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 Real tor® , 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 operatio nal approach (closer than 500’) and equipment being u tilized (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 f rom 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 airc raft 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 ope rations 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) responsibi lities 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 t o 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

, Re altor® 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 promotelocal economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containin g 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 th e 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 re lief Travis Campbell Realtor® seeks and the reason they seek such relief:

Travis Campbell Realtor® submits this application in accordanc e with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent co mmercial 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 i n 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. We ighing 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 small

unmanned aircraft is designed to hover in place via GPS and operate in less tha n 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 pilotcommunication 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 hundre d (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 aircra ft approach their location or should the y suspect manned aircra ft 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 (2 00) 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 U AS/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 a nd 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 Cam pbell 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 thei r 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 minimi zing ecological an d 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 spacefurthers economic growth. Granting their exemption request sub stantially 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 Rea ltor® 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 aer ial 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 Campbe ll, Realt or® wil l only operate their UAS below 2 00 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 wil l land their UAS prior to manufacturer re commended 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 flig ht 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 wil l 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 wil l 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 r ules. The potential loss of life is diminished because UAS's carry no people on board and only operates in specific are as away from mass populations. T here is No fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. The s mall 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 pe rmits 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 o f 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 3 2827.

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

an d 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 A ircraft. 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. Fur ther, 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” o n 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 alti tude greater than 2 00 AGL; in accordance with the standard of 400 AGL. Travis Campbell Realtor® willoperate 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 pres cribed 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 ins pect 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 fort h 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