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 Administra tion (“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 Ser ies 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. M y, Keith Bliss's, exemption request would permit operation of ultralight weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly c ontrolled and limited airspace, p redetermined 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 co ntrols in place to prevent catastrophe.

I, Keith Bliss, have personally instille d 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 lig htweight 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 requirement s 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 complianc e 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 es tate listing videos , h ence 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 ap plicable 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 informa tion 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. Consi derations 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 safe ty, 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 airp orts, 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 helicopte rs, 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 manufactu re 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 h and 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 pract ice 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 myKeith Bliss, Realtor®, Cary NC

- Section 333 ExemptionPetition

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UAS/ultralight weight unmanned aircraft and will not “create a hazard to users o f 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 i nto 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 w il l 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 prohibit ive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expenses, h ence depriving non

- luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through pot ential 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 flow n 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 th e 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 re quest substantially furthers the economic impact for individuals looking to relocate for career advancement through academic and geographical awareness.

Reasons Why Keith Bliss’s Exemption Wi ll Not Adversely Affect Safety o r How The Exemption Will Provi de a Level of Safety A t Least Equal To Existing RuleKeith 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 communicatio n 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 add ition 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

camer a; 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 2 5 minutes per flight; I land my UAS prior to manufacturer recommended

minimum level o f 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 so urces 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 pre

f light 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 photog raphy 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

ex plosions 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 aircraf t 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 i n 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): Maint enance Inspections. 10 A ppendix 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 inspecti ons, 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 f uel, 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

e stablished 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