December 17 , 2015

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



## Real Time Realty, LLC : Petition For Exemption From

The Requirements of Title 14 of the Code of Federal

Regulations: 14 C.F.R §§ 61.101, 61.113(a) and (b), 91.7(a), 91.9 (b)(2), 91.109, 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.407(a)1(a), 91.409(a)(2),

91.417(a) and (b), Pursuant to Section 333 of the FAA
Modernization and Reform Act of 2012

Name and Address of Petitioner

Real Time Realty , LLC

104 Settlers Drive Naperville, Illinois 60565

Scott Gerami Scott@naperhomes.com (630) 357

- 8200SECTION	I

– PETITION	SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (“Section 333), 14 C.F.R 11, and the FAA general exemption authority under 49 U.S.C. § 44701(f ), Real Time R ea l ty, LLC (henceforth, the ‘Petitioner’) he reby applies for a “Summary Grant” e xemption from Federal Aviation R egulations (‘FARs’) identified below, to

allow for commercial operation of small unmanned aircraft

, under 55 pounds in gross weight

, in airsp ace regulated by the Federal Av i a ti on Administr ation (FAA), for the purposes of technology research, operations training, photography, videography, a nd aerial data collection.

The proposed exemptions are specifically from 14 C.F.R §§ 61.101, 61.113(a) and (b), 91.7(a), 91.9 (b)(2), 91.109, 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.407(a)1(a), 91.409(a)(2), 91.417(a) and (b).

The specific small unmanned aircraft to be operated under this exemption petition are the:

DJI Phantom 3 DJI Inspire 1

SECTION	II

– DESCRIPTION	OF PETITIONER OPERATIONS

This exemptio n would be granted to operate the aircraft described above for aerial data collection

, operations training, photography and videography, and operations training

. All aircraft will have a gross weight of less than 25 pounds, travel at speeds no greater than 87 knots, carry neither pilot nor passengers, and will operate at all times within a secured area. All flights will occur within the operating limits recommended by the aircraft manufacturer, and in accordance with the safety guid elines and operational standards outlined by the aircraft manufacturer. All radio frequency spectrum for operations and control of aircraft comply with the Federal Communications

Commi s sion (“FCC”) requirements. All UAS flown under this exemption are equip ped with safety mechanisms to allow for the ability to perform predictable, automated flight maneuvers to return to a predefine d location in the event of cert a i n in

- flight failures, including lost link conditions. Additionally, all flights will be flown wi th a minimum crew consisting of the ‘pilot in command’ (PIC) and ‘visual operator’ (VO).

Below is a summary of the limitations and conditions to which the Petitioner proposes to be bound when conducting commercial flight operations under this petition:

1. Al l aircraft will weigh less than 5 5 pounds

. 2. All flights will occur during daylight hours

. 3. All flights will be conducted with a minimum crew of a PIC and VO

. 4. All flights will be conducted by a PIC who holds an airline transport, commercial, private,

recreati onal, or sports pilot certificate.

5. All PICs will have demonstrated the safe ability to operate the UAS consistent with this exemption, consistent with aircraft manufacturer’s operation limitation s , and consistent to the Petitioner’s internal operational st andards , and aircraft manufacturer’s procedures

. 6. All flights will be conducted by a PIC who holds either a current FAA medical certificate,

or a valid U.S. Driver’s license.7. At all times, VO will be able to communicate by voice and/or radio to PIC

. 8. All fli ghts will be operated within visual line of sight (VLOS) of PIC and/or VO

. 9. All flights will be operated at an altitude no higher than 400 feet AGL

. 10. No flights will occur within 5 nautical miles of an of an ‘ airport reference point ’ (ARP) as denoted in the current FAA Air port/Facility Directory (AFD) 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 of agreement with the airport management must be made

available to the Administrator or any law enforcement official upon request.

11. 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.

12. If the UAS loses communic ations or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

13. All Flight operations must be conducted at least 500 feet from all nonparticipating persons (th is excludes PIC, VO, and operat or trainees), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons rema in under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons;

b. The owner/controll er 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.

SECT ION	III

– EXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY

14	CF R	§ 61.113(a)

- (b): Private	pilot	privileges	and	limitations:	Pilot	in	command

. 1 4	CFR	§	61.133(a):	Commercial	pilot	privileges	and	limitation

. The Petitioner seeks relief to the extent necessary to allow a PIC holding a private pilot’s license to act as PIC for commercial purposes under the constraints of this exemption, given the PIC is qualified to fly the designated UAS as demonstrated by meeting all minimum operational training

as ou tlined by this exemption and the operational standards of the Petitioner.

