Jim Starwalt 

Star Home Finders, Ltd

402 S. Slusser

Grayslake, IL 60030 

(Office) 847-548-2625 

(Fax)847-231-4625

February 19, 2015 

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

Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103

Following the format of FAA Exemption No. 11138 -Regulatory Docket No. FAA – 2014 – 0481 I have 

included: 

1) Supplemental Response for Petition 

2) PHANTOM Flying Flowchart V1.0, 

3) PHANTOM Quick Start Manual v1.7, 

4) PHANTOM 2 Vision+ User Manual 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, 

Jim Starwalt, a licensed Realtor for 18 years, preparing this exemption request myself, would like to 

apply for an exemption from the following Code of Federal Regulations (C.F.R) to be allowed 

commercial operation of lightweight Unmanned Aircraft Systems (UAS) for aerial imaging and video 

of Northern Illinois communities and homes I list for sale. 

I have own a hobby grade DJI Phantom 2 quad-copter (maximum gross weight 3 pounds, equipped 

with four rotors that are driven by electric motors powered by batteries, the UAS has a maximum 

airspeed of 30 knots) manned only with a Phantom 2 Vision+ Camera for the intent of aerial 

photography/videography to enhance academic community awareness and augment real estate 

listing images and videos; following an exemption and approval by the FAA.

My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote 

control) in predetermined areas away from general public, airports, heliports and vehicular traffic,

daylight hours only, under 300 ft. and after carefully reviewing, inspecting and examining the area of 

aerial observation. This would allow for community and individual homeowner real estate listing 

videos/images within property boundaries . 

I will abide all FAA requirements to ensure this exemption will provide a level of safety at least equal 

to existing rules and will only operate in a safe environment that is strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; and I will conduct extensive 

preflight inspections and protocols, during which safety carries primary importance. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

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

am asking exemption from 14CFRpart21,Subpart H(Airworthiness Certificates)and§91.203 (a) and (b) 

(Certifications required),subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under14CFRpart 11 and Section 333 of P.L. 112-95 

(Section 333). 
14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): 

Size of Marks 

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two -inch 

lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. I understand the need for markings and will mark my UAS in the largest possible 

lettering by placing the word “Experimental” or assigned number or name (based on a request or 

ruling by the FAA ) on its fuselage as required by §45.29(f) so that anyone assisting him as a spotter 

will see the markings. 

I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection of my UAS 

before each flight as outlined in his operating documents. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command. 

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however I can 

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

carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control piloting 

skills. The risks of operating a UAS are far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR part61,et seq., I requests an exemption from §61.113 Private Pilot 

Privileges and Limitations. 

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action 

If granted an exemption I agree to additional safety procedures including, but not limited to: 

1) Keeping my UAS within a radius distance of 1000 feet from the controller to both aid in direct line of 

sight visual observation. 

2) Operate the UAS for 3-7 minutes per flight; land my UAS according to the manufacturer’s 

recommended minimum level of battery power. 

3) Operate my UAS only within visual line of sight (VLOS). Daylight hours only.

4) Use the UAS’s global positioning system(GPS) flight safety feature; it hovers and then slowly lands if 

communication with the remote control. 

5) Conduct all operations under my own personal and flight safety protocols (including posting a warning 

sign reading: “Attention Aerial Photography in Progress –Remain Back 150 feet”). 

6) I will operate and will actively analyze flight data and other sources of information to constantly update 

and enhance my safety protocols. 

7) Contact respective airports if operations will be within 5 miles to advise them of his estimated flight 

time, flight duration, elevation of flight and other pertinent information. 

8) Always obtain all necessary permissions prior to operation. 

9) Have procedures in place to abort flights in the event of safety breaches or potential danger. 

Aerial videography for geographical awareness of real estate marketing has been around for a long time 

through manned fixed winged aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. Granting this exemption would allow me to provide this service at a much lower 

cost. Further, my small UAS, when used properly, will pose no threat to the public given its small size and 

lack of combustible fuel when compared to larger manned aircraft. 

I believe that the use of any tool that increases value to a home or community (by adding visibility to more 

potential buyers) is in the best interest of homeowners nationwide. Selling a home faster and for more 

money because of the use of new technology (being safely used and approved by the FAA) will go a long 

way to ensure our economy continues to grow.