May 22, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), Irwin

Malzman (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an exemption from the

Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial still photography and video of

homes, properties and vacant land in Southern Nevada. Applicant:

Irwin Malzman

9332 Fontainbleu Dr.

Las Vegas, NV 89145

Attachments

Blade QX350 Training Manual

Yuneec Q500 Training Manual

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR45.23 (b)

14 CFR91.7 (a)

14 CFR91.9 (b) (2)

14 CFR91.103

14 CFR91.109

14 CFR91.119 (c)

14 CFR91.121

14 CFR91.203 (a) and (b)

14 CFR91.405 (al

14 CFR91.407 (a] (1)

14 CFR91.409 (a) (2)

14 CFR91.417 (a) and (b)

Extent of Relief I and Why

14 CFR Part 21 subpart H

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable

liquids. Given the size, weight, speed and limited operating area associated with the aircraft to be utilized, I

request exception. In the restricted environment and under the conditions proposed operation will be at least as

safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions.
14 CFR45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain words

or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would need to

be smaller than required minimums.

14 CFR 91.7 (a)

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

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

use of safety check list prior to each flight an equivalent level of safety will be provided.

14 CFR91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no

room capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will be

maintained by keeping the flight manual at ground control point where the pilot will have immediate

access to it.

14 CFR91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal

procedures including but not limited to; reviewing weather, flight battery requirement, landing and

takeoff distances, along will all of those found in attachment " Pilot Training". An equivalent level of safety

will be provided by preflight protocol to properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through

the use of a control box that communicates with the aircraft via radio communications. The equivalent level

of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the

speed and size of the aircraft.

14 CFR91.113 (a) and (b)

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not

carry a pilot or passengers. While helpful, a pilots' license will not ensure remote control piloting skills.

14 CFR91.121

The UAS may not have a barometric altimeter, but instead does have a GPSaltitude read out. I believe an

exemption may be needed. An equivalent level of safety is achieve by the operator receiving live flight

data monitoring and confirming current altitude along with altitude of launch site shown on GPS

altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and

registration documents on the aircraft. An equivalent level of safety will be achieved by keeping these

documents, to the extent they are applicable to the UAS, at the ground control point where pilot has

immediate access to them.

14 CFR 91.405 (a), 14 CFR91.407 (a) (1), 14 CFR91.409 (a) (2), 14 CFR91.417 (a) and (b)

Given these sections only apply to aircraft with an airworthiness certificates, theses sections do not apply to this

applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working

condition before initiating each flight.
Irwin Malzman is seeking relief from all FARs above preventing applicant from conducting aerial photography

and video of real estate taken at levels less than 400ft, at a speed less than 30 mph, and with a maximum

flight time of less then 30 minutes,. The drone to be used is less then 15 pounds. The weight of the UAS meets

the definition of "small unmanned aircraft" found in section 331. "The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds

much less than it's top speed of 33.5 mph. Due to the UAS being battery powered there are no combustible

fuels onboard. Maximum flight time for this particular UAS is less then 30 minutes. Flights to be terminated with

no less then 25% battery life remaining. Given the size, weight, speed, and limited operating area associated

with the aircraft to be utilized I find this exception to be reasonable with an equivalent or greater level of

safety to be reached by the operator.

Safety

Please see attachment “Pilot Training Manuals" for safety precautions to be use for every flight.

Additionally:

1) Applicant is a Commercially Rate Pilot. Pilot Cert. # 1864187. 2) I will not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport

manager has been made.

3) I will land my UAS prior to manufacturer recommended minimum level of battery power. 4) I will pilot my UAS through remote control by line of sight. 5) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then

slowly lands if communication with the remote control pilot is lost. 6) I actively analyze flight data and other sources of information to constantly update and enhance safety

protocols. 7) I conduct extensive pre-flight inspections and protocol, during which safety carries primary

importance. 8) I always obtain a ll necessary permissions prior to operation. 9) I have procedures in place to abort flights in the event of safety breaches or potential danger.

Public Interest

The use of an UAS in the real estate industry provides both buyers and sellers a higher level of service. For

a buyer a higher level of marketing and advertising is achieved appealing to more buyers, resulting in a

quicker sale of their home. Quicker home sales also helps accelerate the economy as a whole. Buyers

experience the benefit of encompassing a whole property, sometimes several acres, in one photo or a short

video. Not only does this benefit the specific home seller or home buyer, but it benefits the general

public because it is much more efficient than traditional ways of using a plane or helicopter to achieve

the same result. We can now provide this level of service while being conservative with fuel, time, emissions,

noise, and other resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will

poses much less of a safety concern for the general public when compared to manned aircraft.

Thank you for your consideration,

Irwin Malzman