I**~OUTER EACHES~** **~~** '··..**J~-· ~-**  .I0/20/2015 ->· ._.: Hatteras Island, North Carolina Offices atthe followinglocations: Avon Mail all correspondence to: P.O. Box 280 40227 Tigrone Boulevard Avon, NC 27915LOCAL 252-995-4477FAX: 252-995-6137TOLL FREE800-627-3150FAX: 800-627-3250 Waves

25206 Sea Vista Drive Waves, NC 27982 FAX:252-987-2803 Hatteras Village 57205 Eagle Pass Road Hatteras, NC 27943 FAX: 252-986-1457 E-Mail info@outerbeaches.com Web Address www.outerbeaches.com**.·:_:;~~** r:".. ...**~i..J** .•,.)-·: Docket Operations, M-30 US Dept. ofTransportation 1200 New Jersey Ave, SE Room W12-140, West Bldg. Ground Floor Washington, DC 20590-0001 -'. ..../ •' ';! ...-..?I ·-· -I RE: Petition for Exemption (COA) Request under Section 333 ofthe Federal Aviation Administration Modernization and Reform Actof 2012 and Part 11ofthe Federal Aviation Regulations Dear Siror Madam, Pursuant to Section 333 of FAA Modernization Actof 2012 and 14 CFR Part 11, Outer Beaches Realty, a premier real estate company offering property management, vacation rentals and sales, hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operations ofit'sDJI Phantom II,a small unmanned aircraft system (UAS), so long as such operations are conducted

within and under the conditions and limitations outlined herein oras may be established bythe FAA as required by Section 333. These limitations provide forat least an equivalent or even higher

level of safety to operations under the current regulatory structure. Outer Beaches Realty seeks the ability to offer realistic images ofour vacation homes and their proximity within the coastal community to the public using the latest technology, such as UAS. We wish to conduct these operations inthe highest level, reducing risk and improving overall safety. Therefore, itisinthe best interest ofthe public for the FAA to approve Outer Beaches Realty, Section 333 exemption to conduct UAS operations to photograph vacation homes and the environment we live. SincV.**)Lan~R~"-** President, Outer Beaches Realty'-..

RE: Outer Beaches Realty, Inc Avon, NC 27915 Request for Certificate of Waiver (COA) for UAS/ Drone operation Section 1: Introduction and Interest of Petitioner. Outer Beaches Realty, family owned and operated, isthe premier real estate company on Hatteras Island. Conveniently offering property management, vacation rentals and sales under one roof. Our promise isto provide the highest level of customer service, safety, honesty, integrity and professionalism among all real estate companies onthe Outer Banks. Our primary market of customers is from North Carolina through New England and west to Ohio/Kentucky. Also eastern provinces of Canada. Section 2: Unmanned Aerial Systems Regarding the Unmanned Aircraft System 1. Petitioners should describe how the proposed VAS operation willbe safely conducted to minimize risktothe NAS orto persons and property onthe ground. Spec(fically, petitioners should describe the design and operational characteristics for the type(s) of VAS they intend to operate, e.g. aircraft pe1:{ormance and performance limitations, operating procedures, and aircraft loading information inas much detail as possible. This could be provided inthe petition orinan Aircraft Flight Manual or similar document. NOTE: The FAA will consider all information and data submitted bythe petitioner that describes the VAS developmental and operational hist01y. This could include statistical data or other documentation for the specific design and performance characteristics ofthe VAS, including the operational hist01y and operationalfailure modes, obtained through previous Research & Development (R&D) andlor.flight test activities, e.g. operations conducted under a COA, witha civil ainvorthiness certificate, or under other authorized operating conditions. 2. Petitioners should describe any procedures they ·would implement, such as preflight inspections, maintenance, and repair, to ensure that the VASisina condition for safe flight. This could be provided inthe petition, an Aircraft Flight

Manual, a Maintenance and inspection Manual, or similar document.

