July 22, 2015 Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590 Stellart Real EstateServices, LLC Dba MLS CameraGuy 121 CountryClub Lane Anthony, NM 88021 915.490.3444 Fax/915.317.6027 art@mlscameraguy.com www.MLSCameraGuy.com

Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Stellart Real Estate Services, LLC (PD) seeks an exemption from Federal Aviation Regulations ("FARs") detailed below forthe following described Unmanned Aerial System called in this application the PD System, which includes an Unmanned Aircraft (UA) and ground station-based equipment and crew: THE UNMANNED AIRCRAFT (UA): e A lightweight (2.7 lb gross weightwith all on-board equipment), battery operated 4-motor rotorcraft in theform ofa octocopterthattakes offand landsvertically, manufactured by DJI, Model Phantom Vision Plus 2, to carry the following equipment in flight; • An on-board flight computerwith GPS navigation and location ability that receives signals forflight controls from a ground-based transmitter/controller; • An on-board camera capable of capturing imagery in theform offull color, high definition still photos and video; • An on-board telemetry system that delivers flight data from the on-board flight computerto the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site; • A 600mW, 5.8GHz on-board radio transmitterthattransmits live video from the on-board camera plus all the flight data from the telemetry system described above;

## ..

THE GROUND STATION-BASED PART OF THE SYSTEM:

• A Pilot in Command (PIC) in operational control ofaflight operation from beginning to end and who controlsthe UAwhile in the air; • A 1OOmW, 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight; • A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together onto a screen forthe PIC to view during flight; • A Visual Observer (VO) is a person who provides a second pairofeyes to visually trackthe UAwhile in flight.
The requested exemption would support an application for a commercial Certificate of Authorization to use the above described CAV System to support aerial photography and video primarily of real property.
The UA, powered by batteries, is smaller, lighterand more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little or no riskto national security.
Low level oblique photos and video from several angles are far more effective than ground-based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. Helicopters can be used, butthey are more expensive to and not able to fly as low. The benefits of reduced cost and improved quality ofpresentation from the UAwill be valuable to and benefit many buyers and sellers ofreal property.
The PD System will be operated in the field with both a PIC and aVO in accordancewith FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: (a) No flight will be madewith a UAGross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no morethan 400ftAGL, at an airspeed of no more than 25 knots and no furtherthan 3/4 NM from the PIC; (c) All operations must utilize avisual observer (VO). The VO and PIC must be ableto communicate by voice at all times during aflight operation; (d) Operations will be restricted toflights over private property with the permission ofthe property owner;(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at leastten hours logged as a UA pilot with a similar UAtype; (f)All required permits will be obtained from state and local government priorto operation; (g) The PD System will not be operated over densely populated areas; (h) The PD System will not be operated at airshows; (i) The PD System will not be operated over any open-air assembly of people; 

### U) The PD System will not be operated over heavily trafficked roads; (k)The PD System will not be operated within 5 NM of an airport or heliport; (I) Operations will be restricted to day only and weather conditions equivalentto VFR; (m)The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; (n) No flight may be madewithout a Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UA is in a condition safe forflight (seeAppendixA).
The PIC and VO will meetthe requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training.
We submitthat the combination ofthe UA's lightweight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions (a) through (o) listed above, the FAA can have full confidence that the**opera~ion** will have an equivalent orgreater level ofsafetythan manned aircraft performing the same mission.
The name and contact information ofthe applicant are:

Stellart Real Estate Services, LLC Dba MLS Camera Guy Attn: Art Moreno, Jr. Phone: 915.490.3444 Email: art@mlscameraguy.com

The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendum upon which each may be found togetherwith our proposed equivalent level ofsafetyfor each regulation:

• 14 CFR Part 21

................................. Addendum Page 1 • 14 CFR 91.203

................................. Addendum Page 1 • 14 CFR 45.23, 45.29

.......................... Addendum Page 2 • 14 CFR 91.9

.................................... Addendum Page 2 • 14 CFR 61.113, 61.133

....................... Addendum Page 2 • 14 CFR 91.109, 91.119, 91.121..

