February 12, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

Applicant Information:

The name of the applicant: Master Realty Services Inc.

The primary contact for this application: 

Chester L. “Pete” Porter

Master Realty Services Inc.

18245 Paulson Drive

Port Charlotte, Florida 33954

Master Realty Services Inc. is a corporation formed under the State laws of Florida on 

or about November 19, 1998 and Chester L. Porter is an Officer and Director of Master 

Realty Services Inc.

Pursuant to Section 333 of the FMRA, Master Realty Services Inc. hereby requests a

determination by the Secretary of Transportation authorizing commercial operations of a 

UAS for the purposes of aerial photography & videography, mapping, power line 

surveillance, agricultural crop surveillance, aerial inspections, data collection, 

augmented real estate listings, commercial videos and other work related to aerial 

photography in the NAS. Master Realty Services Inc. does not intend to use it for closed 

set filming. Flight operations will utilize the off the shelf Yuneec family of unmanned 

aircraft. Conduct of UA operations will be with respect to FMRA Section 333(c) and the 

UAS “Blanket COA”.

Exemption is necessary to effect the determination requested pursuant to FMRA 

Section 333. The attached documentation includes detailed exemption requests that 

demonstrate how these exemptions are in the public interest and will maintain at least 

an equal level of safety to existing regulations. Authorizing Master Realty Services Inc.

to conduct commercial UAS operations will result in less disruptive, safer, and more 

cost effective solutions than manned aviation equivalents due to the low altitude 

environment, given the size, speed and inherent risk of traditional commercial helicopter 

operations. These commercial operations often occur in the unsafe areas of the height-
February 12, 2016

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velocity diagram requiring special precision and skill. Master Realty Services Inc. will 

conduct the commercial UAS operation in a manner that will meet, and in many cases 

exceed, the current level of safety of commercial helicopter operations. UA that are

under 10 lbs., have a low noise signature, and carry no volatile fuel, will limit collateral 

damage in the event of catastrophic failure. The low expenses of operation compared to 

cost prohibitive manned aviation alternatives allow a greater economic benefit to 

businesses. For these reasons, granting an exemption under FMRA Section 333(c) is in 

the public interest. UAS technology used for these commercial purposes benefit the 

public interest in the following ways:

・ Reduces the collateral damage risks to life and property associated with low altitude

helicopter operations in undesirable portions of the height-velocity envelope.

・ Increased economic wellbeing to local businesses via cost reductions.

・ Enabling aerial business solutions to be available to a larger market.
February 12, 2016

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Table of Contents

I. Exemptions Requested

II. Commercial Operation/Operator

III. Unmanned Aircraft System (UAS)

IV. UAS Pilot-in-Command (PIC)

V. Public Interest

VI. Summary

VII. List of Attachments

I. Exemptions Requested

Pursuant to 14 C.F.R. § 11.81(e), Master Realty Services Inc. requests exemption from 

the following regulations:

・ 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

Establishes: The procedural requirements for the issuance of airworthiness

certificates as required by 14 C.F.R. § 91.203(a)(1)

Given the small size of the UA and the safeguards that will be taken as outline 

below, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the FMRA with 

consideration “of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS.”

・ 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport, "experimental," or "provisional," as 

applicable.

Master Realty Services Inc. will ensure compliance with § 45.29(f) to meet the 

intent of the regulation by displaying the registration number in the largest 

practicable lettering.

・ 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private 

and Commercial Pilot Privilege and Limitations

14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of 

this section, no person who holds a private pilot certificate may act as pilot in

command of an aircraft that is carrying passengers or property for

compensation or hire; nor may that person, for compensation or hire, act as 
February 12, 2016

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pilot in command of an aircraft. (b) A private pilot may, for compensation or 

hire, act as pilot in command of an aircraft in connection with any business or 

employment

14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a

commercial pilot certificate may act as pilot in command of an aircraft– (ii) For

compensation or hire, provided the person is qualified in accordance with this 

part and with the applicable parts of this chapter that apply to the operation.

14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may

not act as pilot in command of an aircraft:

・ For compensation or hire;

・ In furtherance of a business;

UA operations will employ a PIC who holds, at a minimum, a recreational or sport pilot

certificate of any category or class and a valid driver’s license.

