1

November 19, 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, Jessie R. RichGreer
, 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, Jessie R. RichGreer , an owner and

oper ator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Jessie R. RichGreer , may operate my small ultra -li ghtweight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Jessie R. RichGreer , am a n employee of a small business within the State of Nevada ; experienced in flying hobby type helicopters and aircraft for recreational purpose s and am in the process of obtaining my FAA certificated airplane pilot license . I have added a hobby grade quad

copter UAS ( Inspire 1 Professional ) to my inventory equipped with an attached camera with intent for aerial videography/cinematography and inspection to augment real estate listi ngs, land development,
events, promotional videos and aerial s urveys following exemption and approval by the FAA.

My, Jessie R. RichGreer's
, exemption request would permit operation of ultra -li ghtweight
, unmanned (piloted by remote control) and comparati vely inexpensive UAS(s) in tightly controlled and limited airspace, in areas away from the general public, airports, heliports and vehicular traffic . Such commercial operations will take place within property boundaries for individual homeowner real estat e listing videos/photos

, and such additional inspection, promotional and surveying operations as may be commercially viable . Currently, unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe legally operate similar li ghtweight, remote controlled UAS’s in the National Airspace System.

I, Jessie R. RichGreer
, have personally developed and implemented safety protocols and controls to avoid and prevent public hazard
, and will apply thi s experience and my extensive background in aircraft operation and maintenance to the proposed project

. I expect to contribute materially to the body of knowledge of this fledgling industry and to assist the FAA in developing safety protocols exclusive to lightweight UAS operations as I, Jessie R. RichGreer
, record flight data and other information gained thro ugh permitted flight operations.

Granting my, Jessie R. RichGreer ’ s , request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the National Airspace

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition2

System , but to “...establish requirements for the safe operation of such aircraft systems [UAS's] under Section 333(c ) of the Reform Act specific to the use of UAS's for real estate, photography and videography purposes. ” Further I, Jessie R. RichGreer , will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Jessie R. RichGreer , respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s to enhance real estate listing videos for homeowners who cannot afford expensive manned air craft , and to perform such other commercial photography and promotional services as may become available . This will promote local economic growth through increased employment and an increased tax base. It will further enhance public safety by replacing hea vier manned aircraft containing combustible fuel that poses a potential public hazard. Nevada has been plagued with serious drought conditions that only emphasize more the importance of using a UAS system as opposed to a fixed wing or rotorcraft in th is area. If a mishap were to occur, flying either a rotorcraft or fixed wing airc raft carrying combustible fuels, the devastation to the surrounding area residents and economies could be disastrous.

I. Contact Information: Jessie R. RichGreer
, 4351 Kyle Scott Ct. Sparks, NV 89436 Office 858-366-4225 Email: jgreer@greergrp.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which Jessie R. RichGreer 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 Jessie R. RichGreer seeks and the Reason He Seeks Such R elief:

I, Jessie R. RichGreer , submit this application in accordance with the Reform Act, 112 P.L. 95 §§
331 -3 34, seeking relief from any currently applicable FARs operating to prevent me, Jessie R. RichGreer
, from operating contemplated commercial ci nematic, 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, Jessie Rich Greer ’s
, ultra -l ightweight UAS meets the definition of “small unmanned aircraft” as defined in
Section 331 and therefore th e integration of my ultra light -w eight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra -l ightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft.

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition3

Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all rea l estate and other commercial 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 overa ll 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. Each of these items reflects in favor of an exemption for me, Jessie R. RichGreer

. My UAS utilizes four (4) counter -r otating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. It w eigh s less than five (5) pounds (far below the maximum 55 -p ound limit)
, including camera with gimb al.

I, Jessie R. RichGreer , consider safety as paramount with each flight. My small unmanned aircraft is designed to hover in place via GPS an d operate in a 13 Kn ot (15 mph) wind. For safety, stability and fear of financial loss my policy will be to no t f ly in winds exceeding 8 Kn ots (10 mph). Built -i n 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 for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed to slowly descend to point of take -o ff. I do not and will not operate my UAS near airports, hospitals, p olice heliports, or areas whe re the general public is within fifty to one hundred (50 -1 00) yards depending on location, conditions and weather. I will be constantly on alert for any manned aircraft 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 is flown only within my line of sight (LOS) as the remote control pilot. Utilizing battery po wer rather than combustible fuels, flights generally last between five (5) to ten (1 0 ) minutes, with an altitude under two hundred ( 20 0) feet. I, Jessie R. RichGreer
, will utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is up to twenty -f ive (25) minutes. 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 b etween radio control and UAS to eliminate potential for crash, loss of control or other hazard. Reserve batteries are at hand with each exercise to insure replacement for a sufficient ly safe level of operation. I do not believe in taking risk s that may

ca use a crash, which could not only create a hazard to public/property/manned aircraft, but would seriously jeopardize the economics of the venture

. I have logg ed numerous practice flights in remote areas as a hobbyist simulating flights for future commerc ial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions.

I, Jessie R. RichGreer , am extremely cautious when operating my UAS/ultra lightweight
unmanned aircraft and wi ll 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 correspond ing directive to integrate UAS's into the National Airspace System. Jessie R. RichGreer's UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition4

IV. How Jessie R. RichGreer's 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 a nd average homeowners, the expense of such aerial videography is cost prohibitive. Only large companies and wealthy brokers or luxury homeowners can afford to absorb such expense, d epriving non

- luxury homeowners and lower budget brokers from a valuable mar keting tool. My, Clayton J. Inskeep’s , UAS offer an effective and low cost alternative while pos ing a much lower environmental th reat since size and lack of combustible fuel minimiz es any potential threat to the public.

