Docket Management System

U.S. Department of Transportation

1200 New Jersey Avenue, SE Washington, D.C. 20590

In re: Petition of Open Houses of Oklahoma, LLC for Exemption Pursuant to Section

333 of the FAA Reform Act of 2012

Dear Sir or Madam:

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

14 C.F.R. Part 11, Open Houses of Oklahoma, LLC, referred to hereafter as

Openhouseok.com, a real estate advertising company based out of Norman, OK is

petitioning for an exemption from the Federal Aviation Regulations (FARs) pertaining to

the following described unmanned aircraft systems (UAS).

Openhouseok.com respectfully submits the following petition for exemption from the

listed FARs described in detail below as to allow for safe commercial operation of its

UAS.

Openhouseok.com plans to use the small, safe, and commonly used DJI Phantom 2

Vision +, DJI Phantom 3 Professional, and the DJI Inspire 1 for the purpose of

producing videography and photography in order to market real estate. In the event that

a grant is provided by the FAA, Openhouseok.com is fully committed to abiding by the

31 conditions and limitations (attached at the end of this document as “Conditions and

Limitations”) expressed in Exemption No.’s 11213 (Aeryon Labs, Inc.) and 11341 Bob

Sokoler (The Sokoler Medley Team RE/MAX), and other recent grants made for similar

requests.

Openhouseok.com plans to use UAS in order to capture aerial video and photographs

for the purpose of enhancing real estate listings. By allowing Openhouseok.com to

transition to utilizing UAS by way of exemption, the FAA will provide Openhouseok.com

with the capacity to transition to safer methods for capturing aerial photos that are more

economically accessible to the communities we serve, more environmentally friendly,

and safer because of their light weight, lack of combustible fluids, and not having to

carry human occupants. We believe that having the opportunity by way of a granted

exemption to positively impact economic growth, the environment, as well as the overall

safety of the communities we serve is in the public’s best interest. Our operations will

undoubtedly inspire the public through opening economic opportunities in the

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communities we serve. By using UAS, we will be able to completely eliminate the

possibility of a large airborne vehicle crash while conducting our operations. This makes

our operations safer to people and property.

Openhouseok.com provides real estate marketing solutions to thousands of clients

throughout the Oklahoma marketplace. Having been in business since 1999,

Openhouseok.com has a great deal of experience in the segment it seeks to apply the

use of UAS. We are fully capable of deploying UAS for commercial purposes in a safe

and controlled manner in order to minimize risks. We will deploy UAS with complete

cooperation and permission from property owners.

The UAS we planned to use as mentioned above are the DJI Phantom 2 Vision +, DJI

Phantom 3 Professional, and the DJI Inspire 1. All three devices are commonly used

and have the most advanced safety features available. All three UAS are small and the

design, operational characteristics, and specs for each type are attached as separate

documents

Openhouseok.com requests to be designated as the PIC. Our organization has

employees who have extensive experience operating UAS. We have owned and

operated DJI UAS and have accumulated many hours of flight time during recreational

flights since the technology first became available.

Openhouseok.com will insure that flight training will be completed in order to obtain a

sport pilot certificate for any designated PIC. All of our real estate photography

experience is in geographical areas similar to those we will be using UAS commercially.

An Openhouseok.com PIC will be accompanied by a designated visual observer (VO).

As the owner of Openhouseok.com and experienced operator of the exact models UAS

to be used commercially, our organization is uniquely qualified to assist as a VO during

flights to ensure safety of surrounding people and property. As the owner of

Openhouseok.com, he is also fully committed to ensuring safe and productive UAS

operations articulated in the following section.

Openhouseok.com will incorporate thorough safety policies and operating procedures.

The three UAS listed above will be flown in adherence to supplemental information

entitled “Conditions and Limitations” along with the following restrictions:

1. The PIC will obtain a sport pilot certificate along with 35 hours total flight time with

each UAS used for commercial purposes

2. The PIC will maintain a valid U.S. driver’s license

3. No flight will exceed 400 ft AGL

4. Airspeed of UAS will not exceed 20 knots

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5. All flights will be restricted to 55 lbs gross weight or less