・ 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

No person may operate a civil aircraft unless it is in an airworthy condition.

The PIC will conduct daily pre and post flight inspections in accordance with

manufactures maintenance manual(s) and guidance. During flight, the PIC will 

adhere to § 91.7(b) and abort air operations immediately upon identification of 

an in-flight emergency or other unsafe condition. By complying with 

procedures outlined by the manufacturer, an equivalent level of safety will be 

achieved.

・ 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements

(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any 

combination thereof.

By keeping all operating documents, manuals, authorizations and exemptions 

in a binder co-located with the GCS, Master Realty Services Inc. meet the 

intent of the regulations and therefore achieve an equivalent level of safety.

・ 14 C.F.R. 91.109(a) – Flight Instruction

No person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual 

controls.

The majority of sUAS by design are developed with single operational control 

through the use of pre-determined GPS enabled waypoints programmed 

before or during flight in addition to the use of a single hand held transmitter or 
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control station controlled by the PIC. The design does not allow for dual 

controls during flight training and therefore the exemption is requested to train 

operators, build experience, and maintain proficiency. An equal level of safety 

will be achieved by conducting all training in sterile environments.

Training sessions will be accomplished separately from flights conducted for

compensation or hire.

・ 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (b) Over any congested area of a city, 

town, or settlement, or over any open air assembly of persons, an altitude of 

1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of 

the aircraft. (c) Over other than congested areas. An altitude of 500 feet above 

the surface, except over open water or sparsely populated areas. In those 

cases, the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weightshift-control aircraft. If the operation is conducted without hazard to persons or 

property on the surface —

(1) A helicopter may be operated at less than the minimums prescribed in

paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA.

Commercial UAS operations will be conducted at or below the maximum 

altitude authorized by COA. Given the size, weight and lack of fuel; combined 

with operation limitations listed below, the operation will be conducted with a 

greater level of safety than exists with current manned aviation operations.

・ 14 C.F.R. 91.121 – Altimeter Settings

Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating... SUAS are equipped with Global Positioning System (GPS), 

which provide altitude and geolocation data to the operator without utilizing an 

altimeter. Due to this fact, an exemption is required. GPS are precise within a few feet 

and combined with fail-safes and a visual observer the operation will meet an 

equivalent level of safety.

・ 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

No person may begin a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes;
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This regulation is written based on the capabilities of a traditional aircraft, which 

have

flight times of several hours or greater; therefore, with the majority of sUAS which 

have flight times of only an hour or less, this regulation would effectively deny the 

ability of the air vehicle to operate.

The PIC will achieve an equivalent level of safety by complying with all manufacturer

guidelines and the Yuneec low battery failsafe system.

・ 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Equipment and

Use.

All airspace. Unless otherwise authorized or directed by ATC, no person may

operate an aircraft in the airspace described in paragraphs (b)(1) through 

(b)(5) of this section, unless that aircraft is equipped with an operable coded 

radar beacon transponder having either Mode 3/A 4096 code capability, 

replying to Mode 3/A interrogations with the code specified by ATC, or a Mode 

S capability, replying to Mode 3/A interrogations with the code specified by 

ATC and intermode and Mode S interrogations in accordance with the 

applicable provisions specified in TSO C-112, and that aircraft is equipped with 

automatic pressure altitude reporting equipment having a Mode C capability 

that automatically replies to Mode C interrogations by transmitting pressure 

altitude information in 100-foot increments. This requirement applies—

(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in

appendix D, section 1 of this part from the surface upward to 10,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not

originally certificated with an engine-driven electrical system or which has not

subsequently been certified with such a system installed, balloon or glider may

conduct operations in the airspace within 30 nautical miles of an airport listed 

in appendix D, section 1 of this part provided such operations are conducted-

(I) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area

designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries

of a Class B or Class C airspace area designated for an airport upward to 

10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an

engine-driven electrical system or which has not subsequently been certified 

with such a system installed, balloon, or glider—
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(i) In all airspace of the 48 contiguous states and the District of Columbia at 

and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet 

above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nauticalmile radius of any airport listed in appendix D, section 2 of this part, excluding 

the airspace below 1,200 feet outside of the lateral boundaries of the surface 

area of the airspace designated for that airport.