............Addendum Page 3• 14 CFR 91.151

................................. Addendum Page 4 • 14 CFR Subpart E (91.401- 91.417)

......Addendum Page 4 • FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum Page 4
Ifirmly believethatgrantingthis exemptionwill allowforexpanded accesstothe global real estate market. In manycases, homes/properties may have restricted orlimited accessdueto numerous factors. Many properties are "hidden" behindwalls and landscaping, resulting in diminished "curb appeal". Providingthis reliefwould eliminatethese problems and leadto increased commercefor both buyers, sellers, governmenttaxation agencies, real estate affiliated companies, (title, escrow, notary), construction industryand home improvementbusinesseswho rely on athriving real estate market. Additionally UA V's providefor property inspections including roofand chimneythat can assist in identifying hardto observedefects in manufacturing and installation. Camera mounted drones help mitigateaccidentsanddeath occurring from slips andfallswhich often result in liability claims and damagesto all participants. Invariably, a reduction in riskto life and limb is a general benefittothe public interest. Lastly, aerialvideography providestheviewerwith safe accesstothe propertyvicinity, eliminating needless drivingto determine howclose a property isto afreeway, school, beach ornearby unsightlydevelopment.This in turn reduces exhaust emissions and air pollution. OurUAV's utilize battery powerand have no negative impactonthe environment.Whenfully rolled out, these emission reductionswill be measurableand significant.

Ivoluntarilysubmit my nameand all relevant informationforclearancewith anygoverning board havingjurisdiction overthis issue. Please contact us at any time ifyou require additional information orclarification. We lookforward to working with your office. Sincerely,

# ~~- Art Moreno, Jr., Owner SteUart Real Estate Services, LLC

Addendum containing Exemption Requests ai1d Equivalent Level ofSafety Appendix A
- Flight Manual Appendix 

### 8 - Owner's Manual for UAAddendum
ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Stellart Real Estate Services, LLC, requests an exemption from thefollowing regulations as well as any additional regulations that may technically apply to the operation ofthe CAV System:
14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe PO System undereither or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliancewith regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit our commercial purpose as well.
The aircraftwill not carry persons or property, will not carry fuel, and will only fly understrict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we proposethatthe UAwill be at least as safe, if notsafer, than a conventionally certificated aircraft performing the same mission.
Ifan experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirementfor an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph.
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew."
At a maximum grossweight of2.7 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain anequivalent level ofsafety and meetthe intent of91.203, we propose thatdocuments deemed appropriateforthis aircraft by the FAAwill be co-located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfythe requirement of 14 CFR 45.23, which follows immediatelyafterthe proposed placard description below:
EXPERIMENTAL Manufacturer: DJI Innovations, Inc. 55 South A Street, Suite 110 Pensacola, FL 32502 Model: Phantom Vision 2 Plus, Serial Number: PH646029696
Iffound please contact: (915) 490-3444
14CFR 45.23 Display ofmarks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word "EXPERIMENTAL" in letters at least2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration numberassignedto it by the FAA.
We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on thetop ofthe aircraft, as shown above, wherethe PIC, VO and others in the vicinity ofthe aircraftwhile it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, wewill display at the ground station a high contrastflag or bannerthat contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Since the aircraftwill operate within 3/4 NM ofthe ground station, the bannershould be visible to anyone that observes the aircraft and choosesto investigate its point oforigin.
14CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assumethatthe intent ofthis requirement is to ensurethat flight manual information is available to the aircrewwhile operating the aircraft. We request an exemption tothis requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available to the crew during flight operations.
To obtain an equivalent level ofsafety and meetthe intent of91.9, we propose that a current, approved UA Flight Manual (AppendixA) must ba available to the crew atthe ground stationanytime the aircraft is in, or preparing for, flight.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraftfor compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must either 1. Hold a Commercia! Pilot Certificate issued by the FAA, and have logged 25 hours offlight experience in this type of UA, or 2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available forthe pilot of a UAS to gain the experience in an equivalent category and class in orderto apply for a commercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business.
14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that "No person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fully functioning dual controls."
The PO System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second set of"controls", both the student and instructor can, and will, operate the single set ofcontrols simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level ofsafety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, orstructure. Since the aircraftwill be operating at a maximum of400 feetAGL, we cannot comply with this requirement.
In orderto provide an equivalent level of safety we will only fly over private propertywith the permission ofthe owner ofthe propertyflown over. The aircraftwill not be operated over congested areas or over any open air assembly of persons. The property ownerwill be briefed on the expected route offlight and the associated risks topersons and property on the ground. The aircraftwill be operated at a lowaltitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that dueto the small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft.
The UAwill always fly below400feetAGL and will not need to maintain cruising altitudes in orderto prevent conflict with otheraircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on-board computerto the display screen held by the PIC, providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin aflight in an airplane underday-VFR conditions unlessthere is enough fuel to fly to the first point ofintended landing and to fly after thatfor at least 30 minutes.
We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The UA is battery operated and the maximum duration offlightfrom a single battery charge is 18 minutes with a 20% reserve. Since the aircraftwill neverfly more than 

