June 27, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 205590

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	Ma’am,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR

Part 11, Darren	Galerkin, private pilot, and operator of Small Unmanned Aircraft Systems ("UAS")

equipped to conduct aerial photography for the education of real estate professionals and real estate

marketing purposes, hereby applies for an exemption from the listed Federal Aviation Regulations

("FARs") to allow commercial operation of its “UAS,” so long as such operations are conducted within

and under the conditions outlined herein or as may be established by the FAA as required by Section

333.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive UAS (DJI Inspire 1 and DJI Phantom 3 Pro) under controlled

conditions in airspace that is 1) limited 2) predetermined and 3) controlled as to access. Approval of this

exemption would thereby fulfill the Secretary of Transportation's (the responsibilities to " ... establish

requirements for the safe operation of such aircraft systems in the national airspace system." Section

333 (c) of the Reform Act.

Sincerely,

Darren	Galerkin

5101	Balboa	Blvd.	

Apt.	106

Encino,	CA	91316
I. CONTACT INFORMATION:

Darren	Galerkin

5101	Balboa	Blvd.	

Apt.	106	

Encino,	CA	91316

(323)	481	2510

Email: dgalerkin@gmail.com

Private Pilot FAA: 3382870			11/19/2008

II. THE SPECIFIC SECTIONS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS FROM

WHICH DARREN	GALERKIN	REQUESTS EXEMPTION ARE:

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14CFR91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing Section

333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the national

airspace system (NAS) before completion of the rulemaking required under Section 332 of

the Reform Act. In making this determination, the Secretary is required to determine which

types of UAS do not create a hazard to users of the NAS or the public or pose a threat to

national security in light of the following:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and
• Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers.

Reform Act §333 (a). Lastly, if the Secretary determines that such vehicles "may

operate safely in the national airspace system, the Secretary shall establish

requirements for the safe operation of such aircraft in the national airspace

system." Id. §333 (c) (emphasis added). The Federal Aviation Act expressly grants

the FAA the authority to issue exemptions. This statutory authority by its terms

includes exempting civil aircraft, as the term is defined under §401 01 of the Act;

that includes UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate. The Administrator may grant an exemption from a

requirement of a regulation prescribed under subsection (a) or (b) of this section or

any sections 44702-44716 of this title if the Administrator finds the exemption in

the public interest. 49 U.S.C. §44704; 14 CFR §91.203 (a) (1).

Darren	Galerkins’ UAS(s) are small rotorcraft aircraft, the DJI Inspire 1, weighing less than 10

lbs. including sensor payload	and	DJI Phantom	3	Pro, weighing less than 10 lbs. including

sensor payload. They operate their rotorcraft, under normal conditions at a speed of no

more than 20 knots, usually 3-5 knots, and have the capability to hover, and move in the

vertical and horizontal plane simultaneously. They will manually operate only in Visual Line

of Sight and will operate only within the operating parameters as described in

the Operating Manuals attached as Attachment 1.

Adherence to the Operating Manual will insure that the UAS will "not create a hazard to the

national airspace system or the public."

Given the small size and weight of the UAS involved and the restricted sterile environment

within which they will operate, the applicant falls squarely within that zone of safety (an

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption,

allow commercial operations of UAS to commence immediately. Also due to the size of the

UAS and the areas in which the relevant UAS will operate, approval of the application

presents no national security issue. Given the clear direction in Section 333 of the Reform

Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent

level of safety, surrounding the proposed operations, and significant public benefit,

including enhanced safety, reduction in environmental impact, including reduced emissions

associated with allowing UAS for educational and marketing operations, (as opposed to full

scale aircraft), the granting of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption

without delay.

III. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The applicant proposes that the exemption requested herein apply to civil aircraft that have

the characteristics and that operate with the limitations listed herein. These limitations

provide for at least an equivalent or possibly higher level of safety to operations under the

current regulatory structure because the proposed operations represent a safety

enhancement to the already safe filming operations conducted with conventional aircraft.

These limitations and condition to which Darren	Galerkin agrees to be bound when

conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh less than 10 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew

(Spotter I Observer).