The sUAS to be used in the proposed operation does not come equipped with a

transponder. No transponder exists for the sUAS, which can be installed. The 

petitioner requests relief from the exemption to the extent required to operate in 

areas in which a transponder is required according the applicable regulations in this 

part.

The PIC will achieve an equivalent level of safety by complying with all provisions of

the COA under which operations are to be conducted. By issuing appropriate 

NOTAMS and prior ATO coordination, an equivalent level of safety can be achieved 

as other manned aircraft, which receive authorization to fly in airspace where a 

transponder is required but not operable. In order to give proper notice to the ATO, 

the PIC will comply with the provisions of 91.215(d)(3). The sUAS flown under this 

exemption will comply with all altitude limits and airport standoff distances required 

by COA, which mitigate hazards to aircraft controlled by the ATO in congested 

airspace.

・ 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance

Inspections

91.405(a) States: Each owner or operator of an aircraft— (a) Shall have that

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

91.407(a)(1) States: (a) No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration 

unless—(1) It has been approved for return to service by a person authorized 

under § 43.7 of this Chapter

91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no

person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had—(2) An inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. No inspection performed 

under paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a person authorized to 

perform annual inspections and is entered as an ‘‘annual’’ inspection in the 

required maintenance records.
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91.417(a) & (b) States: (a) Except for work performed in accordance with §§

91.411 and 91.413, each registered owner or operator shall keep the following

records for the periods specified in paragraph (b) of this section: (paragraphs 1 

(i– iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for

the periods prescribed: (paragraphs 1 – 3)

The PIC will conduct Pre/Post flight inspections and maintenance in accordance with 

the manufacturer’s guidance as stated in the operations manual. If maintenance is 

required, the PIC will conduct a dedicated test flight will be conducted to ensure 

safety before resuming commercial operations. All inspection, maintenance and 

alterations will be documented and maintained in a record. These actions will meet 

the intent of the regulations from which exemption is being requested and lead to an 

equivalent level of safety.

II. Commercial Operator/Operation

Any UA flown under this exemption will be controlled by a certificated PIC. The PIC will 

hold, at a minimum, a recreational or sport pilot certificate.

For each flight, Master Realty Services Inc.:

・ Will contact the controlling air traffic organization to issue a NOTAM.

・ Will conduct a comprehensive worksite inspection and analysis, identifying limits of

customer property or authorized access areas.

・ Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

・ Will operate in those areas only with the consent of the landowner or designated

representative.

・ Will identify potential obstructions or other hazards to safe operation.

・ Will clear the area of personnel or bystanders that are non-essential to the operation,

maintaining at a minimum, 500 feet away from non-participating persons.

・ Will conduct a preflight safety briefing to Visual Observer (VO) and participating

persons.

・ Will at all times yield to manned air traffic.

・ Will operate within VLOS of both PIC and VO during daylight hours only.

・ Will maintain voice communications with VO and participating persons.

・ Will operate under visual flight rules, in visual meteorological conditions, for the 

airspace in which the flight is conducted.

・ Will not exceed the maximum altitude as defined in the COA under which flight

authorized, as determined by the installed GPS.
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・ Will keep operating documents, manuals, authorizations and exemptions in a binder 

collocated with the GCS.

・ Will immediately terminate flight, in the safest manner possible, when safety to 

persons or property become compromised.

・ Will terminate flight, in the safest manner possible, when unable to comply with these

 limitations or any other limitations granted as part of this exemption.

In order to remain at an altitude at or below the attitude prescribed by the applicable 

COA, relief is needed from Section 91.119 (c). By following these operating standards, 

the commercial operation will meet an equivalent level of safety to the regulation in 

which relief is sought.

III. Unmanned Aircraft System

Master Realty Services Inc. seeks exemption to operate Yuneec UAS. Other UAS types 

may be requested in future amendments. The Yuneec Typhoon Q500 4K is the primary 

aircraft in our operation for which we seek exemption. The UA will be flown via a 

combination of RC control and tablet GCS. This UA type is a GPS equipped, multirotor 

helicopter. A quad-copter type rotorcraft utilizing four motors. Lithium-polymer batteries 

power the UA.

