PETITION FOR SECTION 333 EXEMPTION

–

Adam H. Guthrie

March 1, 2016

U. S. Department of Transportation Docket Operations 800 Independence Ave., S.W. Washington, DC 20591

Re: Petition of Adam H. Guthrie for Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Adam H. Guthrie (individual) hereby applies for an exemption from th e Federal Aviation Regulations ( “ FARs ” ) identified below, to allow civil operation of small unmanned aerial systems ( “ sUAS ” or “ UAS ” ) as part of daily business operations.

TABLE OF CONTENTS

I. Description of Petitioner II. Description of Proposed Operatio n III. Adam H. Guthrie Proposed UAS Operations Meet the Requirements of Section 333 a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability b. Approval is Warranted Based on the Operationa l Restrictions Set Forth in the included UAS Standard Operating Guide

IV. Regulations From Which Exemption is Sought a. 14 C.F.R. Part 21, Subpar t H: Airworthiness Certificates
b . 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft c. 14 C.F.R. §§ 45.23(b) and 45.27 (a): Marking of the Aircraft d. 14 C.F.R. § 91.7(a ): Civil Aircr aft Airworthiness e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civi l Aircraft Flight Manual in the
Aircraft
f. 14 C.F .R. § 91.103: Preflight Actions g. 14 C.F.R. § 91.109(a): Flight Instru ctionh. 14 C.F.R. § 91.119: Minimum Safe Altitudes

i. 14 C.F. R. § 91.121: Altimeter Settings j. 14 C.F.R. § 91.151(a): Fuel Requiremen ts for Flight in VFR Conditions k. 14 C.F.R. § 91.405, 91.407, 91.409, 91.4 17: Maintenance and In spections l. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 6 1.113: Private Pilot Privileges
and Limitations

V. Public Interest VI. Privacy VII. Federal Register Summary
VIII. APPENDIX A: Adam H. Guthrie UAS Standard Opera ting Guide
IX. APPENDIX B: FAA Advisory Circular

X. AP PENDIX C: AMA Safety Code

I. Description of Petitioner

Adam H. Guthrie provides real estate services to clients that often require photographs and video tours . In recent months clients have requested aerial marketing that woul d require hiring an outsider to provide services related to taking said photographs and videos

.

These photos and videos are often utilized for marketing purposes.

• Adam H. Guthrie is an independent contractor working as a licensed Georgia Real Estate Agent

• Servi ces include real estate consultation and sales

• Adam H. Guthrie is properly licensed in the Georgia to provide said services.

• Adam H. Guthrie holds the following licenses/certific ations; Realtor and Real Estate Agent

In accordance with 14 C.F.R. § 11.81 (a), Adam H. Guthrie provides the following information in support of its Petition for Exemption.

N ame and Address for Petitioner:

Adam H. Guthrie 4405 Huntington Pointe Valdosta, Ga 31602
229

- 548

- 7719 adam@exitintouch.comPoint of contact for this Petition and specific contact information is as follows:

Adam H. Guthrie 4405 Huntington Pointe Valdosta, Ga 31602

II. Description of Proposed Operation

Adam H. Guthrie proposes to conduct the operation of a UAS, specifically the DJI Phantom 3 Standard or Advanced, within the parameters of providing aerial photogra phs of single family residences and or large acreage parcels of land.

The Pilot in Command ( “ PIC ” ) for each operation will, at a minimum, be Adam H. Guthrie

. Adam H. Guthrie has adopt ed and incorporated many of the AMA ’ s UAS Safety Code (the “ Code ” ) and Operating Guide ’ s (the “ Guide ” ) procedures into its own safety code and guide, which sets forth the mandatory standard operating procedures for its proposed UAS operations as detailed he rein. The exception would be the location of operations that will take place at private residences with the authorization of the owner and not on property leased or owned by the AMA. These procedures provide a baselin e to ensure that the Phantom 3 pilot po ssess sufficient knowledge of both airspace and the technology to operate safely in the National Airspace System ( “ NAS ” ). Any other assistant or photographer will operate with Adam H. Guthrie as the PIC in each operation and will meet the standards specifi ed in the Guide, as well as any other additional requirement the FAA requires under this application.