14	CFR	§	91.7(a) Civil	aircraft	airworthiness

. The P etitioner understands that the FAA has issued simi lar exemptions stating that relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , is not necessary, which removes the airworthiness certificate requirement for the UAS within this petition, and that exemption from 14 CFR 91.7(a) there is unnecessary. All operators under this exemption will be responsible for determining whether aircraft are safe for flight using

aircraft manufacturer operating guidelines, Petitioner’s internal maintenance and operating standards, and safety checklists.14	CFR	§	91.9 (a) (b)(2)

- (c) Civil	aircraft	flight	manual,	marking,	and	placard	requirements

. 14	CFR	§	91.203(a)

- (b) Civil	aircraft:	Certifications	required. The Petitioner seeks relief, given the size of the aircraft, to make all operations and emergency

manuals available to all crew members at the ground station at all times. This is in line with the FAA Memorandum “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014. Additionally, all aircraft with be marked in human readable font all necessary aircraft identifying information, to be in accordance with 14 CFR 45(c). All identifying markings will be as large as practical.

14	CFR	§	109	Flight	instruction;	Simulated	instrument	flight	and	certain flight	tests. The Petitioner seeks relief, given the existing inherent means of controlling the aircraft described in this petition, the PIC and operat or trainee will be able to adequately operate a single set of controls during training and instruction wh ile maintaining control over the aircraft.

14	CFR	§	91.119(c) Minimum	Safe	Altitudes	General. The Petitioner seeks relief in that all operations will be limited to 400 feet altitude AGL, or less and thus will maintain as a separation as practical from all nonparticipant persons, vessels, vehicles, or structures from which the operator does not have the permission to fly above or in proximity to.

14	CFR	§	91.121 Altimeter	Se t tings The Petitioner seeks relief since the aircraft described in this petition wi ll not have a typical barometric altimeter onboard. Also, due to the nature of the operations vehicle will always be below 600 feet AGL and will not be flying in proximity to other aircraft to warrant measures for deconflicting airspace. Furthermore, an AG L altitude measurement at the aircraft takeoff location

is stored on the aircraft on

- board f light controller, allowing an updated AGL altitude value to be provided to the operator.

14	CFR	§	91.151 Fuel	requirements	for	flight	in	VFR	conditions

The Petitio ner seeks relief to the extent that all aircraft under this petition are battery operated, will be operated within visual line of sight, and will carry battery charge that permits no more than 45 minutes of continuous operation. In lieu o f the 30 minute re serve, the Petitioner will ensure all flights have at least 20% battery reserve, given the intended flight time.

14	CFR	§ 91.405 Maintenance	required. 14	CFR	§	91.407(a)(1) Operation	after	maintenance,	preventative	maintenance,	rebuilding,	or

alteration. 14	CFR	§	91.409(a)(2) Inspections 14	CFR	§	91.417(a)

- (b) Maintenance	records. The Petitioner seeks relief to the extent that the operator will ensure that an aircraft is in an airworthy condition prior to every flight and will perform detailed inspections pre

- and post

- flight in accordance with the Petitioner’s operational standard s and safety checklists. All maintenance performed on an aircraft will be documented in a dedicated ‘air vehicle log’ in accordance with 14

CFR § 91.417.SECTION I V

- PUBLIC INTEREST STATMENT

Based on the P etitioner ’s UAS, the qualifications and experie nce of Petitioner’s UAS operators,

and restricted flight environments within which the Petitioner will operat e, the requested exemptions fall completely within the zone of safety envisioned the FAA Modern ization and

Reform act of 2012 , at the time of this petition. There is inherent enhanced safety achieved by replacing larger, manned aircraft, carrying crew and fuel, with aircraft carrying no passengers or fuel, and operating under specifically limited guidelines and procedures proposed by the petitioner. The granting of this petition also a dvances Congress goal of integrating commercial UAS operation into the National Airspace System in accordance with the FAA Modernization and

Reform Act

.

These reasons give the FAA good cause to find that UAS operations enabled by this petition are in the public interest

Lastly, b ecause the requested amendment would not set any precedent or otherwise raise any novel issue, and because petitioner seeks to begin these operations without delay, petitioner respectfully requests the FAA to determine that good cause exists to dispense with publication of the summary of this petition in the Federal Register and grant the requested amendment expeditiously by

summary means.

Respectfully submitted,

Real Time Realty , LLC

104 Settlers Drive Naperville, Illinois 60565

Scott Gerami
Scott@naperhomes.com (630) 357

- 8200