Keith Bliss, Realtor®, Cary NC - Section 333 ExemptionPetition 

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September 9, 2015

U. S. Department of Transportation\Docket Operations

West Building Ground Floor, Room w12-140 

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, 

I, Keith Bliss, am writing pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, to request that I, Keith Bliss, an owner 

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

Regulations (“FARs”) listed below so that I, Keith Bliss, may operate my small ultralight 

weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the 

Federal Aviation Administration (“FAA”). 

As described herein I, Keith Bliss, am a licensed Realtor within the State of North 

Carolina (license # 206741); experienced in flying remote controlled devices for 

recreational purposes. I will be flying a DJI Phantom III Professional Series for the 

purpose of aerial photography, videography/cinematography to enhance real estate 

listings; following exemption and approval by the FAA. 

I’m highly sensitive and respectful of the FAA and its commitment to safety and I share 

the same values. My, Keith Bliss's, exemption request would permit operation of 

ultralight weight, unmanned (piloted by remote control) and comparatively inexpensive 

UAS(s) in tightly controlled and limited airspace, predetermined in areas away from 

general public, airports, heliports and vehicular traffic within property boundaries for 

individual homeowner real estate listing videos/photos. 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. 

I, Keith Bliss, have personally instilled safety protocols and controls to avoid and 

prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to 

further safety protocols exclusive to lightweight UAS's specific to real estate video and 

photography usage as I, Keith Bliss, record flight data and other information gained 

through permitted flight operations to share with the FAA through any required FAA 

reports to assist with future protocol and safety regulation. 
Keith Bliss, Realtor®, Cary NC - Section 333 ExemptionPetition 

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Granting my, Keith Bliss’s, request comports with the Secretary of Transportation’s 

(FAA Administrator’s) responsibilities and authority to not only 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. Further I, Keith 

Bliss, will conduct my operations in compliance with the protocols described herein or 

as otherwise established by the FAA. 

For the reasons stated below I, Keith Bliss, respectfully request the grant of an 

exemption allowing me to operate ultralight weight, remote controlled UAS’s to enhance 

real estate listing videos, hence promoting local economic growth through increased 

employment and increased tax base. 

Contact Information: 

Keith Bliss Broker and Owner

Bliss Real Estate, LLC

115 Dry Avenue

Cary, NC 27511 

Office: 919.467.0707

Mobile: 919.796.5478

Email: kbliss@kw.com

The Specific Sections of Title 14 of the Code of Federal Regulations From Which Keith 

Bliss Requests Exemption are: 14 CFR 21; 14 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). 

The Extent of relief Keith Bliss seeks and the Reason He Seeks Such Relief: 

I, Keith Bliss, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 

331-334, seeking relief from any currently applicable FARs operating to prevent me, 

Keith Bliss, 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 interest to do so. My, Keith Bliss’s, ultralight weight UAS meets the 

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

integration of my ultralight weight UAS is expressly contemplated by the Reform Act. I 

would like to operate my ultralight weight UAS prior to the time period by which the 

Reform Act requires the FAA to promulgate rules governing such craft. 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. 
Keith Bliss, Realtor®, Cary NC - Section 333 ExemptionPetition 

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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 by line of sight. 112 P.L. 

95 § 333 (a). Each of these items reflect in favor of an exemption for me, Keith Bliss. My 

UAS utilizes four (4) counter-rotating propellers for balance, control and stability. My 

UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) 

pounds (far below the maximum 55 pound limit); including camera with gimbal. 

I, Keith Bliss, consider safety of paramount importance with each flight. The Phantom II 

Vision Plus unmanned aircraft is designed to hover in place via GPS and operate in wind 

up to 25 mph. For safety, stability and fear of financial loss I will not fly in winds 

exceeding 15 mph. When pilot communication is lost UAS is designed to slowly and 

automatically descend to point of takeoff. I do not and will not operate my UAS within a 

5 mile radius of airports, Hospitals nor Police heliports, and do not operate near areas 

where general public is within fifty to one hundred (50-100) yards depending on 

location, conditions and weather. I am constantly on alert for any manned aircraft 

(Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest 

and safest ground point should a manned aircraft approach my location or I suspect 

manned aircraft may approach near my location. 

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

line of sight of me, as the remote control pilot. Utilizing battery power rather than 

combustible fuels, flights generally last between five (5) to ten (10) minutes, but no more 

than twenty (20) minutes with an altitude under one hundred fifty (150) feet.

I, Keith Bliss, Realtor®, utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is twenty-five (25) minutes as tested. I 

do not operate my UAS at or below manufacture recommend 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 for crash, loss of 

control or hazard. Reserve batteries are at hand with each exercise to insure 

replacement for sufficient safe level of operation. I do not believe in taking risk that may 

cause a crash that could create hazard to the public/property/manned aircraft, and have 

no desire to lose an investment. 