III. Proposed UAS Operations Meet the Requirements of Section 333

Proposed operations in this Petition for Exemption qualify for expedited approval purs uant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied.

a. Approval is Warranted Based on the UAS’s Size, Weight, Speed, and Op erational Capability

Adam H. Guthrie will employ the DJI Phantom 3 Standard or Advanced or quadcopter for the operations described in this Petition for Exemption. This UAS is classified as a small drone or hobby craft and is lawfully used for recreational op erations. The Phantom 3 has a maximum take

- off weight of 5.53

pou nds. The flight speed is limited to a maximum of 33.5 miles per hour and it will not be flown at an altitude that exceeds 200 feet AGL. All flights will be managed in such a way that they can be safely terminated with a reserve battery power of 25% of the battery's maximum charge. The DJI Phantom 3 does not carry any flammable propellant or fuel. The UAS also has an integrated GPS system that
calculates the UAS's position and height and relays that information via a secure connection to the
operator. Throug h use of this GPS system and the installed firmware, the user is able to set maximum height and radius in relation to a pre

- determined home point, restricting flight to a zone that is bothapproved by the FAA and the owner of the property being photographe d. This system also automatically

restricts flight within a range of airports that is greater than the 5 miles that the FAA requires. Additionally, the UAS contains a failsafe mode if its connection to the remote control is lost, and this system permits th e UAS to return to a predetermined location and land without injury or damage.

b. Approval is Warranted Based on the Operational Restrictions Set Forth in the UAS Standard Operating Guide

Together, the Guide and the DJI Phantom 3 User Manual c ontain all of the procedures and limitations necessary to successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Adam H. Guthrie’s proposed operations, below is a summary of operatio nal limitations and conditions which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The Phantom 3 weighs 5.53 +/

- pounds. 2. Flights will be operated within the VLOS of the PIC and or an observer, at a minimum. 3. Maximum total flight time for each operational flight will be limited to 25% reserve battery power remaining. 4. Flights will be operated at an altitud e of no more than 200 feet AGL. 5. All operations will be con ducted in class G airspace. 6. Flights will be restricted to pre

- determined areas of th e owner/clients property, which will always be located outside of 5 miles radius from an airport of any size or the necessary NOTAM will be filed for safe operation in advance of operations. 7. Flight zones will be located at the maximum distan ce away from persons, inhabited structures, and vehicles that is possible given the lay out of the property. The flight zone in which operations occurs will be assigned based on the real time traffic, activities, and weather conditions. 8. Flights will be limited to a speed of 30 mph and vertic al ascent will be limited to 15 mph. 9. The UAS will be operated and maintained in accordan ce with the requirements of the Phantom 3 User Manual and any manufacturer Safety Bulletins. 10. Prior to the operation, the flights will be fully pr eplanned and briefed, including possible contingencies and emergency procedures. 11. The UAS will have the capability to abort flight in the case of unpredicted obstacl es or emergencies. 12. All required permissions and permits will be obtained fro m territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 13. All UAS operations will occur in dayli ght, Visual F light Rules ("VFR") conditions. Instrument flight rules flights are prohibited and no flights will occur at night, or in adverse weather conditions. 14. The UAS will be controlled by the Phantom 3 Standard or Advanced Remote Control Sy stem and the radio frequency spectrum used for operation and control of the UA shall comply with the Federal Communications Commission ("FCC") or other appropriate government oversight agency requirements.