6. All flights conducted will have a pilot in command and a visual observer

7. UAS will be operated within visual line of sight at all times

8. UAS will be operated over private property with the permission of the owner

9. UAS will not be operated over any groups of persons other than the PIC and VO

10. UAS will only be operated in daylight hours and clear weather conditions

11. A thorough inspection of the UAS operational readiness will be conducted before

each flight in accordance with manufacturer’s recommendations. All recommendations

can be found in the documents attached separately

12. A flight plan will be drafted before each operation and reviewed by the PIC and VO

13. The PIC and VO will conduct an area sweep where each operation is to be

conducted to ensure a safe environment

14. The PIC and VO will have on their persons the necessary documents needed to

verify legality of operation

15. The PIC will keep flight records in order to stay in line with manufacturer’s

recommendations for maintenance and replacement standards

16. UAS will not be operated within 5 nautical miles of an airport

17. UAS will not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud

18. PIC will abort any flight operation where conditions become unpredictable or in the

case of an emergency

19. UAS will not operate without a clear connection to GPS stability

20. All manuals for each UAS being operated will be available and on hand to the PIC

and VO any time the UAS is operating

21. The PIC will operate the UAS from a stable position and will not operate from a

moving vehicle or while traversing hazardous terrain

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Contact Information:

Mark McGuire

Open Houses of Oklahoma LLC

2334 N. Interstate Dr.

Norman, OK 73072

(405) 364­4776

markm@openhouseok.com

The specific section or sections of 14 CFR from which you seek an exemption;

14 CFR: parts 21;

45.23(b);

45.29;

61.113(a);

91.7(a);

91.9(b)(2);

91.103;

91.109(a);

91.119;

91.121;

91.151(a);

91.203(a) and (b);

91.405(a);

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91.407(a)(1);

91.409(a)(2);

91.417(a) and (b).

The extent of relief you seek and the reason you seek the relief;

Openhouseok.com respectfully submits this petition in accordance with Reform Act, 112

P.L. 95 §§ 331­334, seeking relief from any currently applicable federal aviation

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regulations FARs pertaining to UAS and operating to prevent Openhouseok.com from

commercial photographic flight operations within the U.S. national airspace system. The

Reform Act in § 332 provides for such integration of civil UAS into our national airspace

system as it is in the public’s interest to do so. Openhouseok.com’s small and

lightweight UAS, not exceeding 7 lbs, meet the definition of “small unmanned aircraft”

as set forth in § 331. Openhouseok.com’s light weight UAS are in line with the Reform

Act and would be good candidates for exemption.

Openhouseok.com requests exemption to use its UAS to capture videography and

photography for real estate listings. We understand that the FAA is committed to safely

integrating UAS into national airspace and believe that Openhouseok.com would be a

strong candidate for exemption because of our experience level, commitment to safe

operating procedures, and desire to further educate the public about safe use of UAS by

way of example.

Safety is Openhouseok.com’s primary focus and we requests you also consider the

following:

a. The size and weight of our UAS are under 7 lbs

b. Our UAS travel at low speeds always less than 20 knots

c. Our UAS are outfitted with the most up to date safety and fail safe features

d. The PIC for Openhouseok.com is a very experienced UAS operator

e. Openhouseok.com will strictly adhere to all 31 of the “Conditions and Limitations”

applied to

recent grants for similar petitions as outlined at the end of this petition

f. Openhouseok.com will strictly adhere to the additional 22 stipulations as outlined

above

Openhouseok.com request exemption from the following specific regulations:

14 C.F.R Part 21 Certification Procedures for Product and Parts, Airworthiness

Certificates

The FAA is authorized to exempt UAS from the requirement for an airworthiness

certificate upon consideration of the size, speed, weight, operational capability,

proximity to airports and populated areas, and whether operation within visual line of

sight does creates a hazard to users of the national airspace system or the public.

Because Openhouseok.com plans to use three small UAS (DJI Phantom 2 Vision +, DJI

Phantom 3 Professional, and DJI Inspire 1) weighing no more than 7 lbs under

extremely controlled circumstances, and intends to keep speeds at less than 20 knots,

we request an exemption from the above.

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By using these three safety oriented UAS,

Openhouseok.com will be able to create a safe operating environment.

14 C.F.R. 45.23 (b) Display of Marks: General and 45.29 Size of Marks

(a) Each operator of an aircraft must display on that aircraft marks consisting of the

Roman capital letter "N" (denoting United States registration) followed by the

registration number of the aircraft. Each suffix letter used in the marks displayed must

also be a Roman capital letter.

The sizes of the UAS Openhouseok.com plans to use are not large enough to

accommodate the required size of the registration numbers. We request relief from the

above requirement on the grounds that it is not applicable at this time. If registration

numbers are issued for UAS, we will certainly add them in the largest format possible to

ensure visibility. We would also like to point out that each UAS Openhouseok.com plans

to use is outfitted with green and red lights designed to communicate with the ground

pilot.

