Dave Dubin, Realtor ® , Gray, TN

- Section 333 Exemption Petition

Page 1 of 9 January 1, 201 6

U. S. Department of Transportation Docket Management Sy stem

1 200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2);

9 1

. 1 0 3 (b ) ; 9 1

. 1 0 9; 119.121; 91.151(a); 91.203( a) &(b) ; 91.405(a )

; 9 1.407(a) ( 1 )

; 91.409(a) (2 )

; 9 1.417(a) &(b)

Dear Sir or Madam,

I, Dave Dubin Realto r® , am writin g pursuant to the FAA Modernization and Reform Act

of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Dave Dub in

R ealtor® , an owner and operator of small unmanned aircraft, be exempted from the

Federal Av iation Regulation s (“FARs”) listed below so that I

, Dave Dub in Realtor®

, may operate m y small ultra light weight unmanned aircr aft s ys tem ( “UAS”) commercially

in airspace regulated b y the Federal Aviation Administration (“FAA” )

. As des cribed herein I

, Dave Dubin Realtor ® , am a licensed R ealtor® within the State of

Ten n essee an d a r eg ister ed fixed wing and powered parachute Pilot Certificate #3 444519

.

I

, Dave Dubin Realtor ® have a dded to my inventory a DJI Phantom 3 Pro quad

- cop ter

UAS equipped with a built in camera with intent for aerial videograph y/ cinematograph y which could be used to en h ance academic commu n ity awareness for those individuals and companies unfamiliar with the geographical lay out of the East Tennessee area, and augment real estate listing videos; f o llo win g exemption and approval b y the FAA.

My

, Dave Dubin's

. ex emption request would permit op eration of an ultr a lig ht weig ht,

u nmanned (piloted by remote con tro l) and comparatively inexpensive UAS in tightly

controlled an d limited airsp ace. Pred etermined in areas away f r o m general public, airports,

h eliports and vehicular traffic for community videos, and within property boundaries for

individual homeowner real estate listing videos/photos. Currently , similar lightweight,

remote controlled UAS are legally op er ated b y u nmo nito red amateur h o b b y ists with n o saf ety p lan or co n tr o ls in p lace to preven t catastrophe. I

, Dave Dubin Realto r® , have

p ers onally instilled safet y

1 Ap p endix A

- Phantom quad-copter Operator ManualDave Dubin Realtor®

, Gray TN

- Section 333 Exemption Petition

Page 2of 9

p r otocols and controls to avoid and prevent public hazard, as well as manned aircraft

h azard s/catastro p h e. This will act to further safet y p r otocols exclusive to lightweight UAS specific to real estate video and photography usage as I, Dave Dubin Realtor®

, record all flight data and other information gained through permitted flight operations to

share with the FAA throu g h an y required FAA reports to assist with future protocol and

safet y regulation.

Granting m y, Dave Dubin's request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS 's into the nat ional airspace s ys tem, but to “...establish requirements for the

safeo peration of such aircraft sy s tems [UAS's] in the national airspace sy s tem” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor

purpos es. Further I, Dave Dubin Realtor® , will conduct my o perations in compliance

with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Dave Dubin Realtor® , respectfully request the grant of an exemption allowing me to operate ultra light weight, remote controlled UAS for academic community awareness to benefit/stimulate attraction to the East Tennessee area and to enhance real estate listing videos for homeowners who ca nnot afford expensive

manned aircraft for the same pu rp ose. Both of which will promote local economic growth through increased employm ent and increased tax b ase. Both with public safet y in mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public hazard.

**I. Contact Information:**  Dave Dubin

, Realtor® Remax Results 175 Brystone Drive Gray TN 28117 Office: ( 423 ) 946-0000

Mobile: ( 423 ) 333

- 1866

Em ail: remax@davedubin.com
**II. The Specific Sections of Title 14 of the Code of Federal Regulat**  **ions From Which**  Dave

Dubin Realtor® **Requests Exemption are:**

14 CFR 21;

1 4 C.F.R. 45.23(b) ; 14 CFR 61.113 (a) & (b) ; 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1) ; 14 CFR 409 (a) (2) ; and, 14 CFR 417 (a) & (b)

.

