in Real Estate.
To Whom It May Concern: My name is Rick Robinson and I am submittingthis requestfor an exemption of section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & 

### (b);91.7 (a); 91.9 (o) 

### (2);91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & 

### (b) 

### Background Iworkinthe real estate industry and specialize in out-of-state buyers. In fact, 99% ofmy clients are out ofstate. When purchasing a piece ofproperty, especiallythe size ofthe properties that are purchased in Idaho, itis ofsignificantbenefitto use an UAS for aerial photography andvideographyto help the buyer make an informed decision aboutthepiece ofpropertybeingpurchased. This also includes the purchase ofhomes. Many out-of-state buyers see the benefit ofbeing able to see aerial photographs and video ofhigh eves, roofs, etc. to note their conditionbefore making an offer on a home. 

### Regardingthe UnmannedAircraftSystem The UAS Iwill be using is a small rotorcraftweighingless than 55 pounds with any and all payload. These UAS's operate at a speed no greaterthan 30 knots and can climb to an altitude no higher than 400ftAGL. It operates onlyinthe line ofmy sight as the sole operator and within a radius of300ft. It 

### does, however, have the capability ofa 1200ftradius ofoperation,butI have found, in myrecreational use, thatthe line ofsight is typically within 300ftofthe operator. These flight

# j I 

## 1 

## j



# I I EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

# I
restrictions ensure thatitis nota hazardto the airspace inwhich itwill be operated.· This UAS falls withinthe safety zone thatthe FAA will, with an exemption in place, allow commercial operation ofa UAS. TheparticularUAS thatwill be operatedis a DJI Phantom 2 Vistion+. The specific specifications are found onthe following pages:

Robinson Capital, LLC 

### I2106 E 1000 N 

### ISugar City, ID 83448 1208.360.46881 rick@theidahorealtor.com

### Aircraft

Gimbal

Camera

Remote Control EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

# I

Suppmied Battery DJI5200mAh LiPo Battery Weight (Battery & Propellers Included) 1242g Hover Accuracy (Ready To Fly) Vertical; 0.8m; Horizontal: 2.5m Max Yaw AngularVelocity 200°/s· · Max Tiltable Angle 35°· Max Ascent I Descent Speed Ascent: 6m/s; Descent: 2m/s Max Flight Speed 15m/s (Not Recommended) Diagonal Motor-Motor Distance 

### ssomm · · Working Current Static ;,750.mA; Dynamic : 900mA Contrql

**~ccuracy** ±0.0:? 0

, Controllabl.e Range Pitch :· -90°

**~** 

## oo

... Maximum Angular Speed Pitch : 90°/S Operating Environment Temperature ' 0°C-40°C

Sensor 'size 1/2.3" Effective Pixels 14 Megapixels Resolution 4384x3288 HD Recording 1080p30 & 720p Recording FOV 110°/85° Operating Frequency 5.728 GHz- 5.85 GHz Communication Distance (Open Area) CE Compliance: 400m; FCC Compliance: BOOm E,eceiver Sensitivity (1 %PER) -93dBm Transmitter Power CE Compliance: 25mW; FCC Compliance: 1OOmW Worldng Voltage 120 mA@3.7V

Robinson Capital, LLC 12106 E 1000 N 

### ISugar City, ID 834481 208.360.46881 rick@theidahorealtor.com

## j' I I 

### 4

Range Extender EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT

Built-In LiPo BatteryWorking Current/Capacity 3.7V, 2000mAh Operating Frequency 2412-2462MHz Communication Distance (Open Area) 500-700m TransmitterPower 20dBm · Power Consumption 2W


### Proceduresfor Flight

. . I , , .. 

### As an avid aviation enthusiast, I understandthe necessityfor safetywhenflying an airplane or an UAS. The procedures for flight are as follows (in no particular order): 1. With an observer, make a walk around the areathatis goingto befilmed or photographed bythe UAS. We will obsente the location oftrees, powerlines, or any other obstaclethatmayinterfere with the safe flight ofanUAS; 2. Ensure thatnothingwill preventa

