August 11, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave, SE Washington, DC 205590

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,

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

and 14 CFR Part 11, Peter Rebristy, private pilot, and operator of Small Unmanned Aircraft 

Systems ("UAS") equipped to conduct aerial photography for the education of real estate 

professionals and real estate marketing purposes, hereby applies 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.

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) 

limited 2) predetermined and 3) controlled as to access. Approval of this exemption would 

thereby fulfill the Secretary of Transportation's (the responsibilities to " ... establish requirements 

for the safe operation of such aircraft systems in the national airspace system." Section 333 (c) 

of the Reform Act.

Sincerely, Peter Rebristy.

I. CONTACT INFORMATION:

Peter Rebristy

1571 NE Kokanee Ln

WoodVIllage OR 97060

Email: prebristy@gmail.com

II. THE SPECIFIC SECTIONS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

FROM WHICH PETER REBRISTY REQUESTS EXEMPTION ARE:

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14CFR91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a)

& (b)
This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system 

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UAS do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of 

the following:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. Reform 

Act §333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of 

such aircraft in the national airspace system." Id. §333 (c) (emphasis added). The Federal 

Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority 

by its terms includes exempting civil aircraft, as the term is defined under §401 01 of the Act; 

that includes UAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if 

the Administrator finds the exemption in the public interest. 49 U.S.C. §44704; 14 CFR §91.203 

(a) (1).

Peter Rebristy’ UAS(s) are small rotorcraft aircraft, the DJI Inspire 1, weighing less than 10 lbs. 

including sensor payload. They operate their rotorcraft, under normal conditions at a speed of 

no more than 20 knots, usually 3-5 knots, and have the capability to hover, and move in the 

vertical and horizontal plane simultaneously. They will manually operate only in Visual Line of 

Sight and will operate only within the operating parameters as described in the Operating 

Manual attached as Attachment 1.

Adherence to the Operating Manual will insure that the UAS will "not create a hazard to the 

national airspace system or the public."

Given the small size and weight of the UAS involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UAS to commence immediately. Also due to the size of the UAS and 

the areas in which the relevant UAS will operate, approval of the application presents no 

national security issue. Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety, 

surrounding the proposed operations, and significant public benefit, including enhanced safety, 

reduction in environmental impact, including reduced emissions associated with allowing UAS 

for educational and marketing operations, (as opposed to full scale aircraft), the granting of the 

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay.

III. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or possibly higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 

filming operations conducted with conventional aircraft. These limitations and condition to which 
Peter Rebristy agrees to be bound when conducting commercial operations under an FAA 

issued exemption include:

1. The UAS will weigh less than 10 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew 

(Spotter I Observer).

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL, though most operations 

will be conducted within 50 feet of the ground.

5. Minimum two (2) man crew for each UAS operation will consist of the Pilot and Spotter I 

Observer. In most cases the third aircrew member will serve as the Safety Officer.

6. The UAS Pilot will be an FAA licensed airman with at least a private pilot's certificate and third 

class medical and valid driver's license.

7. The UAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder, other than the 

UAS Pilot, possesses the necessary PIC qualifications and is also present, that person can also 

be designated as PIC.

8. The UAS will only operate within an area of Portland Oregon, Wood Village Oregon, 

Gresham Oregon.

9. Additionally, the UAS will only operate less than 400ft AGL.

10. The UAS will never enter any MOA or Restricted Airspace, nor shall it violate any TFR as

outlined by the FAA.

11. A pre-flight briefing will be conducted in regard to the planned UAS operation prior to each 

day's flying I recording activities. It will be mandatory that all personnel who will be performing 

duties as "flight crew" be present for this briefing.

12. Pilot and Spotter (Observer) will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as required.

13. Spotter (Observer) and Pilot will at all times be able to communicate by voice or radio.

14. Written and/or oral permission from the relevant property holders will be obtained.

15. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location and land.

16. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

17. Pilot will abide by all Oregon Revised Statutes Chapter 837 (Aircraft Operations).

a. The UAS Pilot in Command (PIC) shall possess at a minimum, a private pilot certificate and 

current third-class medical certificate.

i. The PIC shall also meet the flight review requirements specified in 14 CFR §61.56 in an 

aircraft in which the PIC is rated on their pilot certificate.

ii. The PIC shall be trained in the operation of the specific make and model of the UAS being 

piloted and successfully completed all training required.

iii. The PIC shall have accumulated and logged, in a manner consistent with 14 CFR §61.51 (b), 

a minimum of200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 

five hours logged as a UAS pilot with a similar UAS type (multirotor or helicopter). Prior 

documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement.

iv. The PIC shall have accumulated and logged, in a manner consistent with 14 CFR §61.51 (b), 

a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for 

operations under the exemption and three take-offs and three landings in the preceding 90 

days.
v. Training, proficiency, and experience-building flights can also be conducted under this grant 

of exemption to accomplish the required flight cycles and flight time.

1. During training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered non-participants, and the PIC must operate the UAS with appropriate 

distance from non- participants in accordance with 14 CFR §91.119.

b. The UAS Safety Observer (SO) shall meet all training requirements and be responsible for all 

of his/her duties as set forth by GCUAS UAS Operating Manual.

c. The PIC and SO will be designated before each flight.

i. Minimum crew for each flight operation will consist of the UAS PIC and SO.

d. The PIC and SO shall always be within visual line of sight (VLOS) of each other and in direct 

verbal communication at all times.

e. Safety Briefings shall be conducted before each day's activities to include, but not limited to:

i. Designated roles of PIC and SO

ii. Risk Management and Mitigation

f. Liability Insurance

i. General Liability Insurance shall be maintained in the amount of 500,000/100,000.

IV. DJI INSPIRE 1

Model

Weight (Battery Included) Hovering Accuracy:

Vertical

Horizontal

Max Angular Velocity

Max Tilt Angle

Max Ascent Speed

Max Decent Speed

Max Speed

Max Flight Time

Operating Temperature Range Dimension

T600 6.47 lbs.

1.6 feet

8.2 feet 150°/s

35°

16.4 ft/s 13.1 ft/s

42 kts

18 minutes 14° F - 104° 18"x18"x12"

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section

333 of the Reform Act both authorize the FAA to

exempt aircraft from the requirement capability, and proximity to airports and populated areas of 

the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed-wing or 
rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed.

The UAS to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials nor flammable liquid fuels, and operates exclusively 

within a limited radius area as set out in the preflight briefing I VLOS operations. Unlike other 

civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

Operator, pursuant to safety requirements, and under the requirements and in compliance with 

local public safety requirements, to provide security for the area of operation as is now done 

with conventional aircraft. These safety enhancements, which already apply to civil aircraft 

operated in connection with video production, provide a greater degree of safety to the public 

and property owners than conventional operations conducted with airworthiness certificates 

issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the UAS, due to its 

size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load.

14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted", "light- sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the sUAV, two inch lettering will be impossible. 

The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as 

required by §45.29 (f) where the Pilot, Spotter (Observer) and others working with the sUAV will 

see the identification of the UAS as "Experimental." The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b):

Private Pilot Privileges and Limitations - Pilot in Command (PIC) Sections 61.113 (a) & (b) limit 

private pilots to non-commercial operations. Because the UAS will not carry a pilot or 

passengers, the proposed

operations can achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot's license rather than a commercial pilot's license to 

operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the 

UAS is remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the Operating 

Manual. The level of safety provided by the requirements included in the Operating Manual 

meets that provided by single individual holding a commercial pilot's certificate operating a 

conventional aircraft. The risks associated with commercial operations contemplated by Part 61 

when drafted, that allowing operations of the UAS as requested with a private pilot as the PIC 

exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

14 CFR §91.7 (a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 
Given the size of the aircraft and the requirements contained in the Operating Manual for 

maintenance and use of safety checks prior to each flight, as set forth in the Operating Manual, 

an equivalent level of safety will be provided.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

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

approved manual material, markings, and placards, or any combination thereof.

The UAS, given its size and configuration has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the Operating Manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 95658, 10167, 10167A 10602, 32827, and 10700

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. An equivalent level of safety will be provided as set forth in the 

Operating Manual. The

PIC will take all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight.

14 CFR §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety 

provided by the fact that aircraft will be piloted by a certified private pilot who has previously 

trained in remote flight areas before attempting flight within filming distance of structures.