2 Appendix B

- Personal Protocols and ControlsDave Dubin , Realtor®, Gray TN

- Section 333 Exemption Petition

**III. The Extent of relief** Dave Dubin Realtor® **seeks and the Reason He Seeks Such**

**Relief:**

I

, Dave Dubin Realtor® , submit this application in accordance with the Reform Act, 112

P.L

. 95 §§ 331-334, seeking relie f from an y currently applicable FARs operating to prevent

me, Dave Dubin Realtor® , contemplated commercial cinematic, academic and other flight operations within the national airspace s ys tem. The R eform Act in Section 332 provides for such integration of civil un manned aircraft s ys tems into our national airspace

s ys tem as it is in the public’s interest to do so. My, Dave Dubin ’s, ul tra light weight UAS

meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform

Act. I would like to operate my ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereb y, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photograph y. The Reform Act guides the Secretary in determining the types of UAS's that may operate
safel y i n our nation al airspace s ystem. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated b y line of sight. 112 P.L

. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Dave Dubin

R ealtor® . My U AS utilizes four (4) counter -rot ating propellers for balance, control and stability . My U AS is equipped with GPS and auto return safet y technology . Weighing less than five (5 ) pounds (far below the maximum 55 pound limit); including camera with gimbal.

I

, Dave Dubin Realtor® , cons ider safet y as foremost with each flight. My small

u nmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. F o r safet y, stability and fear of financial loss I will not fl y in winds exceeding 16 kph (10 mph)

. B u ilt in safet y s ys tems include a GPS mode that allows my

UAS to hover in place when radio controls are released. When pilot communication is lost

UAS is de signed slowl y descend to point of take of f . I do not operate m y UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-1 00) ya rds depending on location, conditions and

weather. I am constantl y on alert for an y manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to t he nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach nea r my location. My UAS is capable of vertical and horizontal o p erations, and are flown onl y within my line of sight of me, as the remote contro l p ilot. Utilizing battery power rather than combustible fuels, flights generally last between 15 -20 m inutes , with an altitude

under four hundred (400) fe et. I

, Dave Dubin Realtor® state that the Phantom 3

Professional includes safe circle for operation, position hold, self-leve ling, altitude command, GPS, return home feature, and saf et y control to return home or land in the

event o f communication interruption between RC transmitter and UAS. See Appendix A for P hantom 3 Professional User manual Safe circle, position hold, and

the oth er safet y features.Dave Dubin , Realtor®, Gray TN

- Section 333 Exemption Petition

Page 4 of 9

I

, Dave Dubin Realto r® , utilize a fresh full y charged battery with each flight as a saf ety

p r ecaution; full flight time limit f o r each battery is twenty five (25) t o thirt y (30) minutes

as tested. I do not o p er ate my UAS at or below manufacture reco mmend minimum

cha r g e levels for operation; preferring to remain well within a safe operating range to

in su r e adequate communication between radio control and UAS to eliminate potential for

cr ash, loss of a control or hazard. Reserve batteries are at hand with each exercise to

insure r ep lacement for sufficient safe level of operation. I do n ot believe in taking risk that may cau se a crash, that could create hazard to the public/propert y/ manned aircraft,

and h av e n o d esire to lose an investment. I have clocked numerou s practice flig hts in

r emote areas as a hobb yi st simulating flights for fu tur e commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response r eflex time. All for the sake of safety.

I

, Dave Dubin Realto r ® , am extremely cautious when operating of my UAS/ultra light weight unmanned aircraft and will not “create a hazard to users of the nationa l airspace

sy stem o r the public.” 112 P.L

. 9 5 § 333 (b). Given the small size and weig h t of my UAS it falls well within Congress’ s contemplated safet y zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the nation al airspace sy stem.
Dave Dubin's UAS, used in hobby f lig h t, has a demonstrable safety

r ecord an d d oes not pose any threat to the gen eral public or national security

.

**IV. How**  Dave Dubin's **Request Will Benefit the Public As A Whole:**

Aerial videograph y

for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopter s. For small budget real estate companies and average h o meowners the expense of su ch aerial

v id eo gr ap h y is co st prohibitive. Only large companies and hig h end Realtors or luxury

h o meo wners can afford to absorb such expense. Depriving non

- lux ur y h omeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through poten tial catastrophic crash that the East Tennessee community has experienced in the past with aircraft and medical helicopter crashes within the city of Johnson Cit My

, Dav e Du bin ’s , UAS pose no such threat since size and lack of

co mb u stible fuel allevia tes any potential th reat to the public. C o n g r ess has alread y proclaimed that it is in the public’s interest to integrate commercially flown UAS's into

th e national airspace s ys tem, hen ce the passing of the Reform Act. Gr anting m y, Dav e Dubin' s , exemption r equest f u r thers the public interest through acad emic/visual awareness of the geographical benefits in and around the East Tennessee ar ea. M y ultra light weight UAS is battery p o wered and creates no emissions that can harm the

environment. The co n sequence o f my ultra light weight UAS crashing is far less than a full size helicopter or fixed win g aircraft; which are heav y, contain combustible fuel and can cause catastrophic devastation to the publicDave Dubin , Realtor ®, Gr ay TN

