1 Myrealtor Group, LLC, Dayton, Ohio

 333 Exemption Petition

William F. McDonough

Attorney at Law, LLC

35888 Center Ridge Road, Unit 3

North Ridgeville, OH 44039

Phone: (440) 327-1542 Facsimile: 440-327-1542 

Email: TricountylawOhio@gmail.com Website: www.dronelaw.us

October 22, 2015

U. S. Department of Transportation 

Docket Management System 

1200 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); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam:

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

Act) and 14 C.F.R. Part 11, Myrealtor Group, LLC ("Myrealtor Group”), is a professional real 

estate firm, and hereby applies for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of its Small Unmanned Aircraft Systems (''sUASs") for 

aerial photography and videography, 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.

As detailed in this document and the attached Manual, the requested exemption would 

permit the operation of sUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access, and 4) would provide safety enhancements to the 

already best practices safety protocols followed by Myrealtor Group at each one of its aerial 

photography sites. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation's (the FAA Administrator's) responsibilities to "...establish 

requirements for the safe operation of such aircraft systems in the national airspace system." 

Section 333(c) of the Reform Act.

The name and address of the applicant is: 

Myrealtor Group, LLC

Dakota D. Shannon, President

Realtor, Keller Williams Advantage

4417 State Route 725 

Dayton, OH 45305

Office: 937-601-8827

Email: dakota@myrealtoroh.com

Website: dakotasells.com
 2 Myrealtor Group, LLC, Dayton, Ohio

 333 Exemption Petition

Myrealtor Group is writing pursuant to the FAA modernization Reform Act of 2012 

procedures contained with 14 C. At. Art. 11, to request that Myrealtor Group, the owner and 

operator of a small unmanned aircraft, be exempted from the Federal Aviation Regulations

(“FARS”) listed above, so that it may operate its ultralight weight unmanned aircraft system 

(“UAS”) commercially, in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, the Petitioner, Myrealtor Group’s President, Dakota D. Shannon, is 

a licensed realtor and entrepreneurial, operating a real estate firm that provides marketing and 

consulting services to individuals, as well as private and public entities. President Shannon has 

completed pilot ground school from Sinclair Community College and will be tested in the near 

future (Copy Sinclair Community College’s Ground School Final Grades are Attached as 

Exhibit I). Additionally, Mr. Shannon is experienced in flying hobby aircraft for recreational 

purposes.

Myrealtor Group has added a DJI Phantom 3 Professional, quadcopter UAS, equipped 

with an integrated, original equipment manufacturer (OEM) digital camera, to my inventory. The 

intended use of this equipment will be for aerial videography/photography to enhance academic

and community awareness for those individual entities and companies unfamiliar with the 

geographical layout of the greater Dayton, Ohio metropolitan area. Moreover, it will be used in 

real-estate research, analysis, and for-sale listing photographs and videos; thereby enhancing 

the academic research experience for the greater Dayton, Ohio metropolitan area; following 

exemption approval by the FAA.

This exemption request would permit operation of the ultralight weight, unmanned 

(piloted by remote control) and comparatively inexpensive, UAS in controlled and limited 

airspace. Said flight would occur in predetermined areas away from the public, airports, serial 

ports and vehicular traffic, for community photos and videos, and within property boundaries, for 

individual property owners, for videos/photos used in real estate listings. Currently, similar 

lightweight, remote-controlled UAS’s are legally operated by unmonitored amateur hobbyists 

with no safety plan or controls in place to prevent catastrophe. The Petitioner, Myrealtor Group, 

LLC, has personally installed safety protocols and controls to avoid and prevent public hazard, 

as well as manned aircraft hazards/catastrophe. This will act to further safety protocols closer to 

lightweight UAS’s specific to real estate video and photography usage, as a record flight data 

and other information gained to permitted flight operations to share with the FAA through any 

required FAA reports to assist with future protocol and safety regulation.

