January

13, 2016
U.S. Department of Transportation Federal Aviation Administration 8 0 0 Independence Avenue, SW Washington, DC 20591
Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA” ) , 49 U.S.C § 44701(f) and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Jeff ery McGee , a certificated private pilot, lighter

-than

- air category with a free balloon class rating and operator of an Unmanned Aircraft System (UAS), hereby apply, on my

own behalf and registered DBA, Virtual Tours by

J eff , 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.
I. Exemption Requested
Pursuant to Section 14. C.F.R § 11.81 (e) , I request exemption from 14.C.F.R. Part 21, Subpart H ; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119 (c) , 91.121, 91.151(a), 91.203(a) and (b), 91.215(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and photography real estate purposes and events.
II. Applicant Name : Jeff ery McGee Owner Virtual Tours by

Jeff (DBA) 2214 Landau Lane Bossier City, LA 71111 **III. UAS Operating Parameters** Commercial operation of an UAS, as described herein, which are equipped with camera and

sensors, would operate in the following manner: A. Aerial photography and/or video for public and/or private use including real estate and other related professional activities. B. Aerial video and/or photography for public and/or private use including public and private events.

As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereb y enhance safety and fulfill the Secretary o f Transportation responsibilities to “ ...establish requirements for the safe operation of such aircraft systems in the national airspace s ystem.” As found in Ex emption No. 11138 (Trudeau), the FAA recently approved similar use of a PHANTOM 2 UAS. I will operate a UAS, the DJI Phantom 2 and Phantom 3 Pro , which are comprised of an unmanned aircraft (UA or Phantom), an attached camera and a transportabl e ground station.

The PHANTOM 3 is a quadcopter with a gross weight of 2.8 pounds. Iti s equipped with four rotors that are driven by

e lectric motors powered by b atteries. The UA has a maximum airspeed of 16 m/s. Itwill be operated over various suburban areas, primarily around Shreveport and Bossier City, LA , to augment real estate l isting videos, capture event aeri al video and photography, and related business operations. I will abide by

the following additional operating conditions under this exemption, which ensures a level of safety at least equal to existing rules:

1. operate UAS below 300 feet and within a radius distance of 1000 feet from the controller to aid in direct line of sight visual observation; 2. obtain permission from the owner/controller of any vessels, vehicles and structures when operations may

b e conducted closer than 500 feet to any such vessels, vehicles or structures; I will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard; 3. operate the UAS for 5

- 10 minutes per flight; 4. land UAS prior to the manufacturer’s recommended minimum level of battery power; 5. operate UAS during daylight hours only within visual line of sight (VLOS);6. use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly

lands if communication with the remote control pilot is lost; 7. conduct all operations under the flight safety protocols (including posting a warning sign reading: “Attention Aerial Photogra phy in Progress

– Remain Back 10 0 feet”) contained in the operating documents and will actively analyz e flight data and other sources of information to constantly update and enhance safety protocols; 8. contact respective airports if operations will b e within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information; 9. always obtain all necessary p ermissions prior to operation; have procedures in place to abort flights in the event of safety breaches or potential danger; 10. only operate in safe environments that are strictly c ontrolled, are away from power lines, elevated lights, airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts and through obtaining information regarding congested areas from the local Flight Standards District Office (FSDO); and 11. conduct extensive preflight inspections and protocols, during which safety c arries primary importance (reference PHANTOM Flying Flow Chart and User Manual). Regarding UAS operational training, I have flown numerous practice flights in remote areas as hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of the UAS’ performance under different temperature and weather conditions. I will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logg ed as a UA S pilot with a multi

- rotor UAS. I will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations. Inaddition to the hour requirements, I will accomplish 3 take

- offs and recoveri e s in the preceding 90 days (for currency purposes) prior to any

flight.
**IV. Specific Exemptions Requested**  **Detailed**
Pursuant to 14 C.F.R. § 11.81 (e), the following exemptions are requested: 1. 14 C.F.R. Part 21, Subpart H & 14 C.F.R. §91.203 (a) and (b)