### % NM from the point of intended landing, afull battery charge at launch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and askfor an equivalent interpretation with the word "energy".
14 CFR Subpart E (91.401 - 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection.
It is our intention thatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensure thatthe aircraft is in an airworthy condition priorto every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturerortheir designated repairfacility. The PIC will documentwork performed in accordancewith 91.417. Wefeel that dueto the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety.-_.,_ I

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have avalid FAA second-class medical certificate issued under part 67 in orderto perform as a pilot orobserver.
The UA maximum gross weight is 

### 2.7 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomouslyto the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in 

### a large aircraft is an unnecessary burden.
We propose that the minimum medical requirements forthe PIC and VO be vision corrected to 20/20 and avalid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid airtraffic; a licensed driver is medically qualified to operate a much largervehicle.
APPENDIX A
- FLIGHT MANUAL FLIGHT RESTRICTIONS (a) No flight will be made with a UA Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400'AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; (c) All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate verbally at all times during aflight operation; (d) Operations will be restricted to flights over private propertywith the permission ofthe property owner; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at leastten hours logged as a UA pilot with a similar UAtype; (f) All required permits will be obtained from state and local government priorto operation; (g) The PO System will not be operated over densely populated areas; (h) The PO System will not be operated at air shows; (i) The PO System will not be operated over any open-air assembly of people; U) The PO System will not be operated over heavily trafficked roads; (k) The PO System will not be operated within 5 NM of an airport or heliport; (I) Operations will be restricted to day only and weather conditions equivalent to VFR; (m)The PIC will briefthe VO and property owner aboutthe operation and risk before the firstflight at each new location; (n) No flight may be made without a successful Pre-Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe forflight.PRE-FLIGHT CHECKLIST (1) Use voltmeterto determine that UA battery is fully charged in orderto prevent unexpected premature descent; (2) Check all wiring connections are tight; (3) Check all propellers are undamaged and no cracks exist in any structural members ofthe UA; (5) Turn on radio controller, check for adequate voltage, set itto connectto the UA, move all control switches to forward ordown position and throttle control stickfull back position; (6) Connect UA main battery, check for radio contact with UA's radio receiver; (7) At a location different from previous flight, re-set GPS and compass to current location; (8) Turn on transmitter, gimbal and camera. TO REGAIN CONTROL AFTER LOST RADIO CONTACT 1. Failsafe= ON 2. Throttle = 50% 3. Mode=ATTI 4. Failsafe = OFF 5. Mode= GPS If radio contact is not restored, the UA will automatically continue at 60 ft above its last elevation before losing contact toward its takeoff point, then descend and land there autonomously