IV. Regulations From Which Exemption is SoughtThe Feder al 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 § 40101 of the Act, including UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. Adam H. Guthrie seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using UAS. Listed below are: (1) the specific sections of 14 C.F.R. for which exemption is sought, and; (2) reasons why the exemption would not adversely affect safety or provide a level of safety equivalent to the rule, including any operating procedures and s afeguards that Adam H.
Guthrie has adopted which will ensure a level of safety better than or equal to the rules from which exemption is sought.

a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness certificates.
Adam H. Guthrie requests exemption from this subpart to operate the Phantom 3 without the requirement for an airworthiness certificate. Based on the proposed UAS being limited in size, weight, speed , operating capabilities, and operating within VLOS, Adam H. Guthrie believes that an airworthiness certificate is not necessary to ensure an equivalent level of safety to manned aircraft operations.

Equivalent Level of Safety

The UAS indicated is safe when taking into account its size, weight, speed, and operational capability. As set forth above, the Phantom 3 weighs less than 7 pounds and will be flown at less than 30 mph and completely outside controlled airspace. Additional ly, the craft carries pilots nor passengers, carries no explosive materials and or flammable liquid fuels, and operates exclusively within the parameters stated in the Guide.

Operations conducted under this exemption will be closely controlled and monitore d by the PIC and will be conducted in compliance with local public safety requirements, to provide security for the area of operation. In all cases, the UAS operated under the proposed conditions, will be at least as safe as, or safer than conventional rot orcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

Further, the Phantom 3 does not need a means to communicate with other aircraft or ATC, because those capabilities will be possesse d by the PIC and Observer, who are not onboard the UAS. See Grant of Exemption, Docket FAA

- 2014

- 0352 at 13. In addition, the UAS will be operated at all times in
visual line

- of

- sight and in VFR conditions. Id

.b. 14 C.F.R. Part 27: Airworthiness Standar ds for Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of
normal cate gory rotorcraft. To the extent Adam H. Guthrie’s UAS would otherwise require certification under Part 27, it seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

c. 14 C.F.R. §§ 45.23(b) and 45.27(a): Marking of the Aircraft

Adam H. Guthrie seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 45.23(b) and 45.27(a).

14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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 m ore than 6 inches high, the words "limited," "restricted," "light

sport, "experimental," or "provisional," as applicable.

14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the Phantom 3 is by definition “ unmanned ” and so has no entrance to a cabin, cockpit, or pilot st ation on which the above stated words can be placed. Given the size of the UAV, two

- inch lettering may be impossible. The word “ Exempt ” can be placed on the fuselage in compliance with 14 C.F.R. § 45.29(f).

Equivalent Level of Safety

The equivalent level o f safety will be provided by having the Phantom 3 marked on its fuselage as required by 14 C.F.R. § 45.29(f) where the pilot, observer and others working with the UAS will see
the identification of the Phantom 3 Standard or Advanced as “ Exempt ” if so desir ed. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

d. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in ai rworthy 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
Phantom 3 Standard or Advanced, the descr iption of proposed operations above, an equivalent level of safety will be provided.e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil Aircraft Flight Manual in the Aircraft

14 C.F.R. § 91.9(b)(2) states:

(b) No person may operate a U.S.

- registered civil aircraft

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

14 C.F.R. § 91.203(a) and (b) state:

(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 c urrent airworthiness certificate...

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

Given the small size and configuration of the Phantom 3, it would be impossible to keep
airworthiness documents and other aircraft manuals on board the UAS because there is simply no room. Also the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an F AA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UA S flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved be ensuring that the pilot has access to the documents at the ground control station or point of control from which he or she is piloting the Phantom 3.

f. 14 C.F.R. § 91.103: Preflight Actions

This regulation requires each pilot in command to take certain actions before flight to ensure the safety of flight. As FAA approved flight manuals will not be provided for the aircraft an exemption
will be needed.