. Given the small size, weight, speed, and limited operating area associated with the UA and the safeguards that will be taken , an exemption from 14 CFR P art 21, Subpart H (AirworthinessCertificates) and §91.20 3 (a) and (b) (Certifications required), should be granted with

consideration of the size, weight, speed and operational capability, and proximity to airports and populated areas of the particular UAS.” 2. 14 C.F.R. 45.23

. I request an exemption from § 45.23 Marking and Identification Requirements of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two
- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement

. Regardless of this, we can mark the UAS in the largest possible lettering by

p lacing the word “Experimental” on its fuselage as required by § 4 5.29(f) so that anyone will see the markings. 3. 14. C.F.R. 91.7(a)

. I request an exemption from §91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable. I will conduct daily

pre and post flight inspections in accordance with manufacturer’s maintenance manual(s). During flight, I will adhere to § 91.7(b) and abort air operations immediately upon identification of an in

- flight emergency o r other unsafe condition. By

c omplying with procedures outlined by the manufacturer, an equivalent l evel of safety will be achieved. 4. 14. C.F.R. 91.9(b)

. I request an exemption from § 91.9(b) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation i s inapplicable. I believe an equivalent level of safety will be achieved by

maintaining a safety/flight manual with the UAS ground station. 5. 14. C.F.R. 91. 119

. I request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. I will not operate our UAS above the altitude of 4 00 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the size, weight, lack of fuel, maneuverability, and speed of the UAS, an equivalent or higher level of safety will be achieved. 6. 14. C.F.R. 91. 1 21

. I request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor. The GPS is pre cise within a few feet and combined with fail

- safes and a visual observer the operating will meet an equivalent or higher level of safety. 7. 14. C.F.R. 91.151(a)

. I request an exemption from § 91.151(a) Fuel requirement s for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued per the operating documents, the UAV will be landed at the first alert. Also, our flightswill last only 5

- 10 minutes each, and the UAS has an automated function, which results in immediate recovery when a l ow battery is detected. I will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended recovery and, assuming normal cruising speed, land the UA with 30% battery

power remaining. This regulation is written based on the capabilities of a traditional aircraft, which have flight times of several hours or greater; therefore, with a flight time of less than one hour, this regulation would effectively deny the ability of the

air vehicle to operate. I will achieve an equivalent level of safety by complying with all manufacturer guidelines. 8. 14. C.F.R . 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b)

. I request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution I will perform a preflight and postflight inspection and maintenance in accordance with the manufacturer’s guidance as state in the operations manual. If maintenance is required, Iwill conduct a dedicated test flight to ensure safety before resuming commercial operations. All inspection, maintenance and

alterations will be documented and maintained in a record. These actions will meet the intent of the regulations from which the exemption is being requested and lead to an equivalent level of safety.

**V. Public Interest**  Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts and increase business success. The industry is not new. However, until recently it was conducted through the use of costly manned aircraft, a prohibitive business activity for small companies. By granting this exemption Iwould be able to provide affordable services. Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. Additionally, the operation of our UAS will minimize harm to the environment economic growth by providing information to companies and the public looking to relocate or buil d in the metro areas I service. Public and private events serviced by our business enhance vibrancy and add culture to the community and its citizens.**VI. Commercial Operator/Operation** 

I will comply

with all of the following conditions and limitations should this exemption be provided: 1. Operations will be limited to the following aircraft described in the op erating documents, which is a quad