Granting this request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority not only to integrate UAS’s into the national 

airspace system, but to “... Establish requirements for the safe operation of such aircraft 

systems [UAS’s] in the national airspace system” under section 333(c) of the Reform Act

specific to the use of UAS’s for real estate/realtor purposes how to conduct my operations in 

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

For the reasons stated below Myrealtor Group respectfully requests the grant for an 

exemption allowing them to operate ultra-lightweight, remote-controlled UAS’s academic 

community awareness to the benefits/stimulate attraction to the greater Dayton, Ohio

metropolitan area and to enhance real estate research analysis and for sale listing videos for 

property owners who cannot afford us and said manned aircraft are the same purpose. Both of 
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 333 Exemption Petition

which will promote local economic growth through increased employment and increased tax 

base. Both the public safety in mind by keeping heavier manned aircraft containing combustible 

fuel that poses potential public hazard.

UAV/UAS/UA Clarification

The UAV/UAS/UA which Myrealtor Group, LLC, will be operating is the DJI Phantom 3,

Professional, Quadcopter, referred hereafter as Phantom. The inherent safety features, 

sophistication, programmability, GPS navigation, returned home capability, airport vicinity no-fly 

feature, and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft 

controller/receiver, and for the camera, make this a much safer UAV for the purposes of this 

petition. This is a professional grade radio controlled UAV that has the capacity for software 

upgrades. It is light, less than 3 pounds including battery and camera. Incorporated into the 

programming of this Phantom is an automatic return home feature that automatically directs the 

craft back to the point of takeoff to communication with the transmitter be lost. The Phantom 

has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight times 25 

minutes. Gross weight is 2.82 pounds.

The Phantom has an additional communication link between the camera and the craft on 

a different RF for smart phone connection. Allowing the operator or pilot in command (PIC) to 

monitor battery level, altitude (AGL), distance from PIC, camera imagery, and control camera 

angle. The DJI Phantom 2 Vision 2.4 ghz transmitter/controller/receiver rf for managing flight 

with a 5.8 ghz rf transmitter/receiver for video/photography functions eliminates possible rf 

conflict.

The software for the Phantom allows the operator or PIC to set maximum altitude AGL 

for each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet 

a GL as an example. The 400 foot maximum AGL can be programmed into the UAV’s software,

preflight, to ensure compliance with FAA standards, adding to the safety capabilities of this

UAV. This UAV is programed to remain in position when controls are released, maintaining 

altitude and GPS location.

Further, the Phantom has an altitude and regular monitoring function that allows the 

operator more precise determination of height, direction of flight, and distance from the operator 

or PIC can monitor with a GPS lock status while UAV is in flight, with the ability to anticipate loss 

of GPS locking so the operator or PIC command the UAV as a precaution.

This is a professional grade radio controlled UAV that has the capacity for software 

upgrades. It is light, less than 3 pounds including battery and camera. Incorporated into the 

programming of the Phantom is an automatic return home feature that automatically directs the 

craft back to the point of takeoff to communication with the transmitter be lost. The Phantom is 

a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight times 25 

minutes. Gross weight is 2.86 pounds.

The Phantom is an additional communication link between the camera and the craft on a 

different. Radiofrequency for the smart phone connection. Allowing the operator or pilot in 

command (PIC) to monitor battery level, altitude (AGL), and distance from PIC, camera 

imagery, and control camera angle.
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 333 Exemption Petition

In the Phantom Professional Model the new feature is Failsafe RTH which is activated 

automatically should the remote controller signal is lost for more than three seconds. This 

function returns the aircraft to the confirmed Home Point. A complete illustration for this feature 

is located on page 14 of the Phantom 3 Professional User Manual. (Complete Phantom User 

Manual is Attached as Exhibit II).

The best explanation of the Phantom sophistication and capabilities can be observed 

through a video explanation of an earlier model that was the predecessor to the Phantom 2 

vision plus through link www.youtube.com/watch?v=qajTB3g8TrU. The Phantom 2 Vision Plus 

maintained all capabilities defined in the video.