**line~**

### of-sight operation during the flight. 3. Testbatteriesin UAS, remote controls, and range extenders. The only acceptable batterylevel will be above 75% beforetakeoff. The UAS will be grounded before the batterylevel (which is monitored remotely) reaches 25%. ' ' ' 4. Conduct a pre-flight checklist (see appendixA) 5. Review the plan for the flight with the observer. Review altitudes, distances, and movements ofthe UAS. 6. Ensure the PIC has license and medical onhand. 7. Establish a security perimeterfor observers. Care will also betaken to obtainthe consent ofall persons

**involv~d** 

### in the area and ensure a perimeter of 100ftis kept ofthe flight operationto maintain a sterile area. 8. The operatorwill file FAA Form 7711-1 or equivalent, with the appropriate Flight Standards District Office. 9. 3 days prior to the operation ofan UAS, the PIC will submita writtenplan of activities to the FSDO ifrequired; 10. PIC and observer will maintain communicationthroughoutthe entireflight. 11. Permission from homeowner, landowner, or otherproperty ownerwill be obtained prior to flight. 12. Permission from the local authorities will be obtainspriorto flight. 13. In the eventthe UAS loses signal, thebuiltin programmingwill force the UAS to returnto is location oftake off, and will safely land and power down. 14. Flights have the capability ofbeing aborted due to unpredicted obstacles or emergencies.

Robinson Capital, LLC 

### I 2106 E 1000 N 1Sugar City, ID 834481 208.360.46881 rick@theidahorealtor.comEXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

# I
Radio Frequency This particular UAS operates at a frequency of5.728GHz- 5.85 GHz. Itis compliant withthe FCC to 800m. The power ofthe radio falls withinthe FCC compliance of 100mW. · 

### Qualifications ofUAS PIC At all times, the PIC ofthe UAS will be an FAA certified Private Pilotwith a current 3rd 

### class medical. Because the UAS 

### will not carrypassengers and will fly within a restricted area, itwill exceed the safety standards setforth in 14 C.F.R 61.113 a &

### b. The PIC will also undergo trainingthatthe FAA will require to operate such UAS. The PIC will have over 100 hours offlighttime. The PIC 

### will also carryat all times a portable 2-wayradio for airtraffic monitoring and announcement ofthelocation of ·theUAS ifrequired bythe FAA. At

**~ll** 

### times therewill be an observerwho will also monitorthe UAS, surroundingbuildings or obstacles, observers, andwill be the second setofeyes to warn ofany dangers thatmayaffect the safe flight ofthe UAS. 

### Operations ofthe UnmannedAircraft As 

### stated earlier, the UAS will be a tool mostlyfor out ofstatereal estate clients to be able to view properties, view entire structures; andeducate them more fully before enteringinto a real estatetransaction. · The flights ofthe UAS will notpose a safetythreatwiththe properprocedures in place as mentioned in the section "Procedures for Flight." As described earlier, therewiU, at all times, be an observer, a safetyperimeter of 100 feet, batterylevels above 75% before flight, a full pre-fligrrt.checklist arid run-up, revieW ofthe flight plan, permission ofpropertyowners, written plan submittedto the FSDO if required, proper communication between PIC and observer, and pemnission from local authorities. Flights will onlybe conductedduring daylighthours. The UAS does nothave the capabilityto fly over 29.1577 knots and speeds will generallybe around 3-10 knots. The UAS will notbe operated ifclouds are at a level below 700ftAGL. This will ensurea safe distance from clouds and anylow-flying aircraft. The indented area ofoperationwill bein rural settings, as well as neighborhoods where homes are on lots over one-halfacre and have a distance of75-100 feet betweenhomes. It will notbe used in high-densityresidential settings as thatcould posetoo many safety concerns. Potential hazards in the intended area ofoperation aretrees, powerlines, structures, streetlights, and fences. Because ofthe slow flight ofthe UAS whenin operation for videography and photographyfor the intended purpose, the PIC and observerwill be able to safelymaneuver the UAS around the obstacles. The UAS also has capabilities ofhovering in place which allows itto be flown atverylow speeds. The intended cities and counties ofuse have small non-towered municipal airports. The UAS will neverbe flown near the airports so as to pose anysortofsafety

Robinson Capital, LLC 12106 E 1000 N 

### ISugar City, ID 83448 1208.360.4688 

### Irick@theidahorealtor.comi - 

### J. j EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

# I

concernto pilots in the area. The altitude ofthe UAS will barelybe above structures which should no pose anyconcernto piloted aircraftinthe area. Butfor added safety, a 2-wayradio to communicateto-air trafficwill always be on hand. This UAS will NEVER be flown within a S-mile radius ofanylarge international airport. The UAS has builtin restrictions that preventflight withinthose distances from an airport.