Equivalent Level of SafetyAn equivalent level of safety will be provided through the PIC following the procedures set forth

in the Guide and Manufacturer ’ s User Manual. The PIC will take all actions including reviewing weather, flight battery requirement s, landing and takeoff distances and aircraft performance data before initiation of flight. The PIC will account for all relevant site

- specific conditions in the preflight procedures. The FAA has granted exemption from this regulation to other small UAS op erators. See Exemption No. 11109.

g. 14 C.F.R. § 91.109(a): Flight Instruction

Adam H. Guthrie seeks an exemption from flight instruction requirements contained within 14 C.F.R. § 91.109(a). This section 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 f ully functioning dual controls.

Equivalent Safety Protocol

For student training purposes the PIC and student may use a "buddy box" system that utilizes

two transmitters when applicable. The transmitter of the student is connected by a trainer cable to another transmitter (master transmitter) controlled by the PIC instructor. The PIC Instructor is able to control the UAS with his or her transmitter then flip a switch to turn control over to the student and flip the switch again to reclaim control. In this way, the PIC Instructor can easily demonstrate how to fly the UAS or rescue the UAS if the student makes a poor aeronautical decision without passing the same transmitter back and forth to preserve safety to the NAS and manned aircraft operations.

Given the size and speed of the UAS that the Adam H. Guthrie intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required by the Guide, all persons will be a safe distance away in the event that any difficulties during flight instruction occurs. Moreover, Petitioner will conduct training in a controlled and
sterile e nvironment. As required by the Guide, training and instruction will be conducted in a sterile area on property that is owned and controlled by Adam H. Guthrie . These facilities will not be open to the public during UAS operations, and access will be restri cted to authorized business personnel involved with the company.

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

Adam H. Guthrie requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum sa fe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at
less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An e xemption is required because the proposed UAS operations will occur at under 200 feet AGL. Further, while the Phantom 3 will never be flown in or over congested areas, due to the nature andlocation of the proposed operations, the PIC, Observer(s), Instruc tors and/or Students may at times be

less than 200 feet away from the UAS.

Equivalent Safety Protocol

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel onboard the Phantom 3, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the Phantom 3, as well as the controlled
and s terile location where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 200 feet AGL or below. As set forth in the Guide, the Phantom 3 flight height and radius restrictions will be set accord ing to each operator ’s level of experience which will be judged by the PIC. The Phantom 3 will be operated in an area that is owned by the client and closed to the public when in use. These restrictions will ensure that the proposed UAS operations are perf ormed in a manner that protects the safety of participants, nonparticipants, the UAS, and other property.

i. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an
aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that
the Phantom 3 does not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Safety Protocol

The Guide requires compass calibration prior to each operation of the Phantom 3 to ensure the GPS functions correctly. The Phantom 3 Standard or Advanced User Manuel contains instructions for achieving t his and the manufacturer, DJI, will provide additional support if necessary.

j. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Adam H. Guthrie requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in
VFR condit ions. Section 91.151 states:

(a) No person may begin 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 spe ed

–

i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes.

Here, the technological limitations on the energy capabilities of th e battery used in the Phantom 3 means that no meaningful flig ht operations can be condu cted with the Phantom 3 while still maintaining a 30 minute battery reserve. An exemption from the fuel requirements of

14 C.F.R. § 91.151(a) is therefore required.Equivalent Safety Protocol

The batteries powering the Phantom 3 provide approximately 25 minutes of flight time. Training operations will be limited to a minimum voltage to ensure appropriate reserve battery to maintain an equivalent level of safety at all times. The UAS will notify the operator when they are approaching and they are required to land at their home point and either switch out the battery or pause operations for recharging. If both the operator and PIC fail to land the UAS prior to the allotted minimum voltage, the
UAS wil l autonomously return to its original launch position.

k. 14 C.F.R. §§ 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections

Adam H. Guthrie seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R., sections 91.405, 91.4 07, 91.409, and 91.417. These rules specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See
, e.g. , 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in s ubpart E of this part and shall between required inspections
... have discrepancies repaired as described in part 43 of this chapter. ” ) Exemption from these rules is requested because these sections of Title 14 require the aircraft to be maintained and inspec ted in accordance with Part 43, which only applies to aircraft with
an airworthiness certificate. Therefore, based on the exemptions sought, these sections do not apply to
Adam H. Guthrie proposed UAS operations.