Specific UAV/UAS/UA

The particular UAV/UAS/UA which MyRealtor Group will be operating is the DJI 

Phantom 3 Professional, Serial Number P77DCE12010135.

Settings

 height limitations set for maximum of 300 feet AGL

 radius distance from controller set for maximum of 1000 feet, both to aid in direct line of 

sight and visual observation.

Current firmware upgrades for

 Main controller

 GPS

 Receiver

 Battery

 Zen IMU

Similarities, Distinctions, And Differences of Other Recently Approved 

Exemptions/Petitions

As with several other recently accrued similar petitions at exemptions including that of 

Astraeus (FAA-2014-0352), referred hereafter as the Astraeus Petition, and that of Douglas 

Trudeau (FAA-2014-0481), referred hereafter as the Trudeau Petition Myrealtor Group, LLC has 

a number of similarities, distinctions, and differences.

As with Trudeau Petition, Myrealtor Group, LLC, is using a UAV that had the capability 

for taking off and landing in a single point, identical to a helicopter. There are no runways, aided 

takeoff apparatuses, nor routes that need to be flown to areas being aerial video-recorded or 

photographed, allowing for a reduced and more confined area of flight.

The Astraeus Petition is for movie set involving a significant number of people, aerial 

equipment, moving or action sequences, and a potentially broad geographical area where 

individuals and equipment may be in motion, requiring extensive observation, awareness, 

coordination, and safety precautions. My petition is similar to the Trudeau Petition in that it is for 

video/photography of stationary objects requiring briefer flights. For reporting in tightly confined 

areas the stationary setting of object poses negatively lower risk for safety, allowing the operator 

or pilot in command (PIC) to focus primarily on stationary objects for shorter periods of time. 

With them, with the action scenes, associated with the Astraeus Petition, numerous states may
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 333 Exemption Petition

require repeat flights, where the stationary object, within most cases, requires only a single 

flight.

Similarly, as in the Trudeau Petition, Myrealtor Group, LLC Will require property owners’

written consent for aerial video/photography prior to flight. Signs will be posted cautioning 

anyone within the vicinity to remain back a minimum of 200 feet. (Safety sign is attached and 

marked as Exhibit III)

THE EXTENT OF RELIEF MYREALTOR GROUP, LLC SEEKS AND THE REASON 

HE SEEKS SUCH RELIEF:

The Petitioner, Myrealtor Group, LLC, submits this application in accordance with the 

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any current applicable FARs operating 

that would prevent me, Myrealtor Group, LLC, contemplated commercial cinematic, academic, 

and other flight operations within the national airspace system. The Reform Act in Section 332 

provides for such integration of civil unmanned aircraft systems into our national airspace 

system as it is in the public’s best interest to do so. My ultra, light-weight UAS meets the 

definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of 

my ultra-lightweight UAS is expressly contemplated by the Reform Act. I would like to operate 

my ultra-lightweight UAS prior to the time period by which the Reform Act requires the FAAA to 

promulgate rules governing such aircraft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered uniformly to all real estate related 

UAS aerial Video and photography. The Reform Act guides the Secretary in determining the 

types of UAS’s that may operate safely in our national airspace system. 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 in the 

line of sight. 112 P.L. 95§ 333 (a). Each of these items reflects in favor of an exemption for the 

Petitioner, Myrealtor Group, LLC. My UAS utilizes four (4) counter-rotating propellers for 

balance, control, and stability. Further, my UAS is equipped with GPS and “auto return” safety 

technology. Weighing less than three (3) pounds (far below the 55-pound limit); including 

camera with gimbal.