**Th~** builtinflight restrictions preventtakeoffin a

**S~mile** radius of-a large International airport such as LAX,

**S~C,**_etc. The UAS will also be preventedfrom taking offwithin .6 miles ofa smallerregional airport such as IDA Ifthe UAS is in flight and tries to fly into a no-fly zone, the UAS 

### will stop and returnback. Ifrequired be the FAA, Iwill notifythe FSDO ofmyflight operations priorto flight.

- 14CF.R. Part21, SubpartH,91.203{a) 

### & 

### (b) ,Airworthiness Certificate.· Becausethe UAS·is under 55lbs, fully loaded,, anq does notcarrya pilot, passenger,.. any e4plosiye materials orflammable fuel,

**op~rates** in a fullyrestricted and controlled environment, I requestexemption from 91.203 partA& 

### B. 14

**C~F.R.** 4-5.2.3 B MarkingtheAircraft The UAS.will not.have au airworthiness certificate and bec,ause there is no entrance to the cabin, cockpit, or pilot station, there isno place inside theaircraftto place the word "Experimental." Ifrequired bythe FAA, I will place theword "Experimental" on the exterior ofthe UAS. However, due tg the size, 2 inch letteringwill notbe

-
- possible. 14C.F.R. 61.113_A & B Private PilotPrivileges and Limitations: Pilotin Command Unlike civil aircraft, theUAS does not carrylivingthings onboard; rather, itis controlled remotelyvia a safe and restricted location. The risksduring operation are so minuscule thatthe PIC will exceed thepresentlevel ofsafetyrequired for a commercial pilotto operate a rotorcraftwith a commerciallicense. 14C.F.R. 91.9 B(2): Civil AircraftFlightManual in theAircraft Because ofthe size and configuration ofthe UAS, no such manual can be carried. The flight manual will be carried atthe ground stationwhere the PIC and observer are operatingthe UAS. 14C.F.R. 91.103 B(2): PreflightAction A thorough pre-flightinspection and run-up ofthe aircraftwill be performed prior to anyflight ofthe UAS. Please seethe appendix for the pre-flight checklist. 14C.F.R. 91.105: FlightCrewmembers atStation Becausethere are no souls onboard a UAS, regulation 91.105 should be exempt from mypurposes ofusing a UAS. However, crewmembers will be on the ground and in direct communication, namelythe PIC and Observer. 14C.F.R. 91.109: FlightInstruction

Robinson Capital, LLC 

### I2106 E 1000 N 

### ISugar City, ID 83448 1208.360.46881 rick@theldahorealtor.comEXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

# I
The UAS does nothave dual controls. The PIC communicates to the UAS via a radio control box. The FAA has approved exemptions for flight trainingwithoutfully functional dual controls for a number ofaircraft. 14 C.F.R. 91.119: Minimum Safe Altitudes The UAS will never operate atan altitude greaterthan 400ftAGL. Itwill be operated within a restricted area andwith the consent ofany and all persons or property • involved. 14C.F.R. 91.121Altimeter Settings The UAS thatwill beused does nothave an altimeter. Rather, ituses GPS to determine the altitude. Since the normal protocol is to setyour altimeter to the barometric pressure reading atthetime offlight an exemptionwill be needed. A safety checkwill be performed before each flight ensuringthatthe GPS altitude is reading correctly. · 14 C.F.R. 91.151: Fuel Requirements for FlightinVFR Conditions The batteryinthe DJI Phantom 2 Vision+ is capable of25 minutes ofpowered flight. Given thatthe UAS will never be further than 300ftawayand

**400ftAG~,** 

### the longest possible time it could take the UAS to returnto the ground safely

# is approximately 1.5 minutes. I categorize batterylife under 10 minutes as the danger zone. The UAS will automaticallyreturnto its pointoforigin and safely landwhenthebatterylife reaches 2 minutes. Batterylife as well as flight-time remaining is displayed onthe screen visible to the PIC and observer. For safe flight, Iwill never fly the UAS with under 10 minutes of batterylife. · 14C.F.R. 91.203 A & 