I have clocked numerous practice flights in remote areas as a hobbyist simulating flights 

for future commercial use to gain familiarization with characteristics specific to UAS's 

performances under different temperature and weather conditions. I also practice 

computerized simulated flights to maintain adequate skills and response reflex time. All 

for the sake of safety. I, Keith Bliss, am extremely cautious when operating of my 
Keith Bliss, Realtor®, Cary NC - Section 333 ExemptionPetition 

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UAS/ultralight weight 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 my 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. Keith Bliss’s UAS, used in hobby flight, has a demonstrable 

safety record and does not pose any threat to the general public or national security. IV. 

How Keith Bliss’s Request will Benefit the Public as a Whole

Aerial photography and videography for real estate marketing has been around for a 

long time through manned fixed wing aircraft and helicopters. For small budget real 

estate companies and average homeowners the expense of such aerial videography is 

cost prohibitive. Only large companies and high end Realtors or luxury homeowners can 

afford to absorb such expenses, hence depriving non-luxury homeowners and lower 

budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the 

public through potential catastrophic crashes. 

My, Keith Bliss's, UAS pose no such threat since size and lack of combustible fuel 

alleviates potential threats 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, Keith Bliss’s, exemption 

request opens possibilities to further the public interest through academic/visual 

awareness of the geographical benefits in and around the metro Raleigh area.

I intend to become a steward in my respected market demonstrating the proper way to 

operate a UAS for real estate marketing purposes. My ultralight weight UAS is battery 

powered and creates no emissions that can harm the environment. The consequence of 

my ultralight weight UAS crashing is far less than a full size helicopter or fixed wing 

aircraft; 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 threat by 

permitting aerial video/photo capture through my battery operated ultralight weight 

UAS's. Permitting me, Keith Bliss, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially furthers the economic 

impact for individuals looking to relocate for career advancement through academic and 

geographical awareness. 

Reasons Why Keith Bliss’s Exemption Will Not Adversely Affect Safety or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule
Keith Bliss, Realtor®, Cary NC - Section 333 ExemptionPetition 

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My, Keith Bliss’s, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated permitting me, Keith Bliss, 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 by the NAR6 , AAR7 , and TAR8 for 

development in cooperation with the FAA. 

In addition I, Keith Bliss, submit the following representations of enhancements to 

current aerial videography and photography for real estate: My UAS weighs 1242g 

(including battery and propellers) with a small ultralight weight high quality integrated 

camera; I only operate my UAS below 400 feet (within the 400 foot permissible ceiling 

set by the FAA Modernization and Reform Act of 2012); My UAS will only operate no 

more than 25 minutes per flight; I land my UAS prior to manufacturer 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 hovers and then slowly lands if 

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

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

operate in reasonably safe environment that are strictly controlled, are away from power 

lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which 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 safety breaches or potential danger. 

My, Keith Bliss’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, it is far safer to operate a battery powered 

ultralight weight UAS. First, the potential loss of life is diminished because UAS's carry 

no people on board and I only operate my UAS in specific areas away from mass 

populations. Second, there is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished. Third, the small size and extreme maneuverability of 

my 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 amazing 

images, my 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. 

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

and will continue to operate at and above current safety levels. 
Keith Bliss, Realtor®, Cary NC - Section 333 ExemptionPetition 

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Summary 

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. My, Keith Bliss’s, current and projected 

UAS's meet or exceed each of the elements. 

I, Keith Bliss, can achieve an equivalent level of safety as achieved by current 

Regulations because my UAS does not carry any pilots 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 inherent in the commercial 

activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Keith Bliss, to operate my 

UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 14 

C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for 

the operation of civil aircraft. 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) & (b): Maintenance Inspections. 10 Appendix E -

Safety/Flight Manual. The above-cited Regulations require, amongst other things, 

aircraft owners and operators to “have [the] 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. . . 

.” These Regulations only apply to aircraft with an airworthiness certificate. They will 

not, therefore, apply to my, Keith Bliss's, UAS. However, as a safety precaution I inspect 

my UAS before and after each flight. 

Granting my, Keith Bliss’s, request for exemption will reduce current risk levels and 

thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is 

smaller, lighter and more maneuverable than conventional real estate video 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, Keith Bliss, have 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 safe flight. 

Accordingly I, Keith Bliss, respectfully request that the FAA grant my exemption request 

and am willing to cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large. 

Respectfully submitted, Keith Bliss, Broker and Co-Founder Bliss Real Estate, LLC, 115 

Dry Avenue, Cary, NC 27511