Endpoint Realty LLC 

8356 South Tower Road 

Garrison, MN., 56450 

Tel 218-820-2388 

jim@endpointrealty.com 

December 20, 2015 

l/.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE Washington, DC 20590 

RE: Request for Exemption Per PL 112G95 §333 from 14 CFR Part 21, 14 CFR 45.23 (b ), 14 CFR 61.113( a) 

and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 203 (a) & 

(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b) 

To whom it may Concern, 

This letter will serve as a request for an exemption of the above sections of title 14 CFRfor Endpoint 

Realty LLC, henceforth referred to as the petitioner, for the purpose of conducting commercial "aerial 

photography, videography, search and rescue, home inspections, and survey operations" using a small Unmanned 

Aircraft System (sUAS) in FAA controlled airspace. As described herein, the petitioner has staff who are 

experienced in the operation of UAS, including but not limited to, flying m ulticopters of varying sizes under 55 

pounds using both Visual Line Of Sight (VLOS) and on board camera controls. The following petition provides all 

necessary frl.formation to justify an exemption from the above listed Federal Aviation Regulations. 

The Unmanned Aircraft System 

The petitioner will be operating a D]I Phantom 3 (manual attached). The Petitioner made add additional 

airframes. to th.eir inventory as require from the D]I or other lines. The petitioner will operate the airframe within 

its design parameters. 

The sUAS has built in functionality that can limit the height it flies above the ground, limit the distance 

between the aircraft and PIC, and restrict the sUAS from flying in class B, C, and D airspace. The aircraft also 

comes preinstalled with the ability to automatically return to the PIC and land if any of the previous restrictions 

are violated, or if the connection to the wireless controller is lost 

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The sUAS weighs 2935 grams Gust under 6 pounds) while carrying all necessary batteries and cameras. 

It also has a max speed of 22 meters per second Gust under43 knots) that can be limited prior to takeoff. 

The Unmanned Aircraft PIC 

The company operator and PIC fames K Warta is an FM licensed private pilot and is an sUAS 

experienced operator. 

sUAS Operation Overview 

The sUAS will be operated to provide aerial photography, videography, and survey services to the public 

sector, particularly for the purposes of real estate, events, and properfJl surveys. 

Prior to the operation, flight restrictions will be programmed into to sUAS to prevent it from flying 400 

feet above ground level. Before takeoff, the operator and observer will review the preGflight checklist and survey 

the area to determine if weather/cloud conditions are suitable for flight and what the emergency landing sites 

would be. Once the operation is complete, the sUAS will be inspected to determine if any maintenance will be 

needed before the next operation. 

Compared to traditional flights using manned aircraft, flights using sUAS are much less dangerous and 

therefor would not adversely affect safefJl: 

• The nature of these flights will restrict the use of the sUAS to a small area where all nearby 

persons can be aware of the ongoing flight 

• The sUAS carries no explosive materials or combustible liquid fuel. 

• The light weight of the sUAS would cause minimal damage in the event of an airborne 

failure, especially when compared to traditional manned aircraft with airworthiness 

certificates. 

• The small size of the sUAS would allow for all operations to be conducted within a clearly 

defined area, including takeoffs and landings. 

All flights by the PIC will begin and remain outside of a 5 mile radius of any airport The s!JAS has a 

mandatory, built-in functionalifJl to restrict the aircraft from flying within this radius and will automatically land 

if it inadvertently violates this restriction. Any and all precautions will be taken by the PIC and the accompanying 

Observer to prevent midair collisions with objects and other aircraft, even outside the 5 mile radius of airports. 

All pianned operations utilizing the sUAS will be completed safely. With the combination of the preflight 

safel:J' risk assessments previously discussed and the inherently reduced risk of flying a sUAS compared to a 

traditional manned aircraft, the PIC will be able to provide a level of safety greater than the traditional method of 

performing aerial based photography, videography, and survey operations. 

Benefit to Public Interest 

The services provided by the petitioner would be a great benefit to the public as a whole. Granting this 

exemption would reduce the need for traditional forms of aerial photography, videography, and surveys which, as 

previously discussed, are much more dangerous than operations performed by sUAS. The cost of sUAS operations is 

also significantly lower than traditional aerial photography flights, making these services available to smaller 

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businesses or individuals that otherwise may not be able to afford them. This in turn allows businesses to better 

serve their clients, increasing the public benefit as a whole. 

Conclusion 

All commercial sUAS flights by the petitioner shallsatisfy the criteria provided in Section 333 of the 

Reform Act of 2012, including: size, weight, speed, flight within VLOS, distance from PIC, distance from airports, 

operation capabilities, maintaining safety, and the benefit to the public. These qualifications more than justifY 

granting the petitioner, Cornerstone Technology Services, LLC, with an exemption to the stated sections of title 14 

CFR. 

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The requests of this petition are similar to those of Marcus D. Melhus, Ralph]. Apel, 

Cornerstone Technology Services, LLC and Saratoga Aerial and Video, all of whom have received Section 333 

exemptions for use of comparable aircraft for similar operations. 

Thank you for your time and consideration. 

Sincerely, 

f)Q./ltJ1U' t:_WtJuvkV 

fJmes K Warta President 

· Endpoint Realty, LLC