Equivalent Safety Protocol

Maintenance will be accomplished by authorized operators, staff, and/or contracted labor pursuant to the Guide and the Manufacturer ’ s User Manual. An equ ivalent level of safety will be

a chieved because a UAS like the Phantom 3 Standard or Advanced or like craft and its pl atform are very limited in size, will carry a small payload, and will operate only in defined areas for limited periods of
time. If mechanical issues arise the Phantom 3 Standard or Advanced will be able to land immediately on property owned by the client and or owner of the craft to receive immediate maintenance. As provided
in the Guide and Manufacturer ’ s User Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and will keep a log of any maintenance performed.

l. 14 C.F.R. Part 61, 14 C.F.R. §§ 61.3, 61.113: Private Pilot Privileges and

Limitations

Adam H. Guthrie will serve as the PIC for all flight operations and the instructor/coinstructor of any course including an element of drone flight. This should qualify persons with a private pilot’s certificate, among other qualifications, to instruct drone operation education when necessary. However, as is the nature of the proposed operations, introductory flight instruction using the Phant om 3 UAS willbe provided to staff who will likely not have a private, or any type of, pilot ’ s license. Accordingly, Adam

H. Guthrie seeks exemption from 14 CFR Part 61, including 14 CFR § 61.3 to the extent that these regulations are interpreted as requir ing a student receiving UAS operation instruction to have a private pilot's certificate. All student instruction flights will be conducted under closely controlled circumstances, outside of navigable airspace and away from persons or property not involved in the instruction. In addition, the student instruction flights will be conducted under the close supervision of an instructor acting as PIC.

In addition, to the extent that Adam H. Guthrie may be employing persons with a private pilot’s license to operat e its UAS, an exemption is also sought from 14 C.F.R § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also require a second class medical certificate. The purpose of this section is to ensure the skill and competency of any PIC where the aircraft is carrying passengers or cargo for hire. In this case, while instructors acting as PIC during UAS operations will be doing so for educational purposes as part of Adam H. Guthrie’s staff, the
Phantom 3 or like craft carries neither passengers nor cargo. Moreover, in the Astraeus Aerial Grant of Exemption (FAADocket No.FAA

- 2014

- 0352), the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warr ant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class I or II Medical Certificate.

Equivalent Level of Safety

Adam H. Guthrie will ensure an equivalent level of safety to the regulatory requirements of 14 C.F.R. Part 61, including 14 C.F.R. §§ 61.3 and 61.113 by following the safety procedures provided in the Guide. In addition to training and experience requirements and limitations, Adam H. Guthrie has placed
additional restrictions on i ts proposed UAS operations to ensure an extra margin of safety. The UAS will only operate in a controlled and sterile area away from persons and property not involved in the operation. It will be flown based on VLOS at no more than 200 feet AGL. Collective ly, these procedures ensure that the proposed UAS operations can be conducted safely.

V. Public Interest

Because the technology to provide photographs that can better facilitate clients desires to market real estate for the purchase of real estate has advanced to a degree that is not possible from traditional photography the public will be well served by offering aerial photographs that can better produce the desired results. Some of which include the depiction of the beauty and aesthetics of a
property for marketing purposes or the location of a property to surrounding adverse conditions that may affect the decision process of an institutional lender when making a loan for a particular property.

VI. Privacy

All of Adam H. Guthrie’s UAS operations shal l be conducted in accordance with applicable federal, state, or local laws regarding privacy. Adam H. Guthrie will not conduct flight operations over property that it does not own or control without the prior consent and knowledge of the property
owner. Mo reover, Adam H. Guthrie will not capture or use images from restricted areas requiringprivacy and or confidentiality under any circumstance. This does not mean, however, that images may

not be taken that are permitted by law and do not require a level of privacy that is an exception to the

norm.