- Section 333 Exempti on Petition

Page 5 of 9 The public’s interest is furthered b y minimizing ecological and crash threat b y permitting aerial video/pho to capture through my battery operated ultra light weight UAS's. Permitting me, Dave Dubin Realtor® , to immediatel y fl y within n ationa l air space

f urthers eco no mic g r o wth

. Granting m y exemption req uest sub stantially fu rth er s th e

eco n o mic imp act for the metro East Tennessee community fo r companies looking to

relocate or build

in the East Tennessee area as well as individuals looking to relocate for

career advancemen t through academic and geographical awareness. Both of which ser ve as a stimulus to

th e community

.

**V. Reasons Why**  Dave Dubin's **Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least**  **E qual To Exist**  **ing**

**Rule:**

My

, Dave Dubin's , ex emption will not adversely affect safety . Quite the con trary

, for the reasons stated permitting me, Dave Dubin Realto r® , to log more flight time in

FAA controlled airspace, with communication with the FAA, will allow me to contribute

to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors that can be embraced b y the NAR6 and NCAR7 f or d evelopment in co o peration with the FAA. In addition I

, Dave Dubin Realtor® , submit

the following representations of enhancements to current aerial videograph y and

p h otograph y for real estat e

- : My UAS weighs less than 5 pounds complete with a small ultra light weight high quality

built in camera:

- I only operate my UAS below 400 feet 9 (well within the 400 foot permissible ceiling set b y the FAA Modernization and Reform Act of 2012);

- my UAS only operate for 15 -20 minutes per flight;

- I land m y UAS prior to manufacturer recommended minimum level of battery

power;

- I pilot my UAS through remote control onl y b y line of sight;

- My UAS has GPS a flight safet y feature whereb y it hovers and then slowly lands if communication with the remote control pilot is lost;

- I activel y anal yz e flight data and other sources of information to constantly update an d enhance safety protocols;

- I only operate in reasonably safe environment that are strictl y controlled, are

away from power lines, elevated lights, airports and activel y populated areas;

- I conduct extensive pre

- flight inspections and protocol, during whi ch safety carries primary

importance;

- I always obtains all necessary permissions prior to operation; and,

- I have procedures in place to abort flights in the event of safet y breaches or potential danger.

6 National Association of Realtors, http://www.realt or.org/

7 Tennesse Association of Realtors, http://www. netar

. o r g/

9 Phantom 3 software limits height to 400’ AGL ( see Appendix A Operator

Manual )Dave Dubin , Realtor®, Gray TN

- Section 333 Exemption Petition

Page 6 of 9 My

, Dave Dubin ’s, safety protocols provide a level of safet y equal to or exceeding existing rules. I t is imp ortant to note that absent the integration of commercial UAS into our national airsp ace s ys tem, helicopters are the primary means of aerial video and pho tograph y for community awareness and real estate. While the safet y record of such helicopters is remarkabl y astounding, there has been local incident in v o lving loss of life

as well as extensiv e property damage; it is far safer to operate a batter y powered ultra light weight UAS.

- First, the potential loss of life is diminished because UAS's c arry no people on

b o ard and I onl y operate my UAS in specific areas away from mass populatio ns. -Second, there is no fuel on board a UAS and thus the potential for fi re or explosions is greatly dim inished. Third, the small size and extreme maneuverability of m y UAS allow me to remotely pilot away from and avoid hazards quickly and safely

.

- Lastly, given its small size and weight, even when close enough to capture

amaz ing images, m y UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom.

Accordingl y, m y UAS has been experimentall y operated for familiarization/competency

and will continue to operate at an d above cu r r ent safet y levels.

**VI. A**  **Summ a**  **ry The FAA May Publish in the Federal Register:**

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

1 4 C

. F. R. 2 1

, S u bpart H, entitled Airworthiness Certifica tes, sets forth requirements for p r o curement of necessary airworthin ess certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of m y, Dav e Dubin's , UAS permits exemption from Part 21 because my UAS meets (and
exceed s) an equivalent level of safet y pursuan t to Section 333 of the R eform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation per mit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas su ch as airports and dense populations. My

, Dave Dubin ’s, c urrent and projected U AS's meet or exceed each of the
elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the f orm contemplated by

the FAR s, t his Regulation is inapplicable.1 4 C

. F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are n o on board p ilots or passengers, and given the size of the UAS's, this Regulation is inap plicable. An equivalent level of safety will be achieved by maintaining aDave Dubin , Realtor®, Gray TN

- Section 333 Exemption Petition Page 7

o f 9

s a f e t y / fl i g h t m a n u a l d el i n eating a r eas of whe r e s afety can be define d

. 10 T h e F A A

h a s p reviousl y i s s ue d exemptions to this regulation in Exemption Nos. 8607, 8737,8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and

32827.

