**Ronald W Duff, Broker REALTOR, Springfield Illinois**

**- Section 333 Exemption Petition** 

December 31, 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

**Re:** Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)
Dear Sir or Madam,
I, Ronald W Duff, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Ronald W Duff, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Ronald W Duff, may operate my DJI manufactured, Phantom 3

– Professional model, small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Ronald W Duff, am a licensed real estate Broker within the State of Illinois; experienced in flying quad

-copters for recreational purposes. I own a high grade Phantom 3 Professional model quad

-copter manufactured by DJI UAS, equippedwith a camera which I hereby petition lawful use for aerialvideography/cinematographyto enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the Springfield area and surrounding rural communities, and augment real estate listingvideos;following exemption and approval bythe FAA.Thereby enhancing their academic research experience for the Springfield area and surrounding rural communities

. My quad copter is equipped with the latest technology as of this writing, regarding flight control, navigation stability, safety protocol’s and HD real time imaging which further enhances overall safety
. I have flown small image equipped quad

-copters over the last two years without incident. Committed to safety with each flight. My, Ronald W Duff exemption request would permit operation of ultra light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. Conducting predetermined operation in FAA compliant areas from airports, heliports and reasonable distances from vehicular traffic, for community videos, of individual homeowner’s for real estate listing videos/photos primarily as well as local community events. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent unauthorized flight, filming or catastrophe.I, Ronald W Duff, have personally instilled safety protocols and controls 1 to avoid and prevent

public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photography and community event usage as I, Ronald W Duff, record flight data and other information gained through requested flight operations to share with future professional applicants seeking FAA flight approval. I have also developed “Friendly Flight Protocol”(FFP), procedures which is explained later in this petition under the Safety/Privacy heading.
Granting my, Ronald W Duff, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the useof UAS's for real estate and community event purposes. Further I, Ronald W Duff, will conduct my operations in compliance with the protocols described herein or as otherwise established bythe FAA. Forthe reasons stated below I, Ronald W Duff, respectfully request the grant of an exemption allowing me to operate ultra light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to the Springfield area and surrounding rural communities and to enhance real estate listingvideosfor homeownerswho cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic growththrough increased employment and increasedtax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard.

**I. Contact Information:** **Business:**

Ronald W Duff, Associate Broker RE/MAX Professionals 2475 West Monroe St Springfield Illinois 62704 Office: (217) 787

-7215 Mobile: (217) 652

-6025 **Personal:** Ronald W Duff 1515 West Edwards St Springfield Illinois 62704 Mobile: (217) 652

-6025 Email: RonDuff@Remax.net
Email: RonDuff@Remax.net

**II**

. **The Specific**  **Sections of**  **Title 14**  **of the**  **Code of**  **Federal Regulations**  **From Which**  **Ronald W**  **Duff Requests Exemption are:** 
14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).
**III. The Extent of relief Ronald W Duff** **seeks and the Reason He Seeks Such Relief:**
I, Ronald W Duff, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relieffrom any currently applicable FARs operatingto prevent me, Ronald W Duff, contemplated commercial cinematic, academic and other flight operations within the national airspace system.The ReformAct in Section 332 providesfor such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Ronald W Duff’s, ultra light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated bythe ReformAct. I would liketo operate my ultra light weight UAS priortothe time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate and community related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS's;Whetherthe UASwill be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Ronald W Duff

. My UAS utilizes four (4) counter

-rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including a HD camera with gimbal which provides on the ground, real time imaging

.I, Ronald W Duff, consider safety as foremost with each flight. My small unmanned aircraft is

designed to hover in place via GPS and operate in lessthan a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 24 kph (15 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode 2 for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost, this UAS is designed to slowly descend to the point of take off

. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable ofvertical and horizontal operations, and areflown only within my line of sight, as the remote control pilot. Utilizing battery power ratherthan combustiblefuels, flights generally last between three (5) to seven (10) minutes, with an altitude under two hundred fifty (250) feet. I, Ronald W Duff, utilize a fresh fully charged battery with each flight as a safety precaution. Full flight time limit for each battery is twenty (25) to twenty five (30) minutes as tested. Battery levels and GPS communication monitoring is always displayed on a HD mobile device screen attached to the controller. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose my investment in equipment

. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.
I, Ronald W Duff, am extremely cautious when operating of my UAS/ultra light weight unmanned aircraft andwill not “create a hazardto users ofthe national airspace system orthe public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Ronald W Duff’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security. I Ronald W Duff have exceeded 50 hours of total time as a UAS rotorcraft pilot including in excess of the required 10 hours logged as a UAS pilot with a multi

-rotor UAS. I, Ronald W Duff has further logged in excess of the required 5 hours as a UAS pilot operating the make and model of UAS to be used. (DJI

- Phantom 3 Professional quad

copter).

2 Smart Mode includes safe circle for operation, position hold, self

-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. See Appendix A

- Operator Manual.**IV. How Ronald W Duff** **’s Request Wil l Benefit the Public As**  **a Whole:** 

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and Realtors working in high end properties or luxury homeowners can afford to absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash.The use of combustible fuel can exploded and burn on impact. My, Ronald W Duff's, UAS pose no such threat since size and lack of combustible fuel alleviates any potentialthreattothe public. Congress has already proclaimedthat it is inthe public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, Ronald W Duff, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the city of Springfield and surrounding rural communities

. My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra light weight UAS crashing isfar less than a full size helicopter orfixedwing aircraft;which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.
The public’s interest isfurthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. Permitting me, Ronald W Duff, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Springfield area and surrounding rural communities for companies looking to relocate or build and develop in the Springfield area and surrounding rural communities as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community. Ancillary uses in real estate marketing and sales which benefit the buying and selling public can be demonstrated thru Aerial videography during the property inspection process on building structures taller than three stories. High definition imaging of exterior structures and roofs can be accomplished at very reasonable cost and extreme efficiency through the use of UAS’s. Finally, aerial imaging enhances prospective real estate buyers interest by providing “sky

-views” of the property boundaries, out building location perspectives and neighborhood design. Proximity to shopping, parks, and other cultural sites can also give unique and valuable perspective to a prospective buyer.

**V. Reasons**  **Why Ronald**  **W Duff**  **’s Exemption**  **Will Not**  **Adversely Affect**  **Safety Or**  **How The**  **Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:**
My, Ronald W Duff’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Ronald W Duff, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors andrelated industryfieldsthat can be embraced by the NAR 3 , CAR 4 , and IAR 5 for development

in cooperationwith the FAA. In addition I, Ronald W Duff, submitthefollowing representations of enhancements to current aerial videography and photography for real estate:
My UAS weighs less than 5 pounds complete with a small ultra light weight high quality camera; I only operate my UAS below 300

-325 feet 6 (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS typically operates for 15

-20 minutes perflight; I land my UAS priorto manufacturer recommended minimum level of battery power;

 I pilot my UAS through remote control only by line of sight;

 My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

 I use constant visual display of altitude, battery life and GPS signal strength.

 My UAS navigates with simultaneous, MULITPLE satellite correspondence. Usually 10 to 15 satellites assist in navigation during a single flight.

 I actively analyze flight data and other sources of information to constantly update and enhance safety protocols;

 I only operate in a safe environments that are strictly assessed. Take

-off and Landing is always a vertical assent/dissent in a clearing

- away from power lines, elevated lights, trees and other encroaching structures

. Vertical navigation is applied until a height above utilities and structures is achieved. Iadhere to ordinances and laws regarding airports and do not navigate over power stations or emergency police and medical helicopter destinations;
 I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance;

 I always obtains all necessary permissions prior to operation;

 I have procedures in place to abort flights in the event of safety breaches or potential danger by implementing “Fail Safe” mode which directs the quad

-copter to slowly return to home base and land. **Safety and Privacy via “Friendly Flight Protocol” FFP** 