14 C.F.R. 61.113 (a) &(b) Private Pilot Privileges and Limitations: Pilot in Command

(a) Except as provided in paragraphs (b) through (h) 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 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 if:

(1)The flight is only incidental to that business or employment; and

(2)The aircraft does not carry passengers or property for compensation or hire.

Our UAS will not carry a pilot or passengers. We believe that we can achieve a higher

level of safety by requiring the PIC to obtain a sport pilot certificate. Traditional

operations in the past required a person or persons to elevate in a potentially

combustible vehicle in order to carry out the same operations we plan to accomplish by

way of UAS. Because we operate in a controlled environment, at low altitudes and

speeds, with no persons on board, using lightweight vehicles, the risks are substantially

less than have been in the past. Openhouseok.com also requests exemption regarding

the limitations of compensation for hire since we will be charging clients for videography

and photography in the real estate market.

14 C.F.R. 91.7 Civil Aircraft Worthiness

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

(b) The pilot in command of a civil aircraft is responsible for determining whether that

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aircraft is in condition for safe flight. The pilot in command shall discontinue the flight

when unairworthy mechanical, electrical, or structural conditions occur.

In the event that an exemption is granted, there will be no airworthiness certificate

issued for Openhouseok.com’s UAS. Without an airworthiness certificate, no FAA

regulatory standard will exist for determining airworthiness. As outlined above and in

attached exhibits, Openhouseok.com is committed to incorporating strict safety and

operational procedures in order to create an adequate level of safety that should exceed

current standards.

C.F.R.91.9(b)(2) Civil Aircraft Flight Manual, marking and placard requirements

(b) No person may operate a U.S.­registered civil aircraft—

(1)For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter

unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight

Manual or the manual provided for in § 121.141(b); and

(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.

(c) No person may operate a U.S.­registered civil aircraft unless that aircraft is identified

in accordance with part 45 of this chapter.

Since the UAS we plan to use are not large enough to carry documentation and do not

have on board pilots, Openhouseok.com does not have the ability to carry such

documents. We can recreate the same standard of safety by having the required

manuals on hand during each flight.

C.F.R. 91.103 Pre­Flight Action

Each pilot in command shall, before beginning a flight, become familiar with all available

information concerning that flight. This information must include—

(a)For a flight under IFR or a flight not in the vicinity of an airport, weather reports and

forecasts, fuel requirements, alternatives available if the planned flight cannot be

completed, and any known traffic delays of which the pilot in command has been

advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff

and landing distance information:

(1)For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual

containing takeoff and landing distance data is required, the takeoff and landing

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distance data contained therein; and

(2)For civil aircraft other than those specified in paragraph (b)(1) of this section, other

reliable information appropriate to the aircraft, relating to aircraft performance under

expected values of airport elevation and runway slope, aircraft gross weight, and wind

and temperature.

There is no pre­flight manual to refer to in regards to the UAS we plan to use. We will

apply all pre­flight recommendations from the Manuals provided from the manufacturer

along with our on safety measures as outlined above and in Exhibit A.

Openhouseok.com is committed to incorporated all of the safety measures illustrated

throughout this petition as well as evolving our practices as needed to ensure a high

level of safety.

C.F.R. 91.109(a) Flight Instruction; Simulated Instrument flight and certain flight tests

(a) 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.

However, instrument flight instruction may be given in an airplane that is equipped with

a single,functioning throwover control wheel that controls the elevator and ailerons, in

place of fixed, dual controls, when—

(1)The instructor has determined that the flight can be conducted safely; and

(2)The person manipulating the controls has at least a private pilot certificate with

appropriate category and class ratings. Because the UAS is radio controlled and

operated, it does not have fully functional dual controls. It is on the other hand outfitted

with very effective safety features that assist the craft in returning to a safe landing zone

that is designated before flight if the PIC is no longer able to operate the UAS.

Openhouseok.com does not consider this regulation applicable and requests

exemption.

C.F.R. 91.119 Minimum Safe Altitudes

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

the following altitudes:

(a)Anywhere. An altitude allowing, if a power unit fails, an emergency landing without

undue hazard to persons or property on the surface.

(b)over congested areas. 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

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operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d)Helicopters, powered parachutes, and weight­shift­control 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; and

(2) A powered parachute or weight­shift­control aircraft may be operated at less than

the minimums prescribed in paragraph (c) of this section.

Openhouseok.com asserts that the above is not applicable and believes it is in the

interest of safety to maintain strict rules for maximum altitudes. We will not be operating

our UAS above 400 feet AGL. Our UAS do not contain flammable or combustible fluids

and therefore offer a safer circumstance compared to current standards. They are also

small and light weight and are designed to automatically return to safe landing zones in

the event of an emergency. Risks are minimized through operating in extremely

controlled circumstances as outlined in this petition.