1 4 C

. F .R

. § 9 1 .121 regarding altimeter settings is inapplicable insofar as my UAS

u t i l i z e s el e c t roni c global posi t i o n i n g s y s te m s w i t h a baro m e t r i c s e n s o r

.

1 4 C

. F .R

. § 9 1 .203 (a) and (b) provides for t h e c a r ry i n g o f civi l ai rcraf t

c e rt i f i cations and registrations. They a r e i n a p p l i c a b l e f o r t h e s a m e r easons described above. The equivalent l e v e l o f s a f e t y w i l l b e a c h i e v ed b y main taining

any s uc h r e q u i r e d c e rti fi cations and registra t i o n s by m e , D a v e D u b i n R e a l t or®

. B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according

to certain specifications. My UAS are, b y definition, unmanned. They therefore

do not have a cabin, cockpit or pilot station on w hich to mark certain words or phrases. Further, two- inch lettering is difficult to place on such small aircraft with

dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering b y placing the wo rd “EXPERI MENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or an yone assisting me as a spotter with the UAV will see the markings. The FAA has previously

issued exemptions to this regulation through Exemptions Nos. 8738,

101 67, 10167A and 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and L imitations: PI C. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

commercial operations. I, Dave Dubin Realtor® , can achieve an equivalent level of safety as a chieved b y current Regulations because my UAS does not carry any

p ilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less

than the risk levels i nherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. T h u s, allowing me, Dave Dubin Realtor® , to operate my UAS meet

and exceed current safet y levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

1 4 C.F.R . § 91.119 pr escribes safe altitudes for the operation of civil aircraft. I t
allows h elicopters to be operated at lower altitudes in certain conditions. My UAS

will never operate at an altitude greater than 400 AGL ; Equal the standard of 400 AGL. I, Dave Dubin Realtor® , will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below

those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS,an equivalen t or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.
10 Appendix C Safety/Flight ManualDave Dubin , Realtor®, Gray TN

- Section 333 Exemption Petition Page 8

of 9

Th e above -cit ed Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthin ess certificate. They will not, therefore, appl y to m y, Dave Dubin' s , UAS. However, as a safet y precaution I inspect

my UA S befo r e and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Li ke. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirement s for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my

, Dave

Dubin ’s , UAS meets an equivalent level of safety pu rsuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness

certific ate requirement in consideration of the weight, size, speed, maneuverability and

p roximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an

airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 1 4 C. F.R. § 91.9 (b ) (2) requires an aircraft flight m anual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safet y will be achieved b y m aintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8 737, 8738, 9299, 9299 A, 9565, 9565B, 10167,

mainte nance program that involves regular software updates and curative measures for

any d amaged h ardware. Therefore, an equivalent level of safety will be achieved.

**In summary,** Dave Dubin Realtor® **seeks an exemption fr om t**  **he following Regulations:** 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Dave

Dubin ’s , small unmanned vehicle/lightweight un manned aircraft vehicle in community awareness and real estate operations, and to develop economic p latforms for real estate to enhance the experience of those seeking to relocate to the East Tennessee area. Currently,

area awareness and real estate aerial videography /photography relies pr imarily on the use of larger aircr aft running on combustible f uel. Posing potential risk to the public. Granting

my, Dave Dubin ’s, request for exemption will reduce current risk levels and thereb y enhance safet y. M y U

AS craft do not contain potentiallyDave Dubin , Realtor®, Gray TN

- Section 333 Exemption Petition

Page 9 of 9

explosive fuel, is smaller, lighter and more maneuverable than conventional real estate

v ideo and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. I, Dave Dubin Realtor ® , have been informally anal yz ing f ligh t
inform ation an d will compile safet y protocols and the implementation of a flight

o p erations manual for real estate usage that exceed s cu rrentl y accep ted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for c omplying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Dave

Dubin Realtor® , UAS and therefore the likelihood of d eath or serious bodily injury is significantl y d iminished. My, Dave Dubin ’s, o p eration of my UAS, weig hin g less th an 5 pounds and travelling at lower speeds within limited areas will provide an eq u ivalent

level of safet y as that achiev ed under current FARs. Accor dingly I, Dave Dubin

Realtor® , respectfully request that the FAA g rant my exemption request and am willing to cooperate in sha rin g inf ormation to b enefit the FAA, safet y of manned aircraft, and t he general public at large.