NOTE: The Aircraft Flight Manual and Maintenance and inspection Manual may be separate documents or combined ina single document.\1\\ \

3. The petitioner should describe the Radio Frequency (RF) spectrum usedfor control ofthe VAS and associated equipment thatispart ofthe VAS (i.e., sensors, cameras, etc.), and whether it complies with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. NOTE: Petitioners should be ableto provide the FCC approval letter or show compliance with FCC requirements upon request. General Information Pertaining to Proposed UAS Outer Beaches Realty will safely operate less than fifty-five pound unmanned aircraft system (VAS), with the ability to capture photos and videos to support our marketing efforts of vacation rentals. Prior to each flight the Pilot in Charge (PIC) shall inspect the VAS to ensure itisina condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe VAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the VASis found tobeina condition for safe flight. The Ground Control Station must be included inthe

preflight inspection. Outer Beaches Realty shall follow the manufacturer's VAS aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements. Outer Beaches Realty shall carry out their maintenance and inspections requirements in accordance with the operator's manual. The VAS operated under the proposed exemption shall comply with the manufacturer's operations manual. Before conducting operations, the radio frequency spectrum used for operation and control ofthe VAS shall comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements. DJI Phantom II Outer Beaches Realty seeks an exemption to operate DJI Phantom IIVAS,a lightweight, multi-functional integrated aircraft and camera. The DJI Phantom IIis

comprised ofa quad rotor unmanned aircraft anda handheld ground control station. The DJI Phantom IIhasa maximum gross weight of approximately 2.8 pounds, diameter (rotor span) 23.75 inches, width of 12.5 inches, and height of8.1l'**-~ ~.::::.**  l01**~** l.\,

inches. The DJI Phantom IIis equipped with four rotors driven by four lithium polymer battery powered electric motors.

Design and operational characteristics are provided inDJI Phantom II Operating Manual. (See attached PDF) Section 3: Unmanned Aircraft Pilot in Command (PIC) 4. Petitioners should describe the qual(fications required ofany PIC(s) who willbe directly responsible.for the operation ofthe UAS, including information such as: the level of airman cert(ficate held; any applicable training related tothe operation; and any minimum hours a,( flight experience required bythe PIC(s), both Iota/flight time and the time with the particular UAS. {(the operation would

use visual observers, petitioners should describe their roles and qual(fications. Request relief with limitations and conditions specified inthis petition. 5. Petitioners should describe the medical standards and cert(fication ofthe PIC(s) directly responsible for the operation ofthe UAS. Request relief with limitations and conditions specified inthis petition. Section 4: Operations of UAS Regarding the Operation ofthe Unmanned Aircraft 6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the proposed operation(s) would not adversely affect safety, or how they would provide alevel of safety at least equivalent tothat provided bythe rule .from which exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure public safety, which includes persons and property both intheair andonthe ground. This canbe described inthe petition, inan Operations Manual.-·'"or similar document. NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of

flight, NAS safety considerations, and the safety ofthe non-participating persons and prope"C_ty during the operational period and within the operational area. 7. Petitioners should specify tlze proposed ma:rimum operating speed and altitude, and describe minimum flight visibility and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and safety mitigations

associated with these proposed conditions. These issues canbe addressed inthe petition, an Operations·Manual, or similar document. \-""""-" ...,......

The UAS shall remain clear and yield the right of waytoall other manned aviation operations and activities atall times. The UAS shall be operated atan altitude ofno more than 400 feet above ground level. The multi-rotor UAS shall notbe flown ata ground sped exceeding 30 mph. The UAS Operations will be conducted under visual meteorological conditions (VFR). The UAS will notbe operated less than 500 feet below orless than 2000 feet horizontally froma cloud or when visibility isless than3 statute miles from the PIC. Ifthe UAS loses communications or loses its GPS signal, it must return toa predetermined location within the planned operating area and land. The UAS PIC must abort the flight inthe event ofunpredicted obstacles or emergencies in accordance with the operating documents. The UAS PICis prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power toflyat normal cruising speed tothe intended landing point and land the UAS with 25% battery power remaining. 8. Petitioners should describe the characteristics ofthe area of intended operation(s) and the associated potential hazards, in accordance ·with the statutory mandate under Section 333 regarding proximity to populated areas. These issues canbe addressed inthe petition, an Operations Manual, or similar document. The UAS shall notbe operated oyer congested or densely populated areas. These areas included but arenot limited tothe yellow areas depicted on World Aeronautical Charts, Sectional Aeronautical Charts, or Terminal Area Charts. Each site will also be evaluated based on local conditions.'. All operations ofDJI Phantom IIshall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from the property owner/controller or authorized representative will be obtained for each flight tobe conducted. The UAS will be used to capture photos and videos of Hatteras Island, NC and specifically homes managed by Outer Beaches Realty.9. Petitioners should describe ifthey intend to operate inthe proximity ofany airports, in accordance with the statutory mandate under Section 333 regarding proximity to airports.There is only one airport located on Hatteras Island where the UAS will be used .... Billy Mitchell, HSE, an unmanned 3,000 ft airstrip with no commercial operations. Should UAS operations be performed within 5 miles, the PIC will announce intentions and location viaa handheld radio on HSE frequency aswell as announce 'Clear' when concluded. Inall cases, operation ofthe UAS will cease immediately ifany aircraft isin the areaas evidenced by visual confirmation orvia radio broadcast onthe HSE frequency, until aircraft has landed orleft vicinity. 10. The VAS must be operated within visual line-of-sight (VLOS), in accordance with the statutory mandate under Section 333(b)(1). Petitioners should describe hmv they intend to comply with his mandate. The UAS must be operated within VLOS ofthe PICatall times. This requires the PICto

