Brian DeBoer 4420 Friesian Court Dorr, Ml 49323 BrianDeBoerRealtor@gmail.com 616-293-3645 cell phone

US Department OfTransportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the reform act) and CFR Part 11; I, Brian DeBoer, owner and operator ofSmall Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that I, Brian DeBoer may operate UASs commercially in airspace regulated by the FAA., as long as such operations are conducted within and underthe conditions outlined herein oras maybe established bythe FAA as required by Section 333. I, Brian DeBoer, am a Real Estate agent with City2Shore Real Estate located in Hudsonville, Michigan. Iam requesting exemption from regulations listed belowto perform aerial photography and videography of Real Estate and Landscape. All operations will be performed with the public's safety and right to privacy safe guarded at all times.
Brian DeBoer's UASs is a rotorcraft weighing less than 55 pounds including payload (The DJI Phantom 3Vision Quad Copter). It operates at aspeed less than 50 knots and has the capabilityto hover and move in the vertical and horizontal plane simultaneously. It has an auto return to launch point when battery power is under25%. The UAS will operate within the line ofsight with in a protected flight area as described below and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users ofthe nation airspace, public northe environment.

I, Brian DeBoer, respectfully request the grant ofan exception to the following specific sections oftheTitle 14 Code of Federal regulations allowing itto operate lightweight UASs forcommercial use,
14 CFR 21, subpart H, 14 CFR 45.23 (b) 14CFR 91.7 (a), 91

.9 (b) (2) 91

.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

I, Brian DeBoer submits this application in accordance with the Reform Act ,112 P.L. 95 331-334, seeking relieffrom any currently applicable FAR'S operatingto prevent Brian DeBoer future commercial use ofsmall UASs to operate in the national airspace systemas described below. The reform Act section 332 provides forsuch integration ofcivil unmanned aircraft into our national airspace system as it is in the public's interestto do
so. Brian DeBoer's UASs meetthe definition of "small unmanned aircraft" as defined in Section 331 and thereforthe integration ofthese UASs are expressly contemplated by the Reform Act. I, Brian DeBoer, would like to operate its light weight UASs priortothe time period bywhich the Reform Act requires the FAA to promulgate rules governing such aircraft.
The Reform Act directsthe Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 ofthe reform Act. In making this determination, the Secretary ofTransportation is required to determine which UASs do create a hazard to users ofthe national airspace system orthe public or pose athreatto national security in light ofthefollowing:

The UASs size, speed, weight and operational capability Operation ofthe UASs in close proximityto airports and populated areas Operation ofthe UASs within visual line ofsight ofthe operator
Reform Act 333(a). Ifthe secretary determinesthat such vehicles "may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.

DJI Phantom 3s are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots and have the capabilityto operate in the vertical and horizontal plane simultaneously. The UASs will operate onlywithin the line ofsight ofthe operator within a protected flight area and at 200feetAGL or less

.These will not present a hazard tothe national airspace northe public.
The very small nature ofthese UASs combined with the safe guards presented below, will allowforthe safe operation greaterthan that envisioned by Congress forthe FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudestheywill operate approval ofthis exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact ofgreatly reducing the cost ofaerial photographythereby benefitingthe greater public's interest. Accordingly, the applicant requests thatthe FAA grantthe requested exemption without delay.
The following will be considered as the binding limitation on operations of Brian DeBoer,1. Flights will only occur in the daytime hours, 2. Flights will be operated in the line ofsight ofthe operator( PIC) and Observer,(VSO) 3. Flights will be terminated at any time weather and wind deteriorateto "unsafe for flight" by manufacturers recommendations, 4. The UASs will weigh less that 55 lbs., 5. Flights will be operated at 200 feet AGL or less. 6. Crew will be at a minimum ofoperator(PIC) and an observer and/orcamera operator(VSO), 7. Operator and crew will remain in contact duringtheflight operation, 8. The UASs operator will perform acheck ofthe flight area and make certain ofthe safety ofall persons in the area, 9. Consent will be obtained from all persons with in the video capabilities ofthe unitsto further reduce the chance ofviolating anyone's privacy. 10. All required FAA clearances, will be obtained and distances from airports strictly observed. 11. All UASs will have the capability to return automaticallyto the operator in asafe
mannerwith the auto return function checked and working. 12. When operated in conjunction with fishing vessels in the gulf, achase boat will be assigned to operate the UASs at asafe distance from the main fishing boat. 13. Flights will only operate in VFR conditions. 14. UASs have afunction on the control totell operatorthe distance awayfrom the operator and its battery power remaining. 15. Flightteam will communicate byvoice and the use oftwo-way radio ifthe area is too big to hearvoice from all team members. 16. UASs will be used to video private outings and functions, boating, jetskiing, kayaking, fishing trips in the gulfarea and sporting events from asafe distance. 17. When operating over or near waterthe UASs will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure tothe water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined
area ofoperations for Brian DeBoer's UASs flights permits exception from Part 21 because they meet an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAA to exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. Brian DeBoer's USAs meets or exceeds each ofthese elementsAs of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA forflights at or under 200 AGL to any UASs operatorwith asection 333 exemption.
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Because the sUAS in unmanned and will not carry a pilot or passengers, the proposed operations can achieve a high level of safety ofoperation withoutthe required pilot license.

14CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable forthe same reasons stated above.

14CFR91.7 (a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable.
14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft
14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UASs this regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining such certifications and registrations at ME Drone Video LLC operations center.
The FAA has previously issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827

.

14CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. ME Drone Video LLC will only operate its UASs at or below 200AGL. They will be operated on awill defined AOR that has been carefully reviewed for hazards and minimizes the presence ofany persons not essential forthese operations. Flights will only be over private propertythatthe owner has consented and all persons within this video area also give consent forthis filming. Compared toflight operations ofconventional and traditional aircraft or rotorcraft weighingfar more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present afar smaller risk to the public.

Approval ofthese 333 Exemptions allowing commercial operations ofsmall UASs in the service ofaerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use ofsmall UASs of55 lbs. or less, battery operated and fling below 200 feet AGL the risk of injury ofpeople on the ground orthe crew has been reduced or almost erased. The granting ofthe use ofthese small UASs by Brian DeBoer will give potential sellers of Real Estate acompetitive edge in the market place.

### Granting Brian DeBoer the above exemption will allow forthe expansion of UAS systems intothe future forthe safe conduct offree enterprise and the enjoyment ofthe masses. I, Brian DeBoer, respectfully requests the FAA grant its exception without delay. The FAA has the authorityto issue the exemption sought by Brian DeBoer pursuant tothe Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely



# ~ Brian DeBoer Realtor