The UA also has several fail-safes for loss of RC signal, loss of GPS, and low battery as 

outlined in the respective Operation Manuals. The UA display visual and emit an audible 

low battery alerts at which time the UA will automatically engage the landing sequence. 

Based upon those safeguards, I request exemption from Section 91.151(b) Fuel 

requirements for flight in VFR conditions.

Given the size, weight, speed, and controlled operating area associated with the UA to 

be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) 

and § 91.203 (a) and (b) is requested. Exemption is sought from § 45.23 Marking of the 

aircraft. The UA will display the registration number in the largest practicable lettering. 

Master Realty Services Inc. seeks to be exempt from § 91.405(a), 91.407(a)(1), 

91.409(a)(2) and 91.417(a) and (b) Maintenance inspections will be conducted according 

to operations manual and prudent judgment as previously outlined to determine the 

integrity and safety of the UA and associated equipment. Further, relief is required from 

91.7(a), which prohibits the operation of an aircraft without an airworthiness certificate 

and 91.9(b) (2) requiring an approved flight manual in the aircraft. The UA will not be 

operating with an airworthiness certificate therefore, this would be inappropriate. The 

UAS are too small to carry the operating documents so an equivalent amount of safety 

can be achieved through keeping the operating documents and manuals at the GCS.
February 12, 2016

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IV. UAS Pilot in Command (PIC)

Under part § 61, recreational, sport and private pilots are limited to non-commercial 

operations, however Master Realty Services Inc. can ensure UA operations will achieve 

an equivalent level of safety as current regulation because UA do not carry any pilots or 

passengers. A commercial pilot certificate will not ensure RC piloting ability, as the 

psychomotor skills are different. The inherent risks of operating a UAS are far less than 

in the commercial activities outlined in 14 CFR part 61, et seq., thus exemption is 

requested from § 61.101 Recreational Pilot Privileges and Limitations. PICs will maintain 

recent flight experience on the UAS. Training and experience flights will be conducted 

separate from commercial operations.

V. Public Interest

Given the above stated evidence, procedures, and precautions operating UAS 

commercially for the purposes of aerial photography & videography, mapping, power 

line surveillance, agricultural crop surveillance, aerial inspections, data collection, 

augmented real estate listings, commercial videos and other work related to aerial 

photography will ultimately be in the public interest. These operations, when executed 

with prudence, will exceed the current level of safety as the regulations from which 

exemption is sought. UA operations will allow greater access to commercial aerial 

services that were not previously economically feasible for many firms. This will provide 

a much needed economic uplift to the community and hence the public. UA operations 

are associated with less risk of collateral damage to persons and property while limiting 

disruptive noise pollution associated with low altitude aviation operations.

VI. Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and 

Reform Act of 2012”, Master Realty Services Inc., hereby applies for authorization to 

conduct commercial unmanned aerial systems (UAS) operations for the purposes of 

aerial photography & videography, mapping, power line surveillance, agricultural crop 

surveillance, aerial inspections, data collection, augmented real estate listings, 

commercial videos and other work related to aerial photography listings Rules for which 

exemption is sought:

・ 14 C.F.R. Part 21 Subpart H

・ 14 C.F.R. § 45.23(b)

・ 14 C.F.R. § 61.101, 61.113 and 61.133(a) (1)(ii)

・ 14 C.F.R. § 91.7(a)

・ 14 C.F.R. § 91.9(b)
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・ 14 C.F.R. § 91.103

・ 14 C.F.R. § 91.109(a)

・ 14 C.F.R. § 91.119

・ 14 C.F.R. § 91.121

・ 14 C.F.R. § 91.151(a)

・ 14 C.F.R. § 91.215(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. § 91.417(a) & (b)

VII. Attachments:

1. Specific UAV manuals.

a. Yuneec Typhoon Q500 4K User Manual V2 Pages 1 – 15

b. Yuneec Typhoon Q500 4K User Manual V2 Pages 16 – 38

Thank you for your prompt attention and consideration. Master Realty Services Inc. is 

committed to safe UAS operation and ambassadors. Please do not hesitate to contact 

me directly with any questions or concerns at 941-206-2200.

Very truly yours,

Master Realty Services Inc.

Chester L. “Pete” Porter, President

Pete.Porter@ConsultEngineering.com

Enclosures: Yuneec Typhoon Q500 4K User Manual V2