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AIR-CAM 

U.S. Department of Transportation, Docket Operations Date: 7-22-15 

West Building, Ground Floor, Room w12-140 

1200 New Jersey Ave., SE., Washington DC 20590 .-

Dear Sir or Madam: 

.-: =~~ 

KristopherHenkel DBA "ADVANTAGE AIR-CAM" hereby applies for an exemption from 

the listed Federal Aviation Regulations and any other rules necessary to allow operation 

of a small hobby sized (less than 5 Lbs.) unmanned aircraft (UAS) in order to produce 

aerial video of real estate for sale below a height of 400Ft. AGL. The purpose of UAS is 

to obtain video documentation of real estate for sale in order to provide interested 

parties visual information about chosen property previously not available before 

purchase. Video will safely show interested clients rooftops, vegetation, boundaries, 

streams, adjacent land, drainage issues, nearby roads and topography. Careful use of 

the UAS will greatly assist prospective buyers at selecting property while posing no 

safety or privacy threats to the general public, the participating inspection parties, or 

non-participating parties. 

This request is similar to previous grants of Exemption Nos 11109, 11112,11062 and 

111213 where the exemption was granted in the public interest. 

1. Kristopher D. Henkel DBA ADVANTAGE AIR-CAM 

80-130 Palm Circle Dr., La Quinta Ca. 92253 

Phone (760)343-0933 

Email Khe1144783@aol.com 

2. The specific section or sections of 14 CFR from which you seek an exemption: 

Exemption Request Pursuant to section 333 of the FMRA and Part 11 of the Federal 

Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. & 

45.23 (b); 14 C.F.R. & 45.27; 14 C.F.R. & 61.113(a) and (b) 14 C.F.R. & 91.119(c); 14 C.F.R. 

& 91.121; 14 C.F.R. & 91.151(a); 14 C.F.R. & 91.405(a); 14 C.F.R. & 91.407(a)(1); 

91.409(a)(1) and (2) 14 CFR && 91.417(a) and (b) 

3. The extent of relief you seek and the reason you seek relief: 

Kristopher D. Henkel DBA ADVANTAGE AIR-CAM requests relief and exemption from 

listed Federal Aviation Regulations and any other applicable rules in order to all of the 

use of a small unmanned aircraft system (UAS as defined by the U.S. Congress in 

section 331, PL 112-95, 2014; "6) SMALL UNMANNED AIRCRAFT: The term "small 

unmanned aircraft" means a small unmanned aircraft weighing less than 55 Lbs. "to 

conduct unmanned reconnaissance of specific properties to provide additional 
information to prospective buyers regarding their proposed purchase. The UAS will fly 

no higher than 400 Ft. above a selected property and and will not infringe on the 

property rights of the adjacent or nearby properties. The UAS will remain inside the 

selected properties and public by ways. All Commercial UAS flights will be scheduled 

with the owner/representative and a signed document will be required for flight 

photography. Every day thousand of properties are bought and sold with disregard to 

topography. UAS flights reveal to the prospective owner, Close up roof inspection, 

hidden flaws in design and other information unavailable from the ground. UAS flights 

reveal the character of the selected property with regard to surrounding topography and 

gives the potential buyer a fresh sense of Situational awareness unavailable without a 

manned aircraft fly over. 

4. How your request would benefit the public as a whole. 

A. Safety of real estate personnel is a paramount consideration. Persons attempting to 

gain high-resolution video and photos in area such a marsh land or swamp areas, 

pictures requiring high elevation pictures to improve perspective and pictures of roofs, 

porches, docks and from an adjacent lake. The simple production of otherwise risky 

photography minimizes impact on the general public. 

B. High Resolution photography and video from a UAS can be instantly transmitted to 

an interested parties for immediate resolution of pre-purchase questions thereby 

simplifying and shortening the decision making process for the potential buyer. Conflict 

resolution could be minimized for the general public. 

C. Aerial photography can be accomplished quickly and easily with little or no impact 

on the surrounding neighborhood. Modern UAS utilize quiet electric motors that are 

virtually silent and unobtrusive beyond 100Ft. Given the amount of information that can 

be gathered in less than 10 Minutes, UAS offers an immense advantage to conventional 

photo gathering services with minimal inconvenience to the general public. 

D. With the history of buying and selling property in our country, UAS will ultimately 

benefit a large proportion of the general public. With technological advances, the ability 

of UAS to enhance the buying and selling of real estate will reach everyone. Spectacular 

video of a property is at times, simply breathtaking compared to boring outside from the 

street or from an easement/ally. The real estate market benefits greatly from this new 

technology and is already improving sales on hundreds of homes. 

E. UAS could prove as the ultimate guarantor if the property is destroyed by fire or 

disaster. Insurance agents could receive proof of property condition prior to the 

damage. Claims would be resolved faster and recovery could be accomplished quicker. 

The general public will benefit from having more information about the property before 

the sale with high resolution photos. 

5. Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule. 

Safety would be the prime motivating factor. If the mission to gather information for 

prospective real estate buyers cannot be accomplished safely, then the mission must 
be aborted. Realizing while new technological cannot be adopted with absolutely no 

risk, given the protocols listed below, the implementation of the UAS for the 

Realty/surety market can be accomplished with minimal risk and would be safer than 

existing methods for procuring high resolution video and photos. 

A. The UAS would only be operated by myself, Kristopher Douglas Henkel, a 62 year old 

inactive private pilot with 140 Hours SEL, builder/pilot of a home built two seat 

Experimental Aircraft (Titan Tornado II) and 35 Hours flying Ultralight Aircraft. I am fully 

prepared to exercise good judgment an follow mandatory safety policies with regard to 

the safe operation of a UAS. Pilot and Social Security Number is 538-58-2332. 

