Jim Starwalt Star Home Finders, Ltd 402 S. Slusser Grayslake, IL 60030 (Office) 847

- 548

-2625 (Fax)847

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-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 F lowchart 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 1 8 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 lightwei ght 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 m aximum 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 ul tra

- 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 act ively 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: A irw**  **orthiness 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 b e 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 p rivileges 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. W hile 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 A ction**  If granted an exem ption I agree to additional safety procedures including, but not lim ited to: 1) Keeping m y U AS 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 m inutes per flight; land m y UAS according to the m anufacturer’s recommended m inim um level of battery power. 3) Operate m y UAS only within visual l ine 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 rem ote control. 5) Conduct all operations under m y own personal and flight safety p rotocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Rem ain Back 150 feet”). 6) I will operate and will actively analyze flight data and other sources of inform ation to constantly update and enhance m y safety protocols. 7) Contact respective airports if operations will be within 5 m iles to advise them of his estim ated flight tim e, flight duration, elevation of flight and other pertinent inform ation. 8) Always obtain all necessary perm issions 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 tim e through m anned fixed winged aircraft and helicopters , but for s ma ll business owners, its expense has been cost

- prohibitive. Granting this exem ption would allow m e to provide this service at a m uch lower cost. Further, m y sm all UAS, when used properly, will pose no threat to the public given its sm all size a nd lack of combustible fuel when com pared to larger m anned aircraft. I believe that the use of any tool that increases value to a hom e or community ( by adding visibility to m ore potential buyers) is in the best interest of hom eowners nationwide. Selling a hom e faster and for m ore money because of the use of new technology (being safely used and approved by the FAA) will go a long way to ensure our econom y continues to grow.