To Whom It May Concern: 

I have filed a received an exemption earlier this year. However, I now have a second 

UAS that I need an exemption for. I have updated my request with details of the new 

UAS and have also included my previously granted exemption. Thank you! 

~ Rick Robinson 

1'"•, 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

May 8, 2015 

Mr. Richard Robinson 

Robinson Capital, LLC 

21 06 East 1 000 North 

Sugar City, ID 83448 

Dear Mr. Robinson: 

Exemption No. 11511 

800 Independence Ave .. SW. 

Washington, D.C. 20591 

Regulatory Docket No. FAA-2015-0444 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter dated February 18, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Robinson 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 of the 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 relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H-Airworthiness Certificates. In accordance with the statutory criteria 
provided in Section 333 of Public Law 112-95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 3 3 3. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H-Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

2 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in alL material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA:-:2014-0352), 

11109 to·Clayco, Inc. (see Docket No. FAA-2014-:-0507), 11112 to VDOS Global, LLC (see 

Docket No. F AA-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 of significantly 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 relief previously 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 of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption 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 of exemption, Robinson Capital, LLC is hereafter referred to as the operator. 
3 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the Dll Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-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 than the maximum uA! operating airspeed recommended by the 

aircraft manufacturer. · · · · 

4. The UA must be operated at an altitude or no· rtwre than 400 feet above ground level 

(AGL). Altitude must be reported in feetAGL. · 

5. The UA must be operated within visual line of sight (VLOS) of the 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 must be operated within 

the visual line of sight (VLOS) of the 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 of the flight. The PIC must ensure that the VO can perform the duties 

required of the 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. If a 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. The 
operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA's 

UAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions 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 of a 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 conducta pre-flight inspection and determine the 

U AS is in a condition for safe flight.. The pre'-flight inspection must account .for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

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 of exemption, 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 of Columbia, 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 of training 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 of this 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 of an airp01i reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the aiuport symbol as.denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement 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 may not be operated less than 500 feet below or less than 2,000 feet 

· ·horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the 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 and forecast 

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 if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 4 7, and have identification 

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable. 
6 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the 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. All Flight operations must be eonducted at least 500 feet from all nonparticipating 

persons, vessels, ·vehicles; and strucl:tlres unless: 

a. ·Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/ordebtis ih the event of an accident.' The operator must ensure 

that nonparticipating persons remain under such prbtection. If a situation arises 

· where nonpartiCipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cea·se immediately ih a manner ensuring the safety 

of nonparticipating persons; and · 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

. for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating 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 of the 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. 

If this exemption permits operations for the purpose of closed-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 of exemption. 
7 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming._ The 3-day 

. notification may be waived with the. concurrence of the FSDO. The plan of activities 

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 of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N-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 of those 

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 of any 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 for the filming production, as specified in the 

exemption holder's MPTOM. 

Unless otherwise specified in this grant of exemption, 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 Service 
Richard Robinson 

Robinson Capital, LLC 

2106 E 1000 N 

Sugar City, ID 83448 

February 18th, 2015 

U.S Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

.. . - • '-~ ·. ··: : : ·. :• .• = : ; . 

. ::.: . :·,_ :.: .. ' '·;~ ... 

. · .. .· . : .. . '• ~ 

.. , .. -· . ".; ·.>·. f'~ ... 1, . ~- ~i ·. t / 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 ofthe 

Federal Aviation Regulations from 14 C.F.R. §21, subpart H; 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 submitting this request for an exemption of 

section 333 of the FAA Reform Act and Part 11 of the 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 

I work in the real estate industry and specialize in out-of-state buyers. In fact, 99% 

of my clients are out of state. When purchasing a piece of property, especially the 

size of the properties that are purchased in Idaho, it is of significant benefit to use an 

UAS for aerial photography and videography to help the buyer make an informed 

decision about the piece of property being purchased. This also includes the 

purchase of homes. Many out-of-state buyers see the benefit of being able to see 

aerial photographs and video of high eves, roofs, etc. to note their condition before 

making an offer on a home. 