- rotor aircraft weighing 2.8 pounds: Phantom 2 and Phantom 3 Unmanned Aircraft System. 2. The UA will not be flown at an indicated airspeed exceeding 50 knots. 3. The UA will be operated at an altitude of no more than 400 feet a bove ground level (AGL) , All altitudes reported to ATC must be in feet AGL. 4. The UA will be operated within visual line of sight (VLOS) of me at all times. 5. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and I will be able to communicate verbally at all times. The role of VO will be designated before the flight and , once assignment is accepted, will not transfer his or her designation for the duration of the flight. I will ensure that the VO can perform the functions prescribed in the operating documents. 6. The operating documents will be accessible during UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request. 7. Prior to each flight, I will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records. 8. Any

UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test fl ight. After I conduct the functional test flight , I will make an entry in the aircraft records. 9. The pre

- flight inspection section in the operating documents will account for all discrepancies, i. e. inoperable components, items, or equipment, not already c overed in the relevant sections of the operating documents. 10. I will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 11. I will carry

out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 12. Each UAS operated will comply with all manufacturer Safety Bulletins. 13. An authorized person will make an entry in the aircraft record of the corrective actiontaken against discrepancies discovered between inspections.

14. UAS operations will be conducted b y me and I possess at least a private pilot certificate , will hold a valid, state government issued , driver’s license and will certify that I have no known medical defect that makes me unable to safely pilot the UAS

. I wil l also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which I am rated on my pilot certificate. 15. Prior to operations conducted for the purpose of aerial videography/ photography

and for real estate listing videos and public and private events and similar operations, I will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logg ed as a UAS pilot with a multi

- rotor UA S. 16. Prior to operations conducted for the purpose of aerial videography/ photography

and for real estate listing videos and public and private events and similar operations, I will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations. I will accomplish 3 take

- offs and recoverie s in the preceding 90 days. 17. I will not operate the UAS for the purpose of aerial videography/ photography

and for real estate listing videos and public and private events and similar operations, unless I have demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 18. UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will b e conducted under visual meteorological conditions (VMC). 19. The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

-published aeronautical chart. 20. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from me
. 21. If a UA loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22. I will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23. I will not begin a flight unless (considering wind and forecast weather conditions) there is

enough power to fly at normal cruising speed to the intended recovery point and land the UAwith 30% battery power remaining. 24. I will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (C OA) prior to conducting any operations, and also request a Notice to Air

- man (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 26. The documents required under 14 CFR 91.9 and 91.203 will be available to me at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request. 27. The UA will remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 28. The UAS will not be operated b y me from any moving device or vehicle. 29. The UA will not be operated over congested or densely populated areas. 30. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. I wi ll ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b

. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and I have made a safety assessment of the risk of operating closer to those obje cts and determined that it does not present an undue hazard, and;

c. Operations nearer me , VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 31. All operations will be conducted over private or controlled

- - - access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 32. Any

incident, accident, or flight operation that transgresses the lateral or verticalboundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- - - 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

**VII. Summary** 
Pursuant to FMRA, I hereb y a pply for authorization to conduct commercial unmanned aerial systems operating for the purposes of aerial photography and videography

and other work related to aerial photography listing Rules for each exemption is sought:
1. 14.C.F.R. Part 21, Subpart H 2. 14.C.F.R. Sections 45.23(b) 3. 14.C.F.R. 91.7(a) 4. 14.C.F.R. 91.9(b)(2) 5. 14.C.F.R. 91.119 (c) 6. 14.C.F.R. 91.121 7. 14.C.F.R. 91.151(a) 8. 14.C.F.R. 91.203(a) and (b) 9. 14.C.F.R. 91.215(b) 10. 14.C.F.R. 91.405(a) 11. 14.C.F.R. 91.407( a)(1) 12. 14.C.F.R. 91.409(a)(2) 13. 14.C.F.R. 91.417 (a) and (b)
Thank you for your prompt attention and consideration. I am committed to safe USA operations. Please , do not hesitate to contact me directly with any questions or concerns at cy pressla@live.com or ( 318 ) 465

- 0629

.
Sincerely,

Jeff ery McGee Owner Virtual Tours by

Jeff (DBA)