C.F.R. 91.121 Altimeter Settings

Requires each person to reference an altimeter

The UAS Openhouseok.com plans to use utilizes GPS for altitude readings. Safety can

be achieved by referencing the GPS data before and during each flight. We believe that

an exemption for this regulation is necessary on the basis that an adequate level of

safety and adherence to the purpose of the regulation can be achieved through the

GPS readings.

C.F.R. 91.151(a) Fuel requirements for flight in VFR conditions.

(a) 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; or

(2) At night, to fly after that for at least 45 minutes.

We request an exemption to the above regulation on the basis that the UAS we plan to

use do not carry fuel and we will only be conducting operations during daylight hours.

We also only conduct operations in clear and favorable conditions compared to

traditional aircraft. Our UAS are also outfitted with automatic return home features when

the battery life reaches a certain level. Because of the short amount of time required to

accomplish our goals of capturing videography and photography, we plan to land the

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UAS before exceeding 70% battery life.

C.F.R. 91.203 (a) &(b) Civil aircraft: Certifications required.

(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. Each U.S. airworthiness

certificate used to comply with this subparagraph (except a special flight permit, a copy

of the applicable operations specifications issued under § 21.197 c of this chapter,

appropriate sections of the air carrier manual required by parts 121 and 135 of this

chapter containing that portion of the operations specifications issued under § 21.197 c

or an authorization under § 91.611 ) must have on it the registration number assigned to

the aircraft under part 47 of this chapter . However, the airworthiness certificate need

not have on it an assigned special identification number before 10 days after that

number is first affixed to the aircraft.

A revised airworthiness certificate having on it an assigned special identification

number, that has been affixed to an aircraft, may only be obtained upon application to

an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within

the United States, the second copy of the Aircraft registration Application as provided

for in §47.31 c or a registration certification issued under the laws of a foreign country.

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

paragraph (a) 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.

Our UAS are not capable of carrying certification and registration documents and

therefore believe this is inapplicable. There is no onboard pilot and such documents

would need to be produced by the ground operator. We will ensure that all

documentation required by the FAA is on hand at ground level during all flight

operations.

C.F.R. 91.405 (a) Maintenance Required

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;

Openhouseok.com seeks exemption from the above on the basis that in the event of a

grant, there will be no airworthiness certificate as to this applies. Though in the interest

a assuring a high level of safety, we are committed to addressing any repairs

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replacements immediately. We will seek the assistance of the most qualified in the

industry which would be the manufacturer.

C.F.R. 91.407 (a) (1) Operation after Maintenance, Preventive Maintenance,

Rebuilding, or Alteration

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, (1) It has been approved for return to service by a person authorized

under § 43.7 of this chapter

Openhouseok.com points out that at this time there are no persons authorized to certify

the models UAS we seek to use for commercial purposes. Although, as stated above,

we will seek the assistance of the best qualified service technicians and help from the

manufacturer. Because of the relatively simple nature of the flight components, the

lightweight, and low speeds and altitude, we believe we can offer a high standard of

safety while operating and maintaining our UAS.

C.F.R. 91.409(a)(2) Inspections

(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.

In the event of an exemption being granted, we believe that this is inapplicable and

therefore request relief.

14 C.F.R. 91.417(a) Maintenance Records

(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:

(1)Records of the maintenance, preventive maintenance, and alteration and records of

the 100­hour, annual, progressive, and other required or approved inspections, as

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor,

and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return

to service.

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(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life­limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required

to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last

inspection required by the inspection program under which the aircraft and its

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives

including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.

(vi) Copies of the forms prescribed by § 43.9 d of this chapter for each major alteration

to the airframe and currently installed engines, rotors, propellers, and appliances.

Openhouseok.com requests relief from the above on the basis that at this time, those

regulations are inapplicable to the small and relatively simple UAS we plan to use.

Because of the limited payloads of the small UAS we plan to use can handle,

modifications are limited. The only possible modifications we plan to use are for safety

purposes in the form of prop guards designed by the manufacturer. In addition, we plan

to utilize the most detailed records possible relative to the operating nature of the UAS

incorporated at Openhouseok.com.

How your request would benefit the public as a whole;

The impact of an exemption for Openhouseok.com to use UAS will reach far beyond the

company and the clients we serve. Granting an exemption for Openhouseok.com would

allow the company to immediately transition into providing services that are safer, more

environmentally friendly, and economically accessible.