be abletouse human vision toseethe UAS unaided byany device other than corrective lenses.The UAS will notbe operated bythe PIC from any moving device or vehicle. Operations will notbe conducted during night.

11. Petitioners should describe any procedures they would implementfor conducting a preflight safety risk assessment to determine that the VASisina condition for safejlight (14CFR§91. 7(b)) and that the planned operation canbe completed safely. These procedures canbe addressed inthe petition, an Aircraft Flight Manual, Operations Manual, or similar document. Outer Beaches Realty will conduct preflight safety risk assessments to determine that the

UAS isina condition for safe flight and that the planned operation canbe completed safely.The pre-flight checklist provided by The Public Safety Flight website will be used. (*See attached document) Outer Beaches Realty will check the UAS for damaged or worn propellers, batteries, and other parts that should be replaced or· repaired before flight. Outer Beaches Realty will ensure the flight battery, remote controller, WI-FI range extender, and all other necessary items are fully charged.12.If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) prior to operations -such as motion picture and television filming, or pipeline and powerline patrol.- petitioners should describe their intended coordination inthis regard for their proposed operation(s). Outer Beaches Realty's operations do not require a notification to Flight Standards District Offices. 13. The FAA intends to require entities who obtain an exemption under this process to also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting operation(s) inthe NAS. Outer Beaches Realty shall obtain anAir Traffic Organization issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this requested grant of exemption. Section 5: Requested Exemptions from Regulations Airworthiness Certificate- Outer Beaches Realty recommend thatin consideration of the size, weight, speed and limited operating area associated with this aircraft andits operation, the Secretary of Transportation determines that the aircraft meet the conditions of Section 333. Display of Marks- Outer Beaches Realty DJI Phantom shall be identified bya serial number from the manufacturer. Additional identification numbers will beas large as practicable. Private pilot privileges and limitations -The FAA has found in previous grants of

exemption that the absence ofa licensed PIC witha private pilot certificate operating a UAS would not adversely affect operations inthe NAS or present a hazard to persons or property onthe ground. Commercial pilot privileges and limitations -The FAA has found in previous grants of exemption that the absence ofa licensed PIC witha private pilot certificate operating a UAS would not adversely affect operations inthe NAS or present a hazard to persons or property onthe ground. Civil Aircraft Ainvorthiness - Outer Beaches Realty recommends thatin consideration ofthe size, weight, speed and limited operating area associated with this aircraft anditsoperation, the Secretary of Transportation determines that this aircraft meets the conditions of Section 333. Civil Aircraft Flight Manual, Marking, and Placard Requirements -The FAA has previously determined that relief from these sections isnot necessary. Relevant materials may be kept ina location accessible tothe PICin compliance with the regulations. Preflight Action - Outer Beaches Realty will perform according to standardized procedures. Minimum Safe Altitude- Aircraft will be operated below 400ft., but not over congested areas. Altimeter Settings- The proposed aircraft havea barometric altimeter and GPS derived altitude capabilities. Outer Beaches Realty recommends that the altimeter besettozero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude ofthe proposed operations. Maintenance Required- Request relief with limitations and conditions specified inthis petition. Operation after Maintenance- Request relief with limitations and conditions specified inthis petition.Inspections - Request relief with limitations and conditions specified inthis petition. Maintenance Records- Request relief with limitations and conditions specified inthis petition.Oct 15, 2015