Regarding the Unmanned Aircraft System 

The UAS I will be using is a small rotorcraft weighing less than 55 pounds with any 

and all payload. These UAS's operate at a speed no greater than 30 knots and can 

climb to an altitude no higher than 400ft AGL. It operates only in the line of my sight 

as the sole operator and within a radius of 300ft. It does, however, have the 

capability of a 1200ft radius of operation, but I have found, in my recreational use, 

that the line of sight is typically within 300ft of the operator. These flight 
j 

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EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT I 

restrictions ensure that it is not a hazard to the airspace in which it will be operated.· 

This UAS falls within the safety zone that the FAA will, with an exemption in place, 

allow commercial operation of a UAS. 

The particular UAS that will be operated is a DJI Phantom 2 Vistion+. The specific 

specifications are found on the following pages: 

Robinson Capital, LLC I 2106 E 1000 N I Sugar 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 Angular Velocity 

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 

1 080p30 & 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: 1 OOmW 

Worldng Voltage 

120 mA@3.7V 

Robinson Capital, LLC 12106 E 1000 N I Sugar City, ID 834481 208.360.46881 rick@theidahorealtor.com 
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Range Extender 

EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

Built-In LiPo Battery Working Current/Capacity 

3.7V, 2000mAh 

Operating Frequency 

2412-2462MHz 

Communication Distance (Open Area) 

500-700m 

Transmitter Power 

20dBm · 

Power Consumption 

2W 

Procedures for Flight . . I , , .. 

As an avid aviation enthusiast, I understand the necessity for safety when flying 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 area that is going to be filmed or 

photographed by the UAS. We will obsente the location of trees, power lines, 

or any other obstacle that may interfere with the safe flight of an UAS; 

2. Ensure that nothing will prevent a line~ of-sight operation during the flight. 

3. Test batteries in UAS, remote controls, and range extenders. The only 

acceptable battery level will be above 75% before takeoff. The UAS will be 

grounded before the battery level (which is monitored remotely) reaches 

25%. ' ' ' 

4. Conduct a pre-flight checklist (see appendix A) 

5. Review the plan for the flight with the observer. Review altitudes, distances, 

and movements of the UAS. 

6. Ensure the PIC has license and medical on hand. 

7. Establish a security perimeter for observers. Care will also be taken to 

obtain the consent of all persons involv~d in the area and ensure a perimeter 

of 100ft is kept of the flight operation to maintain a sterile area. 

8. The operator will file FAA Form 7711-1 or equivalent, with the appropriate 

Flight Standards District Office. 

9. 3 days prior to the operation of an UAS, the PIC will submit a written plan of 

activities to the FSDO if required; 

10. PIC and observer will maintain communication throughout the entire flight. 

11. Permission from homeowner, landowner, or other property owner will be 

obtained prior to flight. 

12. Permission from the local authorities will be obtains prior to flight. 

13. In the event the UAS loses signal, the built in programming will force the UAS 

to return to is location of take off, and will safely land and power down. 

14. Flights have the capability of being aborted due to unpredicted obstacles or 

emergencies. 

Robinson Capital, LLC I 2106 E 1000 N 1 Sugar City, ID 834481 208.360.46881 rick@theidahorealtor.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT I 

Radio Frequency 

This particular UAS operates at a frequency of 5.728GHz- 5.85 GHz. It is compliant 

with the FCC to 800m. The power of the radio falls within the FCC compliance of 

100mW. · 

Qualifications ofUAS PIC 

At all times, the PIC of the UAS will be an FAA certified Private Pilot with a current 

3rd class medical. Because the UAS will not carry passengers and will fly within a 

restricted area, it will exceed the safety standards set forth in 14 C.F.R 61.113 a & b. 

The PIC will also undergo training that the FAA will require to operate such UAS. 