Furthermore the Petitioner, Myrealtor Group, LLC, considers safety foremost with each 

flight. My small, unmanned aircraft is designed to hover in place, via GPS, and operate in less 

than a 24-knot (15mph) wind. For safety, stability and fear of financial loss, I will not fly in winds 

exceeding 16 kph (10 mph). Built-in safety systems include a GPS mode that allows my UAS to 

hover in place when the radio controls are released. I utilize this mode for aerial 

videography/photography. This is the safest, most reliable, and stable mode to prevent 

accidents and reduce hazards. When pilot communication is lost the UAS is designed to slowly 

descend to the point of take-off. The Petitioner has not, nor will, operate a UAS near airports, 

hospitals, nor police heliports, and does not operate near areas where the general public is 

within fifty (50) to one hundred (100) yards, depending on the location, conditions, and weather. 

I am constantly on alert for any manned aircraft (i.e. police or medical helicopters, etc.) and am 

prepared to immediately land/abort to the nearest and safest ground point should a manned 

aircraft approach my location, or should I suspect a manned aircraft may approach near my 

location. My UAS is capable of vertical and horizontal operations, and is flown only within my

line of sight, as the remote-control pilot. Utilizing battery power, rather than combustible fuels, 

flights generally last between five (5) to ten (10) minutes, with an altitude under one hundred 
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 333 Exemption Petition

fifty (150) feet. The Petitioner, Myrealtor Group, LLC, will utilize a fresh, fully-charged battery 

with each flight, as a safety precaution; full flight time limit for each battery is twenty (20) to 

twenty-five (25) minutes as tested. I do not operate my UAS at, or below, the manufacturer’s 

recommended minimum charge levels for operation; preferring to remain well within a safe 

operating range to insure adequate communication between radio control and UAS to eliminate 

potential crash, loss of control, or other hazards. Reserve batteries are on-hand, with each 

exercise, to insure replacement and to provide a sufficient safe level of operation. I do not 

believe in taking risks that may cause a crash, or that would create a hazard to the 

public/property/manned aircraft, and have no desire to lose my investment. I have clocked 

numerous practice flights in remote areas, as a hobbyist, simulating flights for future commercial 

use, in order to gain familiarization with the characteristics of this specific UAS’s performance 

under various temperature and weather conditions. Further, the Petitioner has practiced on 

computerized simulated flights to maintain adequate skills and response/reflex time, as 

testament to his commitment to public safety.

Further the Petitioner, is extremely cautious when operating the UAS/ultra-lightweight, 

unmanned aircraft and will not “create a hazard to users of the national airspace system or the 

public.” 112 P.L. 95 § 333(b). Given the small size and weight of the UAS, it falls well within 

Congress’s contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive, to integrate UAS’s into the national airspace system. Petitioner’s UAS, 

used in hobby flight, has a demonstrable safety record and does not pose any threat to the 

general public or national security. 

HOW MYREALTOR GROUP, LLC’S REQUEST WILL BENEFIT THE PUBLIC AS A WHOLE:

Aerial videography for geographical awareness and for real estate marketing has a long 

history, through manned, fixed-wing aircraft and helicopters. For small real estate companies 

and the average homeowner, the expense of such aerial videography is cost prohibitive. Only 

large companies and high-end realtors, or luxury homeowners can afford to absorb such an 

expense; Depriving non-luxury homeowners and lower-budget realtors from a valuable 

marketing tool. Manned aircraft pose a threat to the public through the potential, catastrophic, 

crashes that the Dayton community has experienced in the past with commercial aircraft and 

medical helicopter crashes in the near vicinity of the city of Dayton. Each crash resulted in the 

loss of life when the combustible fuel exploded and burned on impact. Police helicopters have 

made emergency, hard-landings within city limits. My UAS poses no such threat since the size, 

and lack of combustible fuel, alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate 

commercially flown UAS’s into the national airspace system, hence the passing of the Reform 

Act. Granting my exemption request furthers the public’s interest through academic/visual 

awareness of the geographical benefits in and around the metro Dayton area. My ultra, lightweight UAS is battery powered and created no emissions that can harm the environment. The 

consequence of my ultra, light-weight UAS crashing is far less than a full-sized helicopter, or 

fixed wing aircraft; both of which are heavy, contain combustible fuel, and can cause 

catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threats by permitting 

aerial video/photography captured through my battery-operated, ultra, light-weight, UAS. 

