Dear Sir or Madam, 

Travis Campbell Realtor® seeks exemption pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, from the 

Federal Aviation Regulations (“FARs”) listed below so that Travis Campbell 

Realtor®, may operate their small ultra-light weight unmanned aircraft system 

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

(“FAA”). 

This petition is, in most regards, similar to granted exemption No. 11138 both in 

operational approach (closer than 500’) and equipment being utilized (DJI Phantom 

3 Advanced). 

As described herein Travis Campbell Realtor® real estate agent licensed within the 

State Texas has added a UAS to their inventory equipped with a DJI camera with 

intent for aerial videography/cinematography to enhance community awareness for 

those individuals and companies unfamiliar with the geographical layout of real 

estate listings in the state of Texas, and augment real estate listing videos; following 

exemption and approval by the FAA. 

Travis Campbell Realtor® exemption request would permit operation of ultra-light 

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

tightly controlled and limited airspace. Predetermined in areas away from general 

public, airports, heliports and vehicular traffic for community videos, and within 

property boundaries for individual homeowner real estate listing. Travis Campbell 

Realtor® has instilled safety 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 Travis Campbell 

Realtor® records 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. 

Protocols and Controls 

Travis Campbell, Realtor® 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 Travis Campbell, Realtor® will conduct their operations in 

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

FAA. 

For the reasons stated below Travis Campbell, Realtor® respectfully requests the 

grant of an exemption allowing operation of ultra-light weight, remote controlled 

UAS’s for community awareness to benefit/stimulate attraction to the Indiana real 

estate market and to enhance real estate listing videos for homeowners who cannot 

afford expensive manned aircraft for the same purpose. Both of which will promote 
local economic growth through increased employment and increased tax base. Both 

with public safety in mind by keeping heavier manned aircraft containing combustible 

fuel that that poses potential public hazard. 

I. Contact Information: 

Travis Campbell, Realtor®

10925 Briar Forest Dr #1107 Houston, TX 77042

Mobile: (832) 463-8333

Email: travis.tamu12@gmail.com

II. The Specific sections of Title 14 of the Code of Federal Regulations from 

which Travis Campbell, Realtor® requests exemption: 

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). 

III. The extent of relief Travis Campbell Realtor® seeks and the reason they 

seek such relief: 

Travis Campbell Realtor® submits this application in accordance with the Reform 

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

operating to prevent commercial cinematic 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. Travis Campbell Realtor®, ultra-light weight UAS 

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

therefore the integration of their ultra-light weight UAS is expressly contemplated by 

the Reform Act. Travis Campbell Realtor® would like to operate their ultra-light 

weight UAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. 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 are in favor of an exemption for Travis Campbell Realtor®. Their 

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

Their UAS is equipped with GPS and auto return safety technology. Weighing less 

than ten (10) pounds (far below the maximum 55 pound limit); including camera. 

Travis Campbell Realtor®, considers safety as foremost with each flight. Their smallunmanned aircraft is designed to hover in place via GPS and operate in less than a 

24-knot (15 mph) wind. For safety, stability and fear of financial loss they will not fly 

in winds exceeding16 kph (10 mph). Built in safety systems include a GPS mode 

that allows their UAS to hover in place when radio controls are released. When pilot
communication is lost UAS is designed slowly descend to point of takeoff. Travis 

Campbell Realtor® will not operate their UAS near airports, Hospitals nor Police 

heliports, and will not operate near areas where general public is within fifty to one 

hundred (50-100) yards depending on location, conditions and weather. Travis 

Campbell Realtor® will be prepared to land/abort immediately to the nearest and 

safest ground point should a manned aircraft approach their location or should they 

suspect manned aircraft may approach near their location. Travis Campbell, 

Realtor® UAS is capable of vertical and horizontal operations, and will only be flown 

within line of sight of the operator. Utilizing battery power rather than combustible 

fuels, flights generally last between ten (10) to fifteen (15) minutes, with an altitude 

under two hundred (200) feet. Travis Campbell Realtor® will 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. Travis Campbell Realtor® will not operate their 

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 will be at hand with each exercise to insure 

replacement for sufficient safe level of operation. 

Travis Campbell Realtor® will exercise extremely caution when operating of their 

UAS/ultra-light 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 their 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. Travis Campbell Realtor® 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 Travis Campbell Realtor® request will benefit the public as a whole: 

Aerial videography for geographical awareness and 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 expense, depriving non-luxury 

homeowners and lower budget Realtors from a valuable marketing tool.. 