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL, though most

operations will be conducted within 50 feet of the ground.

5. Minimum two (2) man crew for each UAS operation will consist of the Pilot and Spotter I

Observer. In most cases the third aircrew member will serve as the Safety Officer.

6. The UAS Pilot will be an FAA licensed airman with at least a private pilot's certificate and

third class medical and valid driver's license.

7. The UAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder, other than the

UAS Pilot, possesses the necessary PIC qualifications and is also present, that person can

also be designated as PIC.

8. The UAS will only operate within an area of Los	Angeles	and	surrounding	counties.

9. Additionally, the UAS will only operate less than 400ft AGL.

10. The UAS will never enter any MOA or Restricted Airspace, nor shall it violate any TFR as

outlined by the FAA.

11. A pre-flight briefing will be conducted in regard to the planned UAS operation prior to each

day's flying I recording activities. It will be mandatory that all personnel who will be

performing duties as "flight crew" be present for this briefing.

12. Pilot and Spotter (Observer) will have been trained in operation of UAS generally and

received up-to-date information on the particular UAS to be operated as required.

13. Spotter (Observer) and Pilot will at all times be able to communicate by voice or radio.
14. Written and/or oral permission from the relevant property holders will be obtained.

15. If the UAS loses communications or loses its GPS signal, the UAS will have capability to

return to a pre-determined location and land.

16. The UAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

17. Pilot will abide by all California Aviation regulations (Aircraft Operations).

a. The UAS Pilot in Command (PIC) shall possess at a minimum, a private pilot certificate

and current third-class medical certificate.

i. The PIC shall also meet the flight review requirements specified in 14 CFR

§61.56 in an aircraft in which the PIC is rated on their pilot certificate.

ii. The PIC shall be trained in the operation of the specific make and model of the

UAS being piloted and successfully completed all training required.

iii. The PIC shall have accumulated and logged, in a manner consistent with 14 CFR

§61.51 (b), a minimum of200 flight cycles and 25 hours of total time as a UAS

rotorcraft pilot and at least five hours logged as a UAS pilot with a similar UAS

type (multirotor or helicopter). Prior documented flight experience that was

obtained in compliance with applicable regulations may satisfy this

requirement.

iv. The PIC shall have accumulated and logged, in a manner consistent with 14 CFR

§61.51 (b), a minimum of five hours as UAS pilot operating the make and model

of UAS to be utilized for operations under the exemption and three take-offs

and three landings in the preceding 90 days.

v. Training, proficiency, and experience-building flights can also be conducted

under this grant of exemption to accomplish the required flight cycles and flight

time.

1. During training, proficiency, and experience-building flights, all persons

not essential for flight operations are considered non-participants, and

the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR §91.119.

b. The UAS Safety Observer (SO) shall meet all training requirements and be responsible

for all of his/her duties as set forth by UAS Operating Manuals.
c. The PIC and SO will be designated before each flight.

i. Minimum crew for each flight operation will consist of the UAS PIC and SO.

d. The PIC and SO shall always be within visual line of sight (VLOS) of each other and in

direct verbal communication at all times.

e. Safety Briefings shall be conducted before each day's activities to include, but not

limited to:

i. Designated roles of PIC and SO

ii. Risk Management and Mitigation

f. Liability Insurance

i. General Liability Insurance shall be maintained in the amount of

1,000,000/100,00

0.

IV. DJI INSPIRE 1

Model T600

Weight (Battery Included) 6.47 lbs.

Hovering Accuracy:

Vertical 1.6 feet

Horizontal 8.2 feet

Max Angular Velocity 150°/s

Max Tilt Angle 35°

Max Ascent Speed 16.4 ft/s

Max Decent Speed 13.1 ft/s

Max Speed 42 kts

Max Flight Time 18 minutes

Operating Temperature Range 14° F - 104°

Dimension 18"x18"x12"

V. DJI Phantom 3	Pro

Model 

Phantom	3	Pro

Weight (Battery Included) 1280	g.