Permitting the Petitioner, Myrealtor Group, LLC, to immediately fly within the national airspace 
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 333 Exemption Petition

furthers economic growth. Granting my exemption request substantially furthers the economic 

impact for the metro-Dayton community for companies looking to relocate or build in the MetroDayton area as well as individuals looking to relocate for career advancement through academic 

and geographical awareness, both of which serve as a stimulus to the Community.

Reasons Why Myrealtor Group, LLC Exemption Will Not Adversely Affect Safety Or How 

The Exemption Will Provide A Level Safety At Least Equal To Existing Rule:

My exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

permitting Myrealtor Group, LLC, to log in more flight time and effort in a controlled airspace, 

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 by the 

NAR (National Association of Realtors, http://www.REALTOR.org/) for development in 

cooperation with the FAA. In addition the Petitioner, Myrealtor Group, LLC, submits the following 

representations of enhancements to current aerial videography and photography for real estate:

 I am have completed Sinclair Community College ground school;

 my UIS weighs less than 5 pounds complete with the OE am digital camera;

 I only operate my UAS below 200 feet well within a 400 foot permissible ceiling set by 

the FAA modernization and Reform Act of 2012;

 my UAS at only operate for 5 to 10 minutes per flight;

 I land my UAS prior to manufacturers recommended minimum level of battery power;

 I pilot my UAS through remote control only by line of sight;

 My UAS has GPS a flight safety feature whereby it covers and then slowly land 

communication with the remote control pilot is lost; new line I actively analyze flight data 

and other sources of information to constantly update and enhance safety protocols;

 I only operate in reasonably safe environments that are strictly controlled and are away 

from power lines, elevated lights, airports and actively populated areas;

 I conducted then said preflight inspections and protocol, during which safety carries 

primary importance;

 I will obtain all necessary permissions prior to operation; 

 I have procedures in place to abort flight in the event of safety breaches or potential 

danger;

 The UAS that I fly, the DJI Phantom 3 Professional, has a built-in safety feature called 

the “No-Fly Zones Feature” that prevents UAS from taking off or flying near busy 

airports.

The Petitioner, Myrealtor Group, LLC’s safety protocols provide a level of safety equal 

to, or exceeding, existing rules. It is important to note that absent the integration of commercial 

UAS into our national airspace system, helicopters are the primary means of aerial video and 

photography for community awareness and real estate. While the safety record of such 

helicopters is remarkably astounding, there has been local incidents involving loss of life, as well 

as extensive property damage; it is far safer to operate a battery-powered ultralight weight UAS 

for the reasons listed below:

 First, the potential loss of life is diminished because UASs carry no people on board and 

I only operate my UAS in specific areas away from mass populations;
 8 Myrealtor Group, LLC, Dayton, Ohio

 333 Exemption Petition

 Second, there is no fuel on Board a UAS and thus the potential for fire or explosion is 

greatly diminished;

 Third, the small size and extreme maneuverability of my UAS allows me to remotely pilot 

away from and avoid hazards quickly and safely;

 Lastly, given the small size and weight, even one close enough to capture amazing 

images, my UAS need not be so close to the objects that they are focused on through 

the technology and use of post-editing software allowing pan and zoom. 

Accordingly, my UAS has been experimentally operated for familiarization/competency 

and will continue to operate at, or above, current safety levels.