B. All operations will utilize a visual observer in addition to pilot in command. 

C. The visual observer and PIC will be in constant verbal contact at all times during 

flight operations. 

D. As PIC, I will wear a high visibility safety vest identifying me as the operator. 

E. Height limitations will be enabled on the UAS to automatically self limit the flight 

altitude to 400 Ft. on any occasion. Though unlikely to occur, special altitude 

considered in areas near airport/airfield approach and departure areas. No flight will be 

conducted on airfield/airport property. 

F. Property owners will sign a consent form prior to UAS operations. Non-participating 

persons will not be allowed within the property confines during the flight. 

G. The UAS will not fly near obstructions during the flight such as Power lines, towers 

or large buildings. 

H. The UAS will always be in line of sight with the PIC and the visual observer. Over 

ground speed of the UAS will be kept as slow as possible to maintain smooth control. 

I. The UAS will weigh under 5 Lbs. and not exceed 30 Kts. 

J. The UAS will not carry and explosive material or flammable liquids. 

K. Every UAS flight will end in 20 Min. or less or when the battery indicates 25% 

remaining time. 

L. The UAS flight will be preceded by a careful pre-flight check list and follow all 

manufacturers protocols. The owner's manual will always be kept at hand during 

operations. 

M. A logbook will be maintained for each flight including the duration, location and 

anomalies during the flight. 

N. A take-off and landing zone will be set up prior to each flight removed from obstacles 

and persons in order for a safe flight. 
0. Radio frequencies will comply FCC regulations. 

P. The UAS will have "Kristopher Henkel DBA ADVANTAGE AIR-CAM contact 

information and the FAA exemption number prominently displayed. 

Q. UAS flights will be conducted during daylight hours under VFR conditions and flight 

rules. 

R. Kristopher Henkel DBA ADVANTAGE AIR-CAM will maintain a $1,000,000 liability 

insurance policy while operating the UAS. 

S. In accordance with the manufacturers operation manual, the PIC will perform 

extensive pre-flight checks prior to each flight to ensure the UAS is functioning 

properly. In the event that the UAS fails the flight check, the UAS will be grounded until 

it complies with manufacturer specifications and is deemed ready to fly. 

T. The UAS will have a flight termination option and an automatic return to a pre 

selected landing zone should communication be lost. 

These safety protocols exceed the FAA safety rules published in the Model Aircraft 

Operations Limits in the FAA Modernization and reform Act of 2012 

6. A summary we can publish in the Federal Register stating 

a. The rule from which you seek the exemption: and 

b. A brief description of the exemption you seek. 

Kristopher D. Henkel DBA ADVANTAGE AIR-CAM is seeking exemption from: 

Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal 

Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart H; C.F.R. & 

45.23 (b); 14 C.F.R. &45.27; 14 C.F.R. &&61.113(a) and (b); 14 C.F.R. & 91.119(c); 14 

C.F.R. & 91.121; 14 C.F.R. & 91.151(a); 14 C.F.R. & 91.405(a); 14 C.F.R. & 91.407(a) (1) 

and (2)14 C.F.R. && 91.417(a) and (b) 

A brief description of the exemption I seek is as follows: 

I seek exemption from the above listed rules. I will adhere to much more stringent 

safety measures previously described by the Model Aircraft Operations Limits 

according to the FAA Modernization and Reform act of 2012. Many if not most of the 

rules don't apply to the UAS since no pilot or passengers can be carried and the UAS to 

be used is less than 5 Lbs. The UAS will not carry flammable liquid fuels or explosive 

materials because it is battery powered. The small size and limited carrying capacity of 

the UAS I desire limits its purpose primarily to functions such as carrying a lightweight 

camera for short flights of 20 Min. or less. This camera capacity is the sole function I 

seek to obtain. I propose to utilize the camera function to augment the Real Estate 

Market by providing high resolution video and photography of marketed properties. Still 

pictures and video are invaluable to the purchaser of real estate since they provide 

additional information to the buyer that would previously not had access to accept for 

hiring a small plane to fly over with a powerful, expensive telephoto lens. The UAS 

technology with its ability to quickly, easily and safely fill this void in marketing is 
priceless for potential buyers. Given the safety parameters limiting its use restrictions 

such as, qualified operator, visual observer, line of site operations, altitude restrictions 

and return to home function due to loss of signal, short duration of flight, not carrying 

flammable material and light weight, this technology will provide an otherwise 

unobtainable product and prove to be safer than any other know form of gathering 

information method known today. 

This exemption request is similar to previously granted exemptions 11062,11213 and 

11112 where the exemption was granted in the public interest. 

7. Any additional information, views or arguments available to supprort your request. 

Flight platform is based on the accepted industry standard DJI/nspire 1, model, 

Phantom vision 2 supporting high resolution camera providing 1082 video and 12 

Megapixel resolution. A full description can be found at: 

www.dji.com/productlphantomlspec. The model/ wish to fly is the Phantom Vision 2 

Plus which is under 4 Lbs. 

8. If you want to exercise the privileges of your exemption outside the U.S., you must 

state the reason. 

I do not wish to exercise the privilege of my exemption outside the U.S. 

Respectfu//ysubmitted, ~ 7~ Kristopher D. Henkel 

DBA ADVANTAGE AIR-CAM 

80-130 Palm Circle Dr., La Quinta Ca. 92253 

Phone: 760-343-0933 

Email: Khe1144783@aol.com