VII. Federal Register Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following sections in Title 14 of the Code of Federal

Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.3; 61.113; 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1 ); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners by (a) ensuring that the operations of the UAS described above are recognized by the FAA in the form of an exemption (b) h ow to safely operate small UAS in furtherance of career objectives and to the benefit of public safety while providing a valuable service as it relates to the real estate business provided by
Adam H. GuthrieAPPENDIX A

Adam H. Guthrie UAS Standard Operating Guide

▫ Any UAS in operation must weigh less than 55 pounds at its maximum take

- off weight.

▫ Flights will be operated within the VLOS of the PIC and an observer, at a minimum.

▫ Maximum total flight time for each operational flight wil l be limited to 25% reserve battery power remaining.

▫ Flights will be operated at an altitud e of no more than 200 feet AGL.

▫ Radius and altitude limitations will be set according to an assessment of the experience level o f the operator for each flight.

▫ All operations will be conducted in class G airspace.

▫ Flights will be restricted to pre

- determined areas of the client/owners property.

▫ Flight zones will be located at the maximum distance away from persons, inhabited structures, and
vehicles that is possible given the lay out of the property. The flight zone in which operations occurs will be assigned based on surface and air traffic, acti vities, and weather conditions.

▫ Flights will be limited to a speed of 30 mph and vertic al ascent will be limited to 15 mph.

▫ The UAS will be operated and maintained in accordan ce with the requirements of the Phantom 3 User Manual and any manufacturer Safety Bulletins.

▫ Prior to the operation, the flights will be fully pr eplanned and briefed, including possible cont inge ncies and emergency procedures.

▫ The UAS will have the capability to abort flight in th e case of unpredicted obstacles or emergencies.

▫ All required permissions, NOTAM ’ s and permits wil l be obtained from territorial, state, county or city jurisdictio ns, including local law enforcement, fire or other app ropriate governmental agencies.

▫ All UAS operations will occur in daylight, Visual F light Rules ("VFR") conditions. Instrument flight rules flights are prohibited and no fli ghts will occur at night, or in adverse weather conditions.

▫ The UAS will be controlled by the Phantom 3 Standard or Advanced Remot e Control System or like system and the radio frequency spectrum used f or operation and control of the UA shall comply with
the Federal Communicati ons C ommission ("FCC") or other appropriate government oversight agency requirements.APPENDIX B

AMA Advisory Circular ADVISORY CIRCULAR DEPARTMENT OF TRANSPORTATION Federal Aviation Administration Washington, D.C.

Subject: MODEL AIRCRAFT OPERATING STA NDARDS

1. PURPOSE. This advisory circular outlines, and encourages voluntary compliance with, safety standards for model aircraft operators.

2. BACKGROUND. Modelers, generally, are concerned about safety and do exercise good judgement when flying model air craft. However, model aircraft can at times pose a hazard to full

- scale aircraft in flight and to persons and property on the surface. Compliance with the following standards will help reduce the potential for that hazard and create a good neighbor environ ment with affected communities and airspace users.

3. OPERATING STANDARDS.

a. Select an operating site that is of sufficient distance from populated areas. The selected site should be away from noise sensitive areas such as parks, schools, hospitals, churc hes, etc.

b. Do not operate model aircraft in the presence of spectators until the aircraft is successfully flight tested and proven airworthy.

c. Do not fly model aircraft higher than 400 feet above the surface. When flying aircraft within 3 miles of

an a irport, notify the airport operator, or when an air traffic facility is located at the airport, notify the control tower, or flight service station.

d. Give right of way to, and avoid flying in the proximity of, full

- scale aircraft. Use observers to help i f possible.

e. Do not hesitate to ask for assistance from any airport traffic control tower or flight service station concerning compliance with these standards.