Hovering Accuracy:

Vertical +/- 0.1m

Horizontal +/- 1.5m

Max Angular Velocity 150°/s

Max Tilt Angle 35°
Max Ascent Speed 16.4 ft/s

Max Decent Speed 11.1 ft/s

Max Speed 32 kts

Max Flight Time 23 minutes

Operating Temperature Range 14° F - 104°

Dimension 15 1/4 x 8 1/2 x 14 1/4

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The

Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA
exempt aircraft from the requirement capability, and proximity to airports and populated areas of the

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional aircraft (fixed-wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The UAS(s) to be operated hereunder are less than 10 lbs. fully loaded, carries neither a pilot nor

passenger, carries no explosive materials nor flammable liquid fuels, and operates exclusively within a

limited radius area as set out in the preflight briefing I VLOS operations. Unlike other civil aircraft,

operations under this exemption will be tightly controlled and monitored by both the Operator,

pursuant to safety requirements, and under the requirements and in compliance with local public safety

requirements, to provide security for the area of operation as is now done with conventional aircraft.

These safety enhancements, which already apply to civil aircraft operated in connection with video

production, provide a greater degree of safety to the public and property owners than conventional

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly,

application of these same criteria demonstrates that there is no credible threat to national security

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials

or flammable liquid fuels, and inability to carry a substantial external load.

14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:

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", "lightsport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be

placed. Given the size of the sUAV, two inch lettering will be impossible. The word "Experimental" will

be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by

§45.29 (f) where the Pilot, Spotter (Observer) and others working with the sUAV will see the

identification of the UAS as "Experimental." The FAA has issued the following exemptions to this

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b):

Private Pilot Privileges and Limitations - Pilot in Command (PIC) Sections 61.113 (a) & (b) limit private

pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed
operations can achieve the equivalent level of safety of current operations by requiring the PIC operating

the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this small

UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled

with no living thing on board. The area of operation is controlled and restricted, and all flights are

planned and coordinated in advance as set forth in the Operating Manual. The level of safety provided by

the requirements included in the Operating Manual meets that provided by single individual holding a

commercial pilot's certificate operating a conventional aircraft. The risks associated with commercial

operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested

with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

14 CFR §91.7 (a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the

requirements contained in the Operating Manual for maintenance and use of safety checks prior to each

flight, as set forth in the Operating Manual, an equivalent level of safety will be provided.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 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.

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry

such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the Operating Manual at the ground control

point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167,

10167A 10602, 32827, and 10700

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption

will be needed. An equivalent level of safety will be provided as set forth in the Operating Manual. The
PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff

distances and aircraft performance data before initiation of flight.

14 CFR §91.109: Flight Instruction

Section 91.103 provides that 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. UAS and

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that communicates with the aircraft via radio

communications. The FAA has approved exemptions for flight training without fully functional dual

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemptions Nos.

5778K & 9862A. The equivalent level of safety provided by the fact that aircraft will be piloted by a

certified private pilot who has previously trained in remote flight areas before attempting flight within

filming distance of structures.

14 CPR § 91.119: Minimum Safe Altitudes

Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption

is for a UAS, Darren	Galerkin requests authority to operate at altitudes up to 400 ft. AGL; an exemption

may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than

400 ft. AGL. It will however be operated in a controlled area where buildings and people will not be

exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as location

where it is operated. No flight will be taken without the permission of the property owner. Because of

the advance notice to the property owner and participants in the photographic activity, all affected

individuals will be aware of the planned flight operations as set forth in the Operating Manual.

Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 10 lbs.

proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than

those presently presented with conventional aircraft operating at or below 500 ft. AGL. In addition, the

low-altitude operations of the UAS will ensure separation between these small UAS operations and the

operations of conventional aircraft that must comply with Section 91.119.

14 CPR § 91.121 : Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an

altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting

available before departure." As the UAS will not have a barometric altimeter, but instead a GPS altitude

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator,

pursuant to the Operating Manual and Safety Check list, confirming the altitude of the launch site shown

on the GPS altitude indicator before flight.
14 CPR §91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "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; or (2) At night, to fly after that for at least 45 minutes."