### B: Carrying Civil Aircraft Certification and Registration The UAS weighs under 55 pounds and does nothave an on-boardpilot operatingit. The UAS is not capable ofcarrying such documents should theybe required. These documents, ifrequired bythe FAA, will be carried bythe PIC and will be accessible upon request immediately. 14C.F.R. 91.405A; 407A(1); 409A (2); 417A & 

### B: Maintenance Inspections This regulation applies to aircraftthathave an airworthiness certificate and should not applyto the operation ofmyintended use for the UAS. However, regular maintenance, checks, and cleaning ofthe UAS will be performed before each flight and ifrequired bythe FAA, can be logged into a log bookand surrendered upon request. Regular maintenance will include cleaning ofthe 4 motors on the UAS Rotorcraft, motortesting, flight control testing, checkinglights, and a cleaning ofthe entire UAS. Should a mechanical issue arise during a flight, the UAS will land immediately and should notpose a safety concernbecause ofits lightweight, restricted flying area, and low and slow maneuvering. General Summary

Robinson Capital, LLC 12106 E 1000 N 

### ISugar City, ID 834481 208.360.46881 rick@theldahorealtor.comEXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

### I feel thatmyoperation oftheUAS will meet and exceed all current safety standards setforth bythe FAA. Iam seekingexemptionfrom the following rules: 14 C.F.R. §21, subpartH; 14C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & 

### (b);91.7 (a); 91.9 (b) (2);91.103(b); 91.105; 91.109; 91.119; 91.;1.21; 91.151(a);91.203(a) and (b); 91.405 (a); 91.40.7 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & 

### (b) to operate commerciallyfor buyereducation purposes in Real Estate. Approval ofthis exemption will ensure safe flight operations for myUAS following the strictguidelines setforth in the request. Should you have ;;my questions or needtocontactme, myinformation is: Richard Robinson Robinson Capital, LLC 2106 E 1000 N Sugar City, ID 83448 ·. 208-360-4688 rick@theidahorealtor.com. rickrobnson@gmail.com .,: 

### I feel thatthe



### crite~ia for .exemption in Section 333 ofthe Reform Act of2012 (namely size, weight, speed, operating capabilities, proximityto airports and populatedareas and operation withinvisu,al line ofsight and national security) have been satisfied and adequatejustification has beenprovided for this exemption. I appreciateyour time and consideration in this matter.

Robinson Capital, LLC 12106 E 1000 N ISugar City, ID 83448 [208.360.4688 Irick@theidahorealtor.com,;ISSUED TO Robinson Capital, LLC 2106 E 1000 North Sugar City, ID 83448 FAA FORM 7711-1 UAS COA Attachment FAA-2015-0444 DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION CERTIFICATE OFWAIVER ORAUTHORIZATION Page 1 of 6

This certificate is issued for the operations specifically described hereinafter. No person shall conduct any operation pursuant to the authority ofthis certificate except in accordance with the standard and special provisions contained in this certificate, and such other requirements ofthe Federal Aviation Regulations not specifically waived by this certificate. OPERATIONS AUTHORIZED Operation ofDJI Phantom 2 Vision+ Unmanned Aircraft Systems at or below 200 feet Above Ground Level (AGL) for the purpose ofaerial data collection. LIST OF WAIVED REGULATIONS BY SECTION AND TITLE NIA STANDARD PROVISIONS 

### 1. A copy ofthe application made for this certificate shall be attached and become a part hereof. 2. This certificate shall be presented for inspection upon the request ofany authorized representative ofthe Federal Aviation Administration, or of any State or municipal official charged with the duty of enforcing local laws or regulations. 3. The holder ofthis certificate shall be responsible for the strict observance ofthe terms and provisions contained herein. 4. This certificate is nontransferable. Note-This certificate constitutes a waiver ofthose Federal rules or regulations specifically referred to above. It does not constitute a waiver ofany State law or local ordinance. SPECIAL PROVISIONS Special Provisions are set forth and attached. This certificate FAA-2015-0444-333E is effective from May 18, 2015 to May 31, 2017 and is subject to cancellation at any time upon notice by the Administrator or his/her authorized representative. BY DIRECTION OF THE ADMINISTRATOR

FAA Headguarters, AJV-115 (Region) May 13,2015 (Date) FAA Form 7711-1 (7-74) /S/ Jacgueline R. Jackson (Signature) Manager, UAS Tactical OQerations Section (Title)

