# .-.... 

# ·-· 

# -**~-** 

# LII 

# IIILiftl**ILl'~,_** 

# ,.....,., 

# .,,.,

# ..,.,.,.,_ AIR-CAM
U.S. Department of Transportation, Docket Operations Date: 7-22-15 West Building, Ground Floor, Room w12-140 1200 New JerseyAve., SE., Washington DC 20590 .- Dear Sir orMadam: .-:**=~~**

KristopherHenkel DBA "ADVANTAGEAIR-CAM" herebyapplies for an exemption from the listed Federal Aviation Regulations and any otherrules necessary to allow operation ofa small hobbysized (less than 5 Lbs.) unmanned aircraft (UAS) in order to produce aerial video ofreal estate for sale below a height of400Ft. AGL. The purpose ofUAS is to obtain video documentation ofreal estate forsale in order

### to provide interested parties visual information about chosen propertypreviously not available before purchase. Video will safelyshow interested clients rooftops, vegetation, boundaries, streams, adjacent land, drainage issues, nearby roads and topography. Careful use of the UAS will greatly assistprospective buyers atselecting property while posing no safety orprivacy threats 

### to the general public, the participating inspection parties, or non-participating parties. This request is similar to previous grants ofExemption Nos 11109, 11112,11062 and 111213 where the exemption was granted in the public interest.
1. Kristopher D. Henkel DBA ADVANTAGEAIR-CAM

80-130 Palm Circle Dr., La Quinta Ca. 92253 Phone (760)343-0933 Email Khe1144783@aol.com
2. The specific section orsections of 14 CFR from which you seek an exemption: Exemption Request Pursuant

### to section 333 ofthe FMRA and Part 11 ofthe Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part21 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 ofreliefyou seek and the reason you seek relief: Kristopher D. Henkel DBA ADVANTAGEAIR-CAM requests reliefand exemption from listed Federal Aviation Regulations and any otherapplicable rules in order to all ofthe use ofa 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 ofspecific properties 

### to provide additionalinformation to prospective buyers regarding theirproposedpurchase. The UAS will fly no higher than 400 Ft. above a selectedproperty and and will not infringe on the property rights ofthe adjacent ornearbyproperties. The UAS will remain inside the selectedproperties andpublic 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 boughtandsold with disregard to topography. UAS flights reveal to the prospective owner, Close up roofinspection, hidden flaws in design and otherinformation unavailable from the ground. UAS flights reveal the character ofthe selectedproperty with regard to surrounding topography and gives the potential buyera fresh sense ofSituational awareness unavailable without a manned aircraft fly over. 4. Howyourrequest would benefit the public as a whole. A. Safety ofreal estate personnel is a paramount consideration. Persons attempting to gain high-resolution video andphotos in area such a marsh land orswamp areas, pictures requiring high elevation pictures to improve perspective andpictures ofroofs, porches, docks and from an adjacent lake. The simple production ofotherwise risky photography minimizes impact on the generalpublic. B. High Resolution photographyand video from a UAS can be instantly transmitted to an interestedparties for immediate resolution of pre-purchase questions thereby simplifying andshortening the decision making process for the potential buyer. Conflict resolution could be minimized for the generalpublic.


### C. Aerialphotography can be accomplished quickly and easily with little orno impact on the surrounding neighborhood. Modern UAS utilize quiet electric motors that are virtually silent and unobtrusive beyond 100Ft. Given the amount ofinformation that can be gathered in less than 10 Minutes, UAS offers an immense advantage to conventional photo gathering services with minimal inconvenience to the generalpublic. D. With the history ofbuying andselling property in our country, UAS will ultimately benefit a large proportion ofthe generalpublic. With technological advances, the ability ofUAS to enhance the buying andselling ofreal estate will reach everyone. Spectacular video ofa 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 ofhomes. E. UAS couldprove as the ultimate guarantor ifthe property is destroyed by fire or disaster. Insurance agents could receive proofof property condition prior to the damage. Claims would be resolved faster and recovery could be accomplished quicker. The generalpublic will benefit from having more information about the property before the sale with high resolution photos. 