14 CPR § 91.119: Minimum Safe Altitudes

Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a UAS, PeterRebristy requests authority to operate at altitudes up to 400 ft. 

AGL; an exemption may be needed to allow such operations. As set forth herein, the UAS will 

never operate at higher than 400 ft. AGL. It will however be operated in a controlled area where 

buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as location where it is operated. No flight will be taken without the permission of the property 

owner. Because of the advance notice to the property owner and participants in the 

photographic activity, all affected individuals will be aware of the planned flight operations as set 

forth in the Operating Manual. Compared to flight operations with aircraft or rotorcraft weighing 

far more than the maximum 10 lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 ft. AGL. In addition, the low-altitude operations of the UAS will 
ensure separation between these small UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 CPR § 91.121 : Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAS will not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent 

level of safety will be achieved by the operator, pursuant to the Operating Manual and Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight.

14 CPR §91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed- (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

The battery powering the UAS provides approximately 20 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be impossible. Given 

the limitations on the UAS's proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that 

Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting UAS flights would greatly reduce the utility for which the exemption will be 

granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate return the UAS to its planned landing zone from anywhere in its limited operating 

area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 57 45, 

1 0673, and 10808.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) An appropriate and current airworthiness certificate ...

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

paragraph (b) of this section or a special flight authorization issued under §91. 715 is displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 10 lbs. and is operated without an onboard Pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the Pilot flying the UAS will have immediate access to them, to the extent they are 
applicable to the UAS, and should they be issued. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided 

in paragraph C of this section, have discrepancies repaired as prescribed in Part 43 of this 

chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the operator; 

pursuant to the Operating manual. An equivalent level of safety will be achieved because these 

small UAS are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 ft. AGL. As provided in the Operating Manual, the PIC 

(operator) will ensure that the UAS is in working order prior to initiating flight, and perform 

required maintenance. Moreover, the operator is the person most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety.

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: Applicant seeks an exemption from 

the following rules: D 14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 

91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 

(a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (51bs or less) in Educational and Marketing operations.

Privacy

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge, or over remote public land. Image capture of people will rarely take 

place, but in the event they are, they will have consented prior to being filmed or otherwise have 

agreed to be in the area where data collection will take place.

Airborne Image Capture

With regard to airborne filming, Peter Rebristy adheres to all FAA regulations. Further Peter 

Rebristy airborne teams operate under the principals of: Safety First, Quality Assurance, 

Accountability,

Reporting, and Training. When approved by the FAA it is Peter Rebristy’ mandate to treat all 

UAS operations the exact same level of professionalism and seriousness as that of 

conventional aircraft.

Approval of exemptions allowing commercial operations of UAS in the real estate industry will 

enhance safety by reducing risk. Conventional filming operations, using turbine or piston 

powered aircraft present the risks associated with vehicles that weigh in the neighborhood of 

2,0001bs.+, carrying large amounts of Jet A or 100 LL (60 gallons for the aircraft primarily used 

by Peter Rebristy). Such aircraft must fly to and from photographing location. In contrast, a UAS 

weighing fewer than 10 lbs. and powered by batteries eliminates virtually all of the risk given the 

substantial reduced mass and lack of combustible fuel carried on board. The UAS is typically 

transported to the location via auto or cargo van in a medium sized case and is never flown to 

set. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft.

The operation of small UAS, weighting less than 10 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 
allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than ground than 

conventional operations conducted with piston helicopters or fixed wing aircraft operating in 

relatively close proximity to the ground and people.

The primary market of interest for Peter Rebristy utilizing UAS is the marketing of real property, 

and the second is the education of real estate professionals.

It is anticipated that the airborne image capture process will be accomplished exclusively in day 

time VFR environments. To capture the highest quality of resolution the majority of airborne 

data collections will take place during the 07:00am- 07:00pm (19:00) window.

V. Summary

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

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 UAS in the real estate 

industry pursuant to the Operating Manual appended hereto. Peter Rebristy is eagerly standing 

by to support the FAA and UAS community in its quest to establish proper regulations and 

protocols for the safe introduction of unmanned aircraft into the national airspace.

Sincerely,

Peter Rebristy, 1571 NE Kokanee Ln, WoodVIllage OR 97060

prebristy@gmail.com