R espectfully submitted,

Dave Dubin

- Realtor® Remax Results

1 7 5 Brystone Drive Gray TN 28117

Cell Phone: 423-333-1866 Email: remax@davedubin.com

Dave Dub in

, Realtor®, Gray TN

- Section 3 33 Exemption Petition

# Appendix A

Phantom 3 Pro Quad

Copter Operator Manual

(see http://www.dji.co m/product/ phantom-3-pro/

in fo#d ownload s )

# Appendix B

Dave Dub in Realtor®

Personal Protocols and ControlsProtocols and Controls

Aerial Community and R eal Estate Videos

Dave Dubin , Realtor®, R emax Results

, Gray TN Pag e 1

Safety for public on the ground as well as manned aircraft a bove is an essential and

u tmost consideration for aer ial videos and p h o tography

. As such

, saf et y p rotocols and

controls must be imp lemented th ro ugh pre

- flig ht preparation an d du ring flight.

Pre

- Flight Protocol:

- Check batteries with voltage meter to insure fully charged and read y for use.

- Inspect batteries for damage or leakage that may affect proper operation.

- Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion

or unmanageable/uncontrolled flight.

- Check weather forecasts for wind advisory or other conditions that my impact flight.

- Consult five (5) mile radius map for airport vicinity

. o Contact respective airport to advis e of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information.

- Inspect flight area for o vicinity of public safety

helipads/heliports o vicinity of medical helipads/heliports

o vicinity of light poles o vicinity or utility wires o vicinity of trees o flocks of birds that may cause interference and potential flight impact o vicinity of an y elevated obstructions that may pose potential flight hazard o vicinity of roadway s with mod erate to heav y t raffic that can be distracted o public gatherings that may attract viewers o optional point of control for best visual site of UAS while in flight

- Takeoff and landing o inspect area for best and safest point of takeoff and landing

o if in a subdivision or area that is within 150 feet of a residential street, post warning sign(s)/stand(s) "Attention Aerial Photography I n Progress

- Remain

Back 150 Feet " Flight Protocol:

- takeoff and land from same location

- remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow any one to engage in conversation or distract the remote control pilot -restrict flight to minimal elevation sufficient to acquire desired results

- remained prepared f

or emergency

landing at all times- pay

attention to flight time o if possible set a timer as a safet y al ert

- land UAS and shut down propulsion immediately following landing

Protocols and Controls Aerial Community and R eal Estate Videos

Dave Dubin , Realtor®, R emax Results

, Gray TN Pag e 2

Post flight: a. disconnect battery

to prevent accidental activation of propulsion sy stem
b. secure UAS in a safe location c. remove all warning signs from public access areas Emergency

or Suspected Hazard: Immediate land UAS at safest and closet ground location in the event o manned aircraft is heard or seen in vicinity of flight o there is a public gathering within established safety boundary

wanting to observe flight o pilot is being distracted fr om focusing on flight and safet y o sudden change in weather (wind bursts) o sudden increase in vehicular traffic in vicinity of flight o birds enter into proximity of flight

o any sudden unsafe event that can cause collision, distraction or interruption of

controlDave Dubin , Realtor®, Remax Results

- Section 333 Exemption Petition



# Appendix C

Dave Dub in

Realtor® Safety/ Flight ManualSafety Flight Manual

Aerial Community and R eal Estate Videos

Dave Dubin

, Realtor®, Remax Results

, Gray TN Page 1

Safety f o r p u blic on the ground as well as manned aircraft above is an essen tial and utmost consideration for aerial videos and photography

. Maintaining a record of safe flight for FAA request and for determining future UAS

safet y p r otocols is imperative. Date:____________________ L o cation:

___________________________________________________ Pre

- f light Inspection: Yes No Comment:

_________________________________________________ Elements (circle) (c ircle) Commen t
Weather Good Fair

Visib ility Good Fair Wind Speed L ow Medium Proximity to a irport: _________________ (see attached map pinpointing approxi mate location of flight) Airport notified Yes No Date:_______________ Time: ______________

Phone Number : _______________________ Contact Name:

___________________________________ Nearest major intersection:

______________________________________________________________ Proximity to medium traffic road:

_________________________________________________________ Proximity to heavily traveled roadway road:

_________________________________________________ Proximity to congested populatio n:

________________________________________________________ Approx. Takeoff Time Approx. L anding Time

Estimated Elevation Safety Concerns:

Additional Comments:

Unedited flight video/photos available for FAA upon written request within 180

d ay s o f flight: Yes No