R.J. VAN VUREN

Director, Air Traffic Service

Initiated by: AAT

- 220APPENDIX C

AMA Safety Code

Academy of Model Aeronautics National Model Aircraft Safety Code

Effective January 1, 2014

A. GENERAL : A model aircraft is a non

- human

- carrying aircraft capable of sustained flight in the

a tmosphere. It may not exceed limitations of this code and is intended exclusively for sport, recreation

, education and/or competition. All model flights must be conducted in accordance with this safety code and any additional rules specific to the flying site.

1. Model aircraft will not be flown: (a) In a careless o r reckless manner. (b) At a location where model aircraft activities are prohibited.

2. Model aircraft pilots will: (a) Yield the right of way to all human

- carrying aircraft. (b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document#540

- D.) (c) Not fly higher than approximately 400 feet above ground lev el within three (3) miles of an airport
without notifying the airport operator. (d) Not interfere with operations and traffic patterns at any air port, heliport or seaplane base except where there is a mixed use agreement. (e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane p rogram. (AMA Document 520

- A.) (f) Ensure the aircraft is identified with the name and addres s or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This does not apply to model aircraft flown indoors.) ( g) Not operate aircraft with metal

- blade propellers or with gaseous boosts except for helicopters operated u nder the p rovisions of AMA Document #555. (h) Not operate model aircraft while under the influence of alcoh ol or while using any drug that could adversely affect the pilot’s ability to safely control the model. (i) Not operate model aircraft carrying pyrot echnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property.

Exceptions:

• Free Flight fuses or devices that burn producing smoke and are securely attached to the model
airc raft during flight. • Rocket motors (using solid propellant) up to a G

- series size may be used provided they remain attached to the model during flight. Model rockets may be flown in accordance with the National Model Rocketry Safety Code but may not be la unched from model aircraft.• Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as

defined within the Team AMA Program Document. (AMA Document #718.)

(j) Not operate a turbine

- powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510

- A.)

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations
unless:

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. (b) An inexperienced pilot is assisted by an experienced pilot.

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply with comparable standards.

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures
and shall avoid endangerment of life and property of others. 2. A successful radio equipment ground

- r ange check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model aircraft. 3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.)

(a) Only personnel associated with flying the model aircraft are allowed at or in front of

t he safety line. (b) At air shows or demonstrations, a straight safety line must be established. (c) An area away from the safety line must be maintained for spectators. (d) Intentional flying behind the safety line is prohibited.

4. RC model aircraft must use the radio

- control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly licensed by the FCC are authori zed to operate equipment on Amateur Band frequencies. 5. RC model aircraft will not knowingly operate within three (3) miles of any pre

- existing flying
site without a frequency

- management agreement. (AMA Documents #922 and #923.) 6. With the exception of e vents flown under official AMA Competition Regulations, excluding
takeoff and landing, no powered model may be flown outdoors closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline.
7. Under no circu mstances may a pilot or other person touch an outdoor model aircraft in flight
while it is still under power, except to divert it from striking an individual. 8. RC night flying requires a lighting system providing the pilot with a clear view of the model’ s attitude and orientation at all times. Hand

- held illumination systems are inadequate for night flying operations.9. The pilot of an RC model aircraft shall:

(a) Maintain control during the entire flight, maintaining visual contact without
enhancement o ther than by corrective lenses prescribed for the pilot. (b) Fly using the assistance of a camera or First

- Person View (FPV) only in accordance
with the procedures outlined in AMA Document #550. (c) Fly using the assistance of autopilot or stabilization sy stem only in accordance with theprocedures outlined in AMA Document #560.

C. FREE FLIGHT

1. Must be at least 100 feet downwind of spectators and automobile parking when the model
aircraft is launched. 2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function.

D. CONTROL LINE

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to flying. 2. The pull test will be in accordance with the current Competition Regulations for the applicable
model aircraft category. 3. Model aircraft not fitting a specific category shall use those pull

- test requirements as indicated for Control Line Precision Aerobatics. 4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown
closer than 50 feet to any above

- ground electric utility lines. 5. The flying area must b e clear of all nonessential participants and spectators before the engine
is started.