The battery powering the UAS provides approximately 20 minutes of powered flight. To meet the 30

minute reserve requirement in 14 CFR §91.151, UAS flights would be impossible. Given the limitations

on the UAS's proposed flight area and the location of its proposed operations within a predetermined

area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions.

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners

or official representatives who have signed waivers will be allowed, with less than 30 minutes of

reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given

the size and speed of the small UAS. Additionally, limiting UAS flights would greatly reduce the utility for

which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or

25% of battery power whichever happens first. This restriction would be more than adequate return the

UAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 57 45, 1 0673,

and 10808.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate ...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (b)

of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew.
The UAS fully loaded weighs no more than 10 lbs. and is operated without an onboard Pilot. As such,

there is no ability or place to carry certification and registration documents or to display them on the

UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the Pilot flying the UAS will have immediate access to them, to the extent they are applicable to

the UAS, and should they be issued. The FAA has issued numerous exemptions to this regulation. A

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797,

9797A, 9816A, and 10700.

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "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 ... ," and

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the applicant. Maintenance will be accomplished by the operator; pursuant to

the Operating manual. An equivalent level of safety will be achieved because these small UAS are very

limited in size and will carry a small payload and operate only in restricted areas for limited periods of

time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than

400 ft. AGL. As provided in the Operating Manual, the PIC (operator) will ensure that the UAS is in

working order prior to initiating flight, and perform required maintenance. Moreover, the operator is

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety.

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed: Applicant seeks an exemption from the following

rules: D 14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 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) (2)

and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (51bs or less) in Educational and

Marketing operations.

Privacy

All flights will occur over private or controlled access property with the property owner's prior consent

and knowledge, or over remote public land. Image capture of people will rarely take place, but in the

event they are, they will have consented prior to being filmed or otherwise have agreed to be in the

area where data collection will take place.

Airborne Image Capture

With regard to airborne filming, Darren	Galerkin adheres to all FAA regulations. Further Darren	Galerkin

airborne teams operate under the principals of: Safety First, Quality Assurance, Accountability,
Reporting, and Training. When approved by the FAA it is Darren	Galerkins’ mandate to treat all UAS

operations the exact same level of professionalism and seriousness as that of conventional aircraft.

Approval of exemptions allowing commercial operations of UAS in the real estate industry will enhance

safety by reducing risk. Conventional filming operations, using turbine or piston powered aircraft

present the risks associated with vehicles that weigh in the neighborhood of 2,0001bs.+, carrying large

amounts of Jet A or 100 LL (60 gallons for the aircraft primarily used by Darren	Galerkin). Such aircraft

must fly to and from photographing location. In contrast, a UAS weighing fewer than 10 lbs. and

powered by batteries eliminates virtually all of the risk given the substantial reduced mass and lack of

combustible fuel carried on board. The UAS is typically transported to the location via auto or cargo van

in a medium sized case and is never flown to set. The UAS will carry no passengers or crew and,

therefore, will not expose them to the risks associated with manned aircraft.

The operation of small UAS, weighting less than 10 lbs., conducted in the strict conditions outlined

above, will provide an equivalent level of safety supporting the grant of the exemptions requested

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile

environment and, as a result, are far safer than ground than conventional operations conducted with

piston helicopters or fixed wing aircraft operating in relatively close proximity to the ground and people.

The primary market of interest for Darren	Galerkin	utilizing UAS is the marketing of real property, and

the second is the education of real estate professionals.

It is anticipated that the airborne image capture process will be accomplished exclusively in day time

VFR environments. To capture the highest quality of resolution the majority of airborne data collections

will take place during the 07:00am- 07:00pm (19:00) window.

V. Summary

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012- size, weight, speed,

operating capabilities, proximity to airports and populated areas and operation within visual line of sight

and national security- provide more than adequate justification for the grant of the requested

exemptions allowing commercial operation of applicant's UAS in the real estate industry pursuant to the

Operating Manual appended hereto. Darren	Galerkin is eagerly standing by to support the FAA and UAS

community in its quest to establish proper regulations and protocols for the safe introduction of

unmanned aircraft into the national airspace.

Sincerely,
Darren	Galerkin

323	481	2510