The PIC will have over 100 hours of flighttime. The PIC will also carry at all times a 

portable 2-way radio for air traffic monitoring and announcement of the location of 

·the UAS if required by the FAA. At ~ll times there will be an observer who will also 

monitor the UAS, surrounding buildings or obstacles, observers, and will be the 

second set of eyes to warn of any dangers that may affect the safe flight of the UAS. 

Operations of the Unmanned Aircraft 

As stated earlier, the UAS will be a tool mostly for out of state real estate clients to 

be able to view properties, view entire structures; and educate them more fully 

before entering into a real estate transaction. · 

The flights of the UAS will not pose a safety threat with the proper procedures in 

place as mentioned in the section "Procedures for Flight." As described earlier, 

there wiU, at all times, be an observer, a safety perimeter of 100 feet, battery levels 

above 75% before flight, a full pre-fligrrt.checklist arid run-up, revieW of the flight 

plan, permission of property owners, written plan submitted to the FSDO if 

required, proper communication between PIC and observer, and pemnission from 

local authorities. Flights will only be conducted during daylight hours. 

The UAS does not have the capability to fly over 29.1577 knots and speeds will 

generally be around 3-10 knots. The UAS will not be operated if clouds are at a level 

below 700ft AGL. This will ensure a safe distance from clouds and any low-flying 

aircraft. 

The indented area of operation will be in rural settings, as well as neighborhoods 

where homes are on lots over one-half acre and have a distance of 75-100 feet 

between homes. It will not be used in high-density residential settings as that could 

pose too many safety concerns. Potential hazards in the intended area of operation 

are trees, power lines, structures, street lights, and fences. Because of the slow flight 

of the UAS when in operation for videography and photography for the intended 

purpose, the PIC and observer will be able to safely maneuver the UAS around the 

obstacles. The UAS also has capabilities of hovering in place which allows it to be 

flown at very low speeds. 

The intended cities and counties of use have small non-towered municipal airports. 

The UAS will never be flown near the airports so as to pose any sort of safety 

Robinson Capital, LLC 12106 E 1000 N I Sugar City, ID 83448 1208.360.4688 I rick@theidahorealtor.com 
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EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT I 

concern to pilots in the area. The altitude of the UAS will barely be above structures 

which should no pose any concern to piloted aircraft in the area. But for added 

safety, a 2-way radio to communicate to-air traffic will always be on hand. This UAS 

will NEVER be flown within a S-mile radius of any large international airport. The 

UAS has built in restrictions that prevent flight within those distances from an 

airport. Th~ built in flight restrictions prevent takeoff in a S~mile radius of-a large 

International airport such as LAX, S~C, _etc. The UAS will also be prevented from 

taking off within .6 miles of a smaller regional airport such as IDA If the UAS is in 

flight and tries to fly into a no-fly zone, the UAS will stop and return back. 

If required be the FAA, I will notify the FSDO of my flight operations prior to flight. -

14 CF.R. Part21, SubpartH,91.203{a) & (b) ,Airworthiness Certificate.· 

Because the UAS·is under 55lbs, fully loaded,, anq does not carry a pilot, passenger, .. 

any e4plosiye materials or flammable fuel, op~rates in a fully restricted and 

controlled environment, I request exemption from 91.203 part A & B. 

14 C~F.R. 4-5.2.3 B Marking the Aircraft 

The UAS.will not.have au airworthiness certificate and bec,ause there is no entrance 

to the cabin, cockpit, or pilot station, there is no place inside the aircraft to place the 

word "Experimental." If required by the FAA, I will place the word "Experimental" 

on the exterior - of the UAS. However, due tg the size, 2 inch lettering will not be -

possible. 

14 C.F.R. 61.113_ A & B Private Pilot Privileges and Limitations: Pilot in 

Command 

Unlike civil aircraft, the UAS does not carry living things on board; rather, it is 

controlled remotely via a safe and restricted location. The risks during operation 

are so minuscule that the PIC will exceed the present level of safety required for a 

commercial pilot to operate a rotorcraft with a commercial license. 