### 5. Reasons why the exemption would notadverselyaffectsafety, orhow the exemption wouldprovide a level ofsafety at least equal to the existing rule. Safety would be the prime motivating factor. Ifthe mission to gatherinformation for prospective real estate buyers cannot be accomplishedsafely, then the mission mustbe aborted. Realizing while new technological cannot be adopted with absolutely no risk, given the protocols listed below, the implementation ofthe UAS for the Realty/surety market can be accomplished with minimal risk and would be safer than existing methods forprocuring high resolution video andphotos. A. The UAS would only be operated bymyself, Kristopher Douglas Henkel, a 

### 62 year old inactive private pilot with 140 Hours SEL, builder/pilot ofa home built two seat Experimental Aircraft (Titan Tornado II) and35 Hours flying UltralightAircraft. I am fully prepared to exercise good judgment an follow mandatorysafetypolicies with regard to the safe operation ofa UAS. Pilot and Social Security Number is 538-58-2332. B. All operations will utilize a visual observerin addition to pilot in command. C. The visual observerand PIC will be in constant verbal contact at all times during flight operations. D. As PIC, I will weara high visibility safety vest identifying me as the operator. E. Height limitations will be enabled on the UAS to automaticallyselflimit the flight altitude to 400 Ft. on any occasion. Though unlikely to occur, special altitude considered in areas nearairport/airfield approach and departure areas. No flight will be conducted on airfield/airportproperty. 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 nearobstructions during the flight such as Powerlines, towers orlarge buildings. H. The UAS will always be in line ofsight with the PIC and the visual observer. Over groundspeed ofthe 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 orflammable liquids.


### K. Every UAS flight will end in 20 Min. orless or when the battery indicates 25% remaining time. L. The UAS flight will be preceded bya carefulpre-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-offand landing 

### zone will be set up prior to each flight removed from obstacles andpersons in orderfor a safe flight.

### 0. Radio frequencies will comply FCC regulations. P. The UAS will have "KristopherHenkel DBA ADVANTAGEAIR-CAM contact information and the FAA exemption numberprominently displayed. Q. UAS flights will be conducted during daylight hours under VFR conditions and flight rules. R. Kristopher Henkel DBA ADVANTAGEAIR-CAM will maintain a $1,000,000 liability insurance policy while operating the UAS. S. In accordance with the manufacturers operation manual, the PIC willperform 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 manufacturerspecifications 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 safetyprotocols exceed the FAA safety rules published in the ModelAircraft Operations Limits in the FAA Modernization and reform Act of2012


### 6. A summary we can publish in the Federal Registerstating a. The rule from which you seek the exemption: and b. A briefdescription ofthe exemption you seek. Kristopher D. Henkel DBA ADVANTAGEAIR-CAM is seeking exemption from: Exemption Request Pursuant to Section 333 ofthe FMRA and Part 11 ofthe Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part21 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 briefdescription ofthe 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 ModelAircraft Operations Limits according to the FAA Modernization and Reform act of2012. Many ifnot most ofthe rules don't apply to the UAS since no pilot orpassengers can be carried and the UAS to be used is less than 5 Lbs. The UAS will not carry flammable liquid fuels orexplosive materials because it is batterypowered. The small size and limited carrying capacity of the UAS I desire limits its purpose primarily to functions such as carrying a lightweight camera forshort flights of20 Min. orless. This camera capacity is the sole function I seek to obtain. I propose to utilize the camera function to augment the Real Estate Market byproviding high resolution video andphotography ofmarketedproperties. Still pictures and video are invaluable to the purchaser ofreal estate since theyprovide additional information to the buyer that wouldpreviously not had access to accept for hiring a smallplane to fly over with a powerful, expensive telephoto lens. The UAS technology with its ability to quickly, easily andsafely fill this void in marketing ispriceless forpotential buyers. Given the safetyparameters limiting its use restrictions such as, qualified operator, visual observer, line of site operations, altitude restrictions and return to home function due to loss ofsignal, short duration offlight, not carrying flammable material and light weight, this technology willprovide an otherwise unobtainable product andprove to be safer than any otherknow form ofgathering information method known today. This exemption request is similar to previouslygranted exemptions 11062,11213 and 11112 where the exemption was granted in the public interest.


### 7. Anyadditional information, views orarguments available to supprortyourrequest. Flightplatform 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 under4 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 ofmy exemption outside the U.S. Respectfu//ysubmitted,

# ~**7~** Kristopher D. Henkel DBA ADVANTAGEAIR-CAM 80-130 Palm Circle Dr., La Quinta 

### Ca. 92253 Phone: 760-343-0933 Email: Khe1144783@aol.com