Congress has already proclaimed t hat 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, Jessie R. RichGreer' s , exemption request furthers the public interest through academic/visual awar eness of the geographical benef its in and around Reno
, Nevada . My ultra lightweight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra lightweight UAS crashing is far less than a full siz e helicopter or fixed wing aircraft
, which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. Again, considering the extreme fire danger present now in all o f Nevada due to our current drought conditions, any act ions to possibly mi nimize the operation of aircraft carrying combustible fuels for aerial photography or surveying and potentially having a mishap is both significant and in the best interest of the publ ic.

The public’s interest is furthered by minimizing potential ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight UAS's. Permitting

me, Jessie R. RichGreer , to immediately fly within national air space furthers economic growth. Granting

my exe mption request positively impacts the economic s of the County of Washoe , from real estate sales, inexpensive aerial surveying and aerial support of the thriving industrial industry which is a major employer and economic engine for Reno and the surroundi ng counties. All of these factors provide a potential economic stimulus to the community.

V. Reasons Why Jessie R. RichGreer ’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Jessie R RichGreer ’s , exemption will not adversely affect safety. Quite the contrary, for the

reasons previously stated permitting me, Jessie R. RichGreer , to log more flight time in FAA controlled airspace, with ongoing communication with the FAA, will allow me to contribute to the continued development and implementation of new and novel, as yet undiscovered safety protocols for the UAS community, promoting growth and safety of this new and vital industry in cooperation with the FAA. In

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition5

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition addition I, Jessie R. RichGreer , submit the following representations of enhancements to current aerial videography and photography for real estate and other opportunities, to illustrate its ben efits :

My UAS weighs less than 5 pounds complete with a small ultra lightweight high quality built

- in camera; I only operate my UAS at or below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); m y UAS only operate s for a maximum of 37 minutes per flight; I will land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by visual line of sight (VLOS); My UAS has GPS flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in a safe environment that is strictly controlled, away from power lines, elevated lights, airports and actively populated areas; I conduct extensive pre

- flight inspections and protocol during which safety carries primary importance; I always obtain all necessary permissions prior to operation
, and I have procedures in place to abort flights in the event of safety breaches or potential danger. I am also very familiar with pre

- flight procedures for both certificated and experimental civil aircraft. I have recently installed a state of the art navigation suite in an expe rimental aircraft and was successful in initializing the system to provide compliance for the upcoming 2020 ADSB FAA mandate for aircraft operating in controlled airspace. I am intimately familiar with the rules and limitations for the safe operation of al l types of aircraft.

My, Jessie R. RichGreer'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 planned environment that helicopters are the pri mary means of aerial video and photography for community

awareness , aerial surveying and real estate.

First, the potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific areas away from mass popul ations. Second, there is no fuel on board a UAS and thus the potential for fire or explosion is essentially eliminated. Third, the small size and extreme maneuverability of my UAS allow s me to remotely pilot away from and avoid hazards quickly and safely. Lastly, the photographic sophistication of the equipment carried on my UAS permits operation from a safe distance.

Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. I will also be carrying a portable aviation radio

to notify any aircraft operating in the vicinity of nearby UAS operations.

VI. A Summary t he FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificate s, 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, Jessie R. RichGreer ’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.6

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, Jessie R. RichGreer'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

cert ificate 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 wherein safety can be defined.

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8 737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827 and many others.

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable in so far 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 certifica tions and registrations by me, Jessie R. RichGreer

B. 14 C.F.R. § 45.23: Marking of th e Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefor e do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two -i nch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark the 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 -c ommercial operations. I, Jessie R. RichGreer , 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, Jessie R. RichGreer , to operate my UAS

meet s and exceed s current safety levels in relation to 14 C.F.R. §6 1.113 (a) & (b).

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition7

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, Jessie R. RichGreer , will however operate my UAS in safe areas away from public and traffic, providing a level of altitude safety at least equivalent to or below those in relation t o 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): M aintenance Inspections.

The above

- cited R egulations 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 discrepancie s 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, Jessie R. RichGreer's , UAS. However, as a safety precaution I inspect my UAS be fore 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 requirement s 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, Clayton J. Inskeep’s , UAS meets an equivalent level of safety p ursuant 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 t he 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.
86 07, 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, Jessie R. RichGreer , seeks a n 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. §

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition8

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, Jessie R. RichGreer's , small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, real estate operations and other opportunities which may present itself. Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger a ircraf t running on combustible fuel, p osing potential risk to the public.

Granting my, Jessie R. RichGreer's , request for exemption will reduce current risk levels and thereby enhance safety. My UAS aircraft does not contain potentially explosive fuel, i s 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 most cases away from controlled airspace eliminating potential public risk flyi ng to and from established airfields.

I, Jessie R. RichGreer , have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate and other commercial usage that exceeds currently accepted means and methods for saf e 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, Jessie R. RichGreer's , UAS and theref ore the likelihood of death or serious bodily injury is significantly diminished. My, Jessie R. RichGreer's , operation of my UAS, weighing less than 5 pounds and traveling at low speeds within limited areas will provide an equivalent level of safety as th at achieved under c urrent FARs. Accordingly I, Jessie R. RichGreer
, 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 lar ge.

Respectfully submitted,

Jessie R. RichGreer
, 4351 Kyle Scott Ct. Sparks NV 89436 ( 858) 366-4225 jgreer@greergrp.com

Attached: Preflight Form and Checklist

Jessie R. RichGreer Reno, NV

– Section 333 Exemption Petition