14 C.F.R. 91.9 B(2): Civil Aircraft Flight Manual in the Aircraft 

Because of the size and configuration of the UAS, no such manual can be carried. 

The flight manual will be carried at the ground station where the PIC and observer 

are operating the UAS. 

14 C.F.R. 91.103 B(2): Preflight Action 

A thorough pre-flight inspection and run-up of the aircraft will be performed prior 

to any flight of the UAS. Please see the appendix for the pre-flight checklist. 

14 C.F.R. 91.105: Flight Crewmembers at Station 

Because there are no souls on board a UAS, regulation 91.105 should be exempt 

from my purposes of using a UAS. However, crewmembers will be on the ground 

and in direct communication, namely the PIC and Observer. 

14 C.F.R. 91.109: Flight Instruction 

Robinson Capital, LLC I 2106 E 1000 N I Sugar City, ID 83448 1208.360.46881 rick@theldahorealtor.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT I 

The UAS does not have dual controls. The PIC communicates to the UAS via a radio 

control box. The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

The UAS will never operate at an altitude greater than 400ft AGL. It will be operated 

within a restricted area and with the consent of any and all persons or property • 

involved. 

14 C.F.R. 91.121 Altimeter Settings 

The UAS that will be used does not have an altimeter. Rather, it uses GPS to 

determine the altitude. Since the normal protocol is to set your altimeter to the 

barometric pressure reading at the time of flight an exemption will be needed. A 

safety check will be performed before each flight ensuring that the GPS altitude is 

reading correctly. · 

14 C.F.R. 91.151: Fuel Requirements for Flight in VFR Conditions 

The battery in the DJI Phantom 2 Vision+ is capable of 25 minutes of powered flight. 

Given that the UAS will never be further than 300ft away and 400ftAG~, the longest 

possible time it could take the UAS to return to the ground safely is approximately 

1.5 minutes. I categorize battery life under 10 minutes as the danger zone. The UAS 

will automatically return to its point of origin and safely land when the battery life 

reaches 2 minutes. Battery life as well as flight-time remaining is displayed on the 

screen visible to the PIC and observer. For safe flight, I will never fly the UAS with 

under 10 minutes of battery life. · 

14 C.F.R. 91.203 A & B: Carrying Civil Aircraft Certification and Registration 

The UAS weighs under 55 pounds and does not have an on-board pilot operating it. 

The UAS is not capable of carrying such documents should they be required. These 

documents, if required by the FAA, will be carried by the PIC and will be accessible 

upon request immediately. 

14 C.F.R. 91.405 A; 407 A(1); 409 A (2); 417 A & B: Maintenance Inspections 

This regulation applies to aircraft that have an airworthiness certificate and should 

not apply to the operation of my intended use for the UAS. However, regular 

maintenance, checks, and cleaning of the UAS will be performed before each flight 

and if required by the FAA, can be logged into a log book and surrendered upon 

request. Regular maintenance will include cleaning ofthe 4 motors on the UAS 

Rotorcraft, motor testing, flight control testing, checking lights, and a cleaning of the 

entire UAS. 

Should a mechanical issue arise during a flight, the UAS will land immediately and 

should not pose a safety concern because of its lightweight, restricted flying area, 

and low and slow maneuvering. 

General Summary 

Robinson Capital, LLC 12106 E 1000 N I Sugar City, ID 834481 208.360.46881 rick@theldahorealtor.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

I feel that my operation of the UAS will meet and exceed all current safety standards 

set forth by the FAA. I am seeking exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.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 commercially for buyer education purposes in Real Estate. 

Approval of this exemption will ensure safe flight operations for my UAS following 

the strict guidelines set forth in the request. 

Should you have ;;my questions or need to contact me, my information 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 that the crite~ia for .exemption in Section 333 of the Reform Act of 2012 

(namely size, weight, speed, operating capabilities, proximity to airports and 

populated areas and operation within visu,al line of sight and national security) have 

been satisfied and adequate justification has been provided for this exemption. 