Small UAS Operations 200 feet and below for Commercial Purposes March 2015FAA FORM 7711-1 UAS COA Attachment FAA-2015-0444 

### STANDARD PROVISIONS A. General. Page 2 of 6

1. The approval ofthis COA is effective only with an approved FAA Grant ofExemption. 2. A copy ofthe COA including the special limitations must be immediately available to all operational personnel at each operating location whenever UAS operations are being conducted. 3. This authorization may be canceled atany time by the Administrator, the person authorized to grant the authorization, orthe representative designated to monitor a specific operation. As a general 

### rule, this authorization may be canceled when it is no longer required, there is an abuse ofits provisions, or when unforeseen safety factors develop. Failure to comply with the, authorization is cause for cancellation. The operator will receive written notice ofcancellation. B. 

### Safety of

**Fl~ght.** 1. The operator orpilot in command (PIC).is responsible for halting or canceling activity in the COA area if, at any time, the safety ofpersons orproperty on the ground or in the air is injeopardy, or ifthere is a failure to comply with the terms or conditions ofthis authorization. · · 

### See-and-Avoid Unmanned aircraft have no

**on~board** pilot to perform see-and-avoid responsibilities; therefore, when operating outside ofactive restricted and warning areas approved for aviation activities, provisions must be made to ensure an equivalent level ofsafety exists for unmanned operations consistent with 14 CFR Part 91 §91.111, §91

### J 13 and §91.115.
a. The pilot in command (PIC) is responsible:
• To remain clear and give way to all manned aviation operations and activities at all times,
• For the safety ofpersons or property on the surface with respect to the UAS, and • For compliance with CFR Parts 91.111, 91.113 and 91.115
b. UAS pilots will ensure there is a safe operating distance between aviation activities and unmanned aircraft (UA) at all times.
c. Visual observers must be used at all times and maintain instantaneous communication with the PIC. d. The PIC is responsible to ensure visual observer(s) are: Small UAS Operations 200 feet and below for Commercial Purposes March 2015FAA FORM 7711-1 UAS GOA Attachment FAA-2015-0444 Page 3 of 6

• Able to see the UA and the surrounding airspace throughout the entire flight, and • Able to provide the PIC with the UA's flight path, and proximity to all aviation activities and other hazards (e.g., terrain, weather, structures) sufficiently for the PIC to exercise effective control ofthe UA to prevent the UA from creating a collision hazard.
e. Visualobserver(s) must be able to communicate clearly to the pilot any instructions required to remain clear ofconflicting traffic. 2. Pilots are reminded to follow all



### feder~l regulations e.g. remain clear ofail Temporary Flight Restrictions, as well as following the exemption granted for their operation.

< • ' ' • 3. The operator or delegated representative



### ~4st notoperate in Prohibited Areas, Special Flight Rule Areas or, the Washington National Capital Region Flight Restricted Zone. Such areas are depicted on chmis available at http://www.faa.gov/air traffic/flight info/aeronav/. Additionally, aircraft operators should beware ofand avoid other areas identified in Notices to Airmen (NOTAMS) which restricts operations in proximity to Power Plants, Electric Substations, Dams, Wind Farms, Oil Refineries, fudustrial



### CompL~xes, National Parks, The Disney Resorts, Stadiums, Emergency Services, the Washington DC Metro Flight Restricted Zone, Military or other Federal Facilities. 4. All aircraft operated in accordance with this Certificate ofWaiver/Authorization must be identified by serial number, registered in accordance with 14 CPRpart 47, and have identification (N-Number) markings in accordance with 14 CPRpart 45, Subpart

### C. Markings must be) as large as practicable. 

### C. Reporting Requirements 1. Documentation ofall operations associated with UAS activities is required regardless of the airspace in which the UAS operates. NOTE: Negative (zero flights) reports are required. 2. The operator must submit the following information through



### mailto:9-AJV-115-UASOrganizati~n@faa.gov on a monthly basis: a. Name ofOperator, Exemption number and Aircraft registration number b. UAS type and model c. All operating locations, to include location city/name and latitude/longitude d. Number offlights (per location, per aircraft) e. Total aircraft operational hours f. Takeoffor Landing damage

Small UAS Operations 200 feet and below for Commercial Purposes March 20 15FAA FORM 7711-1 UAS COA Attachment FAA-2015-0444 Page 4 of 6
g. Equipment malfunctions. Reportable malfunctions include, but are not limited to the following: (1) On-board flight control system (2) Navigation system (3) Powerplant failure in flight (4) Fuel system failure (5) Electrical system failure (6) Control station failure 3. The number and duration oflost link events (control, performance and health monitoring, or communications) per UA per flight. 