As highlighted throughout this petition, Openhouseok.com believes the substitution of

small UAS in place of traditional aircraft to accomplish the same objectives provides a

host a safety benefits. The UAS are considerably safer because of their size, weight,

and power source. They are operated at low altitudes under extremely controlled

circumstances and do not require onboard pilots.

We believe that this strongly supports the position that the risks to person or property

are dramatically lower with UAS. It is undoubtedly in the public’s interest to reduce the

occurrences of catastrophic or fatal crashes by way of integrating newer and safer

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technologies to accomplish the same goals. We appreciate the cautious nature of

integrating UAS and are committed to serving as an example of safe operations.

The environmental impact of granting an exemption for Openhouseok.com as well as

any other responsible petitioner is significant. In a time when society is highly conscious

of their environmental footprint, switching to battery operated UAS is a logical step for

society as a whole. Traditional aircraft will always have a role in the national airspace.

With that said, Openhouseok.com believes that by obtaining an exemption to carry out

its objectives, it will be empowered to replace the wasteful use of traditional aircraft and

the emissions expelled from the fuel they burn. It is commonly accepted that becoming

more efficient and less wasteful whether it be in regards to trash disposal, gas, food,

and other resources is in the public’s best interest. Throughout history, society has

eagerly adopted new ways to conserve the resources available to everybody. An

exemption for Openhouseok.com and companies alike, will allow us to continue those

efforts and impact the environment we all share as a society.

The economic benefits of the exemption Openhouseok.com seeks are far reaching.

This exemption will not only benefit our clients and Openhouseok.com but also the

communities in general that we serve.

Through the use of UAS, we will be able offer economically accessible options to

homeowners and realtors that were completely out of reach accept for a limited group.

Our country’s continuous efforts to create equal opportunity constitute the framework of

our economic system. Creating accessible options for entrepreneurs, leveling the

playing field, discouraging monopolies, and creating a vibrant atmosphere of

competition has been accepted as America’s path towards an elevation of society as a

whole since the country was founded. UAS are a prime example of what makes new

technologies so valuable to society. It has the potential to help people of all

circumstances that are exposed. An exemption for Openhouseok.com will allow us to

share in that positive impact on society as a whole.

Another tremendous public benefit an exemption for Openhouseok.com would offer is to

help promote cooperation and trust with regulatory organizations. By providing us with

an exemption, it will provide a concrete example for other companies and people

looking to conduct business responsibly and lawfully. Openhouseok.com’s experience

in dealing with the FAA in regards to using UAS has been positive. They have

highlighted that the FAA is committed to providing a path through the exemption

process for businesses to incorporate the technology. Clear rules have been outlined

and Openhouseok.com is committed to abiding by those rules. Each exemption granted

to responsible companies like Openhouseok.com help the public understand the

process and create a positive outlook for anyone looking to engage with this new

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technology.

Reasons why the exemption would not adversely affect safety, or how the exemption

would provide a level of safety at least equal to the existing rule;

As stated and supported throughout this petition, Openhouseok.com is fully capable of

integrating UAS in a manner that will not adversely affect safety. We have also put forth

that integrating UAS for the purpose of obtaining real estate photos and videography not

only meets but exceeds the current level of safety offered through traditional manned

aircraft.

A summary we can publish in the Federal Register

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register:

Openhouseok.com seeks an exemption from the following:

14 CFR: parts 21;

45.23(b);

45.29;

61.113(a);

91.7(a);

91.9(b)(2);

91.103;

91.109(a);

91.119;

91.121;

91.151(a);

91.203(a) and (b);

91.405(a);

91.407(a)(1);

91.409(a)(2);

91.417(a) and (b).

An exemption for Openhouseok.com will allow commercial operations of UAS under 15

strictly controlled conditions for the purpose of real estate photography, videography,

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and marketing. The pilot in command will obtain a sport pilot certificate and will be

accompanied by a visual observer. The PIC for Openhouseok.com plans to use the DJI

Phantom 2 Vision +, DJI Phantom 3 Professional, and the DJI Inspire 1. All three UAS

are outfitted with numerous safety features and are commonly used. They are all small,

lightweight, and pose minimal risks to property and people. The physical characteristics

of the UAS and fail safe features combined with Openhouseok.com’s commitment to

safe operating procedures and policies meets or exceeds the level of safety commonly

accepted with traditional manned aircraft.

An exemption as requested in this petition should be granted and will allow

Openhouseok.com the ability to impact safety, the environment, and the economy of

society as a whole.

If you want to exercise the privileges of your exemption outside the United States, you

must state the reason.

We do not seek to exercise the privileges of an exemption outside the United States.

Sincerely,

Mark McGuire, Owner

Open Houses of Oklahoma, LLC

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