I appreciate your time and consideration in this matter. 

Robinson Capital, LLC 12106 E 1000 N I Sugar City, ID 83448 [208.360.4688 I rick@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 OF WAIVER OR AUTHORIZATION 

Page 1 of 6 

This certificate is issued for the operations specifically described hereinafter. No person shall conduct 

any operation pursuant to the authority of this certificate except in accordance with the standard and special 

provisions contained in this certificate, and such other requirements of the 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 of aerial data collection. 

LIST OF WAIVED REGULATIONS BY SECTION AND TITLE 

NIA 

STANDARD PROVISIONS 

1. A copy of the application made for this certificate shall be attached and become a part hereof. 

2. This certificate shall be presented for inspection upon the request of any authorized representative of the 

Federal Aviation Administration, or of any State or municipal official charged with the duty of enforcing 

local laws or regulations. 

3. The holder of this certificate shall be responsible for the strict observance of the terms and provisions 

contained herein. 

4. This certificate is nontransferable. 

Note-This certificate constitutes a waiver of those Federal rules or regulations specifically referred to 

above. It does not constitute a waiver of any 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 2015 
FAA 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 of the 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 at any time by the Administrator, the person 

authorized to grant the authorization, or the 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 of its provisions, or when unforeseen safety factors 

develop. Failure to comply with the, authorization is cause for cancellation. The operator 

will receive written notice of cancellation. 

B. Safety of Fl~ght. 

1. The operator or pilot in command (PIC).is responsible for halting or canceling activity in 

the COA area if, at any time, the safety of persons or property on the ground or in the air 

is in jeopardy, or ifthere is a failure to comply with the terms or conditions of this 

authorization. · · 

See-and-Avoid 

Unmanned aircraft have no on~board pilot to perform see-and-avoid responsibilities; 

therefore, when operating outside of active restricted and warning areas approved for 

aviation activities, provisions must be made to ensure an equivalent level of safety 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 of persons 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 2015 
FAA 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 of the 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 of conflicting traffic. 

2. Pilots are reminded to follow all feder~l regulations e.g. remain clear of ail Temporary 

Flight Restrictions, as well as following the exemption granted for their operation. < • ' ' • 

3. The operator or delegated representative ~4st not operate 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 of and 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 CPR part 4 7, and have 

identification (N-Number) markings in accordance with 14 CPR part 45, Subpart C. 

Markings must be) as large as practicable. 

C. Reporting Requirements 

1. Documentation of all 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 of Operator, 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 of flights (per location, per aircraft) 

e. Total aircraft operational hours 

f. Takeoff or Landing damage 

Small UAS Operations 200 feet and below for 

Commercial Purposes March 20 15 
FAA 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 of lost link events (control, performance and health monitoring, 

or communications) per UA per flight. 

D. Notice to Airmen (NOT AM). 

A distant (D) NOTAM must be iss~ed when unmanned aircraft operations are being 

conducted. This requirement may be accomplished: 

a. Through the operator's local base operations or NOT 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 of the pilot filing the NOT AM request 

(2). Location, altitude, or operating area 

(3) Time and nature of the activity. 

AIR TRAFFIC CONTROL SPECIAL PROVISIONS 

A. Coordination Requirements. 

1. Operator filing and the issuance of required distance (D) NOT AM, will serve as 

advance A TC facility notification of UAS 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 MTR will be affected. In the event the UAS operational area 

overlaps (5 miles either side of centerline) 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, if unable 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 AP 11 B 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. If prior coordination and 

deconfliction does not take place 24 hours in advance, the operator must remain clear 

of all MTRs. 

B. Communication Requirements. 

1. When operating in the vicinity of an 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 reference point (ARP) of a public use 

airport, heliport, gliderport, or ~eaport listed in the Airport/Facility Directory, Alaska 

Supplement, or Pacific Chart Supplement of the 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: 

• If the 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 2015 
FAA 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 of local authorities or 

property owners, it is the responsibility of the 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