### D. Notice to Airmen (NOTAM). A distant (D) NOTAM must be



### iss~ed when unmanned aircraft operations are being conducted. This requirement maybeaccomplished:
a. Through the operator's local base operations orNOT AM issuing authority, or b. By contacting the NOTAM Flight Servi<;e Station at 1:-877-4-US-NTMS (1-877-487- 6867) not more than 72 hours in advance, but not less than 24 hours prior to the operation, unless

**otherwi~e** authorized as a special- provision. The issuing agency will require the: (1) Name and address ofthe pilot filing the NOT AM request (2).Location, altitude, or operating area (3) Time and nature ofthe activity.


### AIR TRAFFIC CONTROL SPECIAL PROVISIONS

A. Coordination Requirements. 1. Operator filing and the issuance ofrequired distance (D) NOT AM, will serve as advance ATC facility notification ofUAS operations in an area. 2. Operator must cancel NOTAMs when UAS operations are completed or will not be conducted. 3. Coordination and deconfliction between Military Training Routes (MTRs) is the operator's responsibility. When identifying an operational area the operator must evaluate whether an MTRwill be affected. In the event the UAS operational area overlaps (5 miles either side ofcenterline) an MTR, the operator will contact the scheduling agency 24 hours in advance to coordinate and deconflict. Approval from the scheduling agency is not required. Scheduling agencies are listed in the Area Planning AP/lB Military Planning Routes North and South America, ifunable to gain Small UAS Operations 200 feet and below for Commercial Purposes March 2015

# .. FAA FORM 7711-1 UAS COA Attachment FAA-2015-0444 Page 5 of 6

access to AP11B contact the FAA at email address mailto:9-AN-115-UASOrganization@faa.gov with the IRIVR routes affected and the FAA will provide the scheduling agency information. Ifprior coordination and deconfliction does not take place 24 hours in advance, the operator must remain clear ofall MTRs. B. 

### Communication Requirements. 1. When operating in the vicinity ofan airport without an operating control tower, announce your operations in accordance with the FAA Aeronautical Information Manual (AIM) 4-1-9 Traffic Advisory Practices at Airports without Operating Control Towers. 

### C. Flight Planning Requirements. This COA will allow small UAS (55 pounds or less) operations during daytime VFR conditions under the following conditions and .limitations:

(1) At or below 200 feet AGL; and (2) Beyond

**th~** following distances from the airport referencepoint (ARP) ofa public use airport, heliport, gliderport, or

**~eaport** listed in the Airport/Facility Directory, Alaska Supplement, or Pacific Chart Supplement ofthe U.S. Government Flight Information Publications. a) 5 nautical miles (NM) from an airport having an operational control tower; or b) 3 NM from an airpmi having a published instrument flight procedure, but not having an operational control tower; or c) 2 NM from an airport not having a published instrument flight procedure or an operational control tower; or d) 2 NM from a heliport, gliderport or seaport 

### D. Emergency/Contingency Procedures. 1. Lost Link/Lost Communications Procedures:

• Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled-access property and land.

• The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 2. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries defined in this COA must be reported to the FAA via email at Small UAS Operations 200 feet and below for .Commercial Purposes March 2015FAA FORM 7711-1 UAS COA Attachment FAA-2015-0444 Page 6 of 6 mailto:9-AJV-115-UASOrganization(a),faa.gov within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov 

### AUTHORIZATION This Certificate ofWaiver or Authorization does not, in itself, waive any Title 14 Code of Federal Regulations, nor any state law or local ordinance. Should the proposed operation conflict with any state law or local ordinance, or require permission oflocal authorities or property owners, it is the responsibility ofthe operator to resolve the matter., This COA does not authorize flight within Special Use airspace without approval from the scheduling agency., The operator is hereby authorized to operate the small Unmanned Aircraft System in the National Airspace System.
' :

\_ ':. \

Small UAS Operations 200 feet and below for Commercial Purposes March 2015