 Regarding safety and privacy of collateral population and properties, I have developed “Friendly Flight Protocol” (FFP), procedures that include disclosure and consent

- by notifying contiguous property owners prior to flight and providing a descriptive flight objective Flyer (“Notice of Aerial Photography” Flyer) which provides a brief explanation of the equipment and intended use as well as anticipated flight dates and times. 9

3 National Association of Realtors, http://www.realtor.org/ 4 Capitol Area Realtors, http://www.seehouses.com/ 5 IllinoisAssociation of Realtors, http://www.iar.org/ 6 Phantom 3 Professional quad

-copters altitude is constantly displayed on an attached mobile device (see Operator Manual) Also, as part of FFP, written consent is obtained from the subject property owner. In

addition, a yard sign similar in size to a typical real estate “For Sale” sign is posted directing passer byers that low aerial flight photography is underway directing a distance of 50’ from the ground controller and UAS (Camera Drone), be maintained. This is done primarily to keep fascinated on-lookers from distracting me during flight. My name and contact information is provided on the sign as well as on the “Notice of Arial Photography” Flyer which provides completetransparency asto who isflying, why aerial photos are beingtaken and howthe public can contact someoneto ask questions or present concerns.

 Regarding privacy, it’s worth noting that my UAS creates a discernable propeller noise which would likely alert anyone nearby of it’s presence thereby making privacy flight infractions obviousto the public.Although my UAS is capable of nightflight, imaging is not possible due to lack of necessary camera lighting necessary for distance imaging. My UAS also has Red and Green flashing flight lighting easily revealing it’s presence thereby deterring flight in or over areas of un-consenting land owners or visitors. Finally, My UAS has no audio recording capabilities and I have no intention or need to add such capabilities nor is audio practical from typical height used for imaging and considering flight noise previously mentioned. 9 Appendix C

- Notice of Aerial Photography
 Accordingly, my UAS has been operated applying Friendly Flying Protocol procedures and will continue to operate at and above current safety/privacy standards

. My, Ronald W Duff’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, they are not without incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra light weight UAS.
First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thusthe potentialforfire or explosions is eliminated

.Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through developed technology of4K camera imaging and use of post editing software allowing pan and zoom.

**VI. A Summary The FAA May Publish in the Federal Register:**

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals andThe Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and

enclosed operational area of my, Ronald W Duff’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Ronald W Duff’s, current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 7 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Ronald W Duff

. B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked accordingto certain specifications. My UAS are, by definition, unmanned.Theytherefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotterwiththe UAVwill seethe markings.The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limitedto non-commercial operations. I, Ronald W Duff, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills.The risks attendedtothe operation of my UAS isfar lessthanthe risk levels inherent inthe commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Ronald W Duff, to operate my UAS and meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

10D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the

operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Ronald W Duff, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above

-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.

. . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Ronald W Duff, UAS. However, as a safety precaution I inspect my UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Ronald W Duff’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.
**In summary, Ronald W Duff** **seeks an exemption from the following Regulations:** 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a)& (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a)& (b) to commercially operate my, Ronald W Duff’s, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, events and real estate operations, and to develop economic platforms for real estate to enhance the experience of those seeking torelocate to Springfield Illinois and surrounding rural communities

. Currently, area awareness

and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, Ronald W Duff’s, requestfor exemption will reduce current risk levels andthereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. I, Ronald W Duff, have been informally analyzing flight information and have developed safety protocols and the implementation of a flight operations public awareness process for real estate and community event usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and ReformAct of 2012.There are no personnel on board my, Ronald W Duff’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Ronald W Duff’s, operation of my UAS,weighing lessthan 5 pounds andtravelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Ronald W Duff, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Finally, I Ronald W Duff have complied with the requirementto register my Drone (UAS)

.My **UAS CERTIFICATE**  **NUMBER IS** **: FA373YMHWN** 

Respectfully submitted,

Ronald W Duff, Broker RE/MAX Professionals 2475 West Monroe St Springfield IL 62704