The specific sections of Title 14 of the Code of Federal Regulations from Which 

Petitioner, Myrealtor Group, LLC, Requests Exemption are:

14 CFR 21;

14 CFR 45.23(b);

14 CFR 61.113 (a) & (b);

14 CFR 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409(a) (2); and

14 CFR 417 (a) & (b).

14 C. F.R. 21 and 14 C. F. R. 91: Airworthiness Certificate, Manuals and the Like.

14 C.F.R. 21. Subpart H, entitled Airworthiness Certificate, sets forth requirements for 

procurement of necessary airworthiness certificate in relation to FAR § 91.203 (a)(1). The size, 

weight, and enclosed operational area of my UAS permits exemption from Part 21 because the 

Petitioner’s UAS meets (and exceeds) an equivalent level of safety pursuant 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 certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. The Petitioner, Myrealtor Group, LLC’s 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. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual 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 safety will be achieved by maintaining a safety/flight manual delineating areas of where safety 

can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167. The Phantom employs a maintenance 

program that involves regular software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor.
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14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

safety will be achieved by maintaining any such required certifications and registrations by the 

Petitioner, Myrealtor Group, LLC.

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, by definition, unmanned. They therefore do not have a cabin, 

cockpit, or pilot station on which Mark certain words or phrases. Further, two-inch lettering 

difficult place on such a small aircraft with dimensions Moeller then minimal lettering 

requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the 

word “EXPERIMENTAL” on its fuselage as required by 14. C.F.R.§ 45.29 (f) so that I can the 

pilot, or anyone assisting me as a spotter with the UAS will see the markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A 

and 10700.

14 C. F. R. § 61. 113: Private Pilot Privileges And Limitations: PIC.

Pursuant to 14 C. F. R. § 61.113 (a) & (b), private pilots are limited to noncommercial 

operations. The Petitioner, Myrealtor Group, LLC, can achieve in the equivalent level of safety 

as achieved by current Regulations because my UAS does not carry any pilots or passengers. 

Further, while helpful, a pilot’s license will not ensure remote control piloting skills. The risks 

attendant to the operation of my UAS is far less than the risk levels inherent in commercial 

activities outlined in 14 C. F. R. § 61, et seq. Thus, allowing the Petitioner, Myrealtor Group, 

LLC, to operate my UAS meeting, and exceeding, current safety levels in relation to 14 C. F. R. 

§ 61.113 (a) & (b).

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

14 C. F. R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at 

an altitude greater than 200AGL; safely below the standard of 400 AGL. The Petitioner, 

Myrealtor Group, LLC, will however, operate my UAS in safe areas away from the 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 equivalent or 

higher level of safety will be achieved.

E. 14 C. F. R. § 91.405 (A); 407 (a) (1); 409 (A) (2); 417 (A) and (B): 

Maintenance Inspections

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] aircraft inspected as prescribed 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 45 of this chapter. ..” These Regulations only apply to aircraft 

with an airworthiness certificate. They will not, therefore, apply to the Petitioner’s UAS. 

However, as a safety precaution I inspect my UAS before and after each flight.
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 333 Exemption Petition

Petitioner requests modification, waiver, or exemption, and clarification (within reason),

concerning Section 91.119 - Prohibition of Flight In Congested Areas. Such restriction puts 

homeowners and other real property owners in subdivisions, at a disadvantage by limiting 

enhanced marketing of their homes and properties, thereby discriminating against them. 

Vertical takeoff and landing while video-recording, or photographing a home can allow an 

enhanced perspective for viewing, or proximity of mountains, golf courses, manmade lakes, or 

other attractions, not possible through ground-level photography. I am requesting waiver for this 

condition to allow reasonable and responsible aerial video/photography in congested areas of 

subdivisions and neighborhoods.

Similarly, with the Trudeau Petition, the single UAV utilized in this petition is a 

professional quad-copter that does not require an airman certificate for non-commercial flight 

involving less-restrictive, less-regulated flight.

Likewise, as in the Trudeau Petition, the motors, rotors, propellers, body/frame, landing 

pads, etc. for the UAS utilized in this Petition are not complicated. Engineering and design 

allows layman maintenance. As in the Astraeus and Trudeau Petitions, I am requesting waiver 

or exemptions for markings due to the small size of the fuselage for the DJI Phantom 3

Professional, Quadcopter.

