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, equipped with a camera 

which I hereby petition lawful use for aerial videography/cinematography to 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 

listing videos; following exemption and approval by the 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 use of 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 by the FAA. For the 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 listing videos for homeowners who cannot afford 

expensive manned aircraft for the same purpose. Both of which will promote local economic 

growth through increased employment and increased tax 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 relief from any currently applicable FARs operating to prevent me, Ronald W Duff, 

contemplated commercial cinematic, academic and other flight operations within the national 

airspace system. The Reform Act in Section 332 provides for 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 by the Reform Act. I would like to operate my ultra light weight UAS prior to the 

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 of the UAS's; Whether the UAS will 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 less than 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 of vertical and horizontal operations, and are flown only within my 

line of sight, as the remote control pilot. Utilizing battery power rather than combustible fuels, 

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 and will not “create a hazard to users of the national airspace system or the 

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 quadcopter).

 

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 Will 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 

potential threat to the public. Congress has already proclaimed that it is in the 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 is far less than a full size helicopter or fixed wing aircraft; which are heavy, 

contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered 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 and 
related industry fields that can be embraced by the NAR 3

 , CAR 4 , and IAR 5 for development 

in cooperation with the FAA. In addition I, Ronald W Duff, submit the following 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 per flight; I land my UAS prior to 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. I adhere 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

Illinois Association 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 complete transparency as to who is flying, why 

aerial photos are being taken and how the public can contact someone to 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 obvious to the public. Although my UAS is capable of night flight, 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 thus the potential for fire 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 of 4K 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 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, 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 according to certain specifications. My UAS are, by definition, unmanned. They therefore 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 spotter with the UAV will see the 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 limited to 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 

attended to the operation of my UAS is far less than the risk levels inherent in the 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).

 

10
D. 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 to 
relocate 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, 

request for exemption will reduce current risk levels and thereby 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 Reform Act 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 less than 5 pounds and travelling 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 requirement to 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