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 Travis Campbell Realtor®, exemption request furthers the 

public interest through visual awareness of the geographical benefits in Indiana. 

Their ultra-light weight UAS is battery powered and creates no emissions that can 

harm the environment. The consequence of their ultra-light 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 their battery operated ultra-light weight UAS's. 

Permitting Travis Campbell Realtor® to immediately fly within national air space 
furthers economic growth. Granting their exemption request substantially furthers the 

economic impact for the Houston, TX community for companies looking to relocate 

or build in the area as well as individuals looking to relocate, both of which serve as 

a stimulus to the community. 

V. Reasons why Travis Campbell Realtor® exemption will not adversely affect 

safety or how the exemption will provide a level of safety at least equal to 

existing rule: 

Travis Campbell Realtor® exemption will not adversely affect safety. The following 

represents enhancements to current aerial videography and photography for real 

estate: 

Their UAS weighs less than 10 pounds complete with a small ultra-light weight high 

quality DJI Long Range V2.0 camera;

• Travis Campbell, Realtor® will only operate their UAS below 200 feet (within the 

400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); 

• Their UAS only operates for 10-15 minutes per flight; 

• They will land their UAS prior to manufacturer recommended minimum level 

of battery power; 

• They will pilot their UAS through remote control only by line of sight; 

• Cobblestone Realty will utilize a private pilot with experience in manned and 

radio controlled aircraft operation; 

• Their UAS has GPS a flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost; 

• Their pilot will actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols; 

• They will only operate in reasonably safe environment, away from power 

lines, elevated lights, airports and actively populated areas; 

• They will conduct extensive pre-flight inspections and protocol, during which 

safety carries primary importance; 

• They will obtain all necessary permissions prior to operation; and, 

• They will have procedures in place to abort flights in the event breaches or 

potential danger of safety Travis Campbell Realtor® safety protocols provide 

a level of safety equal to or exceeding existing rules. The potential loss of life 

is diminished because UAS's carry no people on board and only operates in 

specific areas away from mass populations. There is No fuel on board a UAS 

and thus the potential for fire or explosions is greatly diminished. The small 

size and extreme maneuverability of the UAS allows for it to be remotely 

piloted away from and avoid hazards quickly and safely. 

VI. A summary the FAA may publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 
14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements 

for procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size and weight of Travis Campbell Realtor® UAS permits 

exemption from Part 21 because their UAS meets (and exceeds) an equivalent level 

of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

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

such as airports and dense populations. Travis Campbell Realtor®, UAS meets or 

exceed each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are 

no on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

safety/flight manual delineating areas of where safety can be FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

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

utilizes electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications 

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

equivalent level of safety will be achieved by maintaining any such required 

certifications and registrations by Travis Campbell Realtor®. 

14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. UAS are, by 

definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place 

on such small aircraft with dimensions smaller that minimal lettering requirement. 

Regardless, Travis Campbell Realtor® will mark its UASs in the largest possible 

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 

C.F.R. §45.29 (f) so that the pilot, or anyone assisting the pilot as a spotter with the 

UAV will see the markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 

1. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

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

It allows helicopters to be operated at lower altitudes in certain conditions. 

Their UAS will never operate at an altitude greater than 200 AGL; in 

accordance with the standard of 400 AGL. Travis Campbell Realtor® will 
operate their UAS in safe areas away from public and traffic, providing a level 

of safety at least equivalent to or below those in relation to minimum safe

altitudes. Given the size, weight, maneuverability and speed of the UAS, an 

equivalent or higher level of safety will be achieved. 

2. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. 

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 Travis Campbell Realtor®, UAS. However, as a safety 

precaution Travis Campbell Realtor® pilot will inspect their UAS before and after 

each flight. 

A Summary the FAA may Publish in the Federal Register: A. 14 C.F.R. 21 and 14 

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

H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size and 

weight of Travis Campbell Realtor® UAS permits exemption from Part 21 because 

Travis Campbell Realtor®, UAS meets an equivalent level of safety pursuant to 

Section 333 of the Reform Act. 

Respectfully Submitted,

Travis Campbell, Realtor® 

10925 Briar Forest Dr. #1107 

Houston, TX 77042