Recording parts replacement for this UAV may prove impractical, or redundant, due to 

the simplicity of the craft. Therefore, as in the Astreaus and Trudeau Petitions I am requesting 

a waiver or exemption for maintenance records. However, pre-flight inspection for cracks, 

damage or other physical conditions that could hamper safe flight/operation is a reasonable 

expectation; as is post-flight inspection, that may aid in identifying flight conditions that may

cause stress to propellers, landing gear, etc. Thorough inspections of the UAV shall be 

conducted and flight response tested should a hard landing or crash occur, insuring that the 

UAV can operate in a safe manner before conducting any further video/photography.

Myrealtor Group, LLC, as with the Trudeau Petition, requests a waiver or exemption 

from Section 91.203 (a) since the Phantom is a professional-grade UAV/UAS that should not 

require an airworthiness certificate, or a registration certificate. Posting of special flight 

authorization would not be possible since the Phantom has no cabin and is not large enough to 

carry said certificate. However, a special flight authorization can be maintained by the operator 

to make available upon request.

In compliance with section 90.151 (a) the Phantom is a battery operated UAV/UAS with 

battery level monitoring capability. Fully charged battery flight-time is rated at 25 minutes, with 

videos/photos taking much less time to record. Operator or PIC is warned when battery level is 

low.

PRIVACY

All flights will occur over controlled property with the appropriate party’s consent and/or 

knowledge. Images taken will be of individuals who have also consented to being filmed or 

otherwise have agreed to be in the area where aerial photography will take place.

*******

 Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, 
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 333 Exemption Petition

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security -provide more than adequate justification for the grant of 

the requested exemptions allowing commercial operation of applicant's UASs in the real estate 

industry pursuant to the Manual appended hereto.

In Summary, Myrealtor Group, LLC Seeks an Exemption From the Following Regulations

14 C.F.R. 21, subpart H; 14 C. F. R. 45. 23 (b); 14 C. F. R. 61.133 (a) and (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. § 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); and, 14 C.F.R. § 91. 417 

(a) &(b) to commercially operate my small, unmanned vehicle/ultra-lightweight, unmanned 

aircraft vehicle in community awareness and real estate operations, and to develop economic 

platforms for real estate to enhance the understanding and experience of those seeking real 

estate information, or to relocate to the greater Dayton metropolitan area.

Currently, area awareness and real estate aerial videography/photography relies 

primarily on the use of larger aircraft running on combustible fuel, posing potential risk to the 

public. Granting the Petitioner, Myrealtor Group, LLC’s request for exemption will reduce the 

current risk levels and thereby enhance safety. My UAS craft does not contain potentially 

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

photographic aircraft much less flight time. Further, I operate at lower altitudes and in controlled 

airspace eliminating potential public risk flying to and from established airfields.

The Petitioner, Myrealtor Group, LLC, has been informally analyzing flight information 

and will compile safety protocols and the implementation of a flight operations manual for real 

estate usage that exceeds currently accepted means and methods for Safelight. Formal 

collection of information shared with the FAA will enhance the FAA’s internal efforts to establish 

protocols for complying with the FAA Modernization and Reform Act of 2012. There are no 

personnel on onboard my UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished the operation of my UAS, weighing less than 5 pounds and traveling at 

lower speeds within limited areas will provide an equivalent level of safety as that achieved 

under current FARs.

Accordingly the Petitioner, Myrealtor Group, LLC, respectfully requests that the FAA 

grant my exemption request as I am willing to cooperate in sharing information to benefit the 

FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

_______________________________

William F. McDonough (#00003915)

35888 Center Ridge Road, Unit 3

North Ridgeville, OH 44039

(440)327-1542 Telephone

(440)327-1225 Facsimile

TricountylawOhio@gmail.com Email

Counsel for Myrealtor Group, LLC