April 17, 2015

Exemption No. 11364 Regulatory Docket No. FAA–2015–0116

Mr. Jeffrey Galindo Principal Real Estate Strategies LLC 3011 Brighton Creek Ct Las Vegas, NV 89135

Dear Mr. Galindo:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 16, 2014, you petitioned the Federal Aviation Administration (FAA) for an exemption. The exemption would allow th e petitioner to operate an unmanned aircraft system (UAS) to conduct aerial videogra phy/cinematography to enhance academic community awareness for those individuals/e ntities and companies unfamiliar with the geographical layout of the grea ter Las Vegas, NV, metropolitan area and to augment real estate research analys is and for-sale listing photographs and videos.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition woul d be detrimental to the petitioner. However, the FAA received one comment made to the docket, th e commenter expressed pr ivacy concerns about data collection on or near his property.2

Airworthiness Certification

The UAS proposed by the petitioner is a DJI PHANTOM 2 VISION +.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, th e FAA finds that the re quested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pr esented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Je ffrey Galindo is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a )(1), 91.409(a)(1) an d (2), and 91.417(a) and (b), to3

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Jeffrey Gali ndo is hereafter referred to as the operator.

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI PHANTOM 2 VISION + when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will re quire a new petition or a peti tion to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not perm itted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the4

Administrator upon request. If a discrepa ncy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questi ons arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.6

22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These

documents must be made available to th e Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards ServiceJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 1 of 15 January 16 , 2014

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam

,

I, Jeffrey Galindo, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Jeffrey Galindo, an owner and operator of small unmanned aircraft, be exempted

from the Federal Aviation Regulations (“FARs”) listed below so that I, Jeffrey Galindo, may operate my small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Jeffr ey Gal indo, am a licensed REALTOR, a P rincipl e at Real Estate Strategies LLC; a market research firm that provides real estate research and consulting services to individuals, as well as private and public entities, and I am a licensed private pilot (PRIVA TE PILOT C ERTIFICATE NUMBER 3514267) 1 with a current THIRD CLASS MEDICAL CERTIFICAT E 2 . In addition I am experienced in flying hobby aircrafts for recreational purposes.

I have added a hobby grade DJI PHANTOM 2 VISION + quad

- copter1 UAS equipped with an inc luded original equipment manufacturer (OEM) digital camera to my inventory. The intended use of this equipment will be for aerial videography/cinematography to enhance academic community awareness for

those individuals entities and companies unfamiliar with the geographical layout of the greater Las Vegas NV metropolitan area and to augment real estate research analysis and for

- sale listing photographs and videos; following exemption and approval by the FAA. Thereby enhancing the academic res earch experience for the greater Las Vegas NV metropolitan area.!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1 Appendix J

– Private Pilot Certificate

2 Appendix J

– Medical Certificate Third ClassJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 2 of 15 I have held a Private P ilots Certificate since 07/07/2000 and have had no

accidents or incidents and flown small RC electric aircrafts since 2009 without

incident as I am c ommitted to safety with each flight.

My, Jeffrey Galindo exemption request would permit operation of an ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive

UAS in c ontrolled and limited airspace 3

. Predetermined in areas away from general public, airports, heliports and vehicular traffic for community photos and videos, and within property boundaries for individual property owner’s, real estate listing videos/photos. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I , Jeffrey Galindo, have personally instilled safety protocols and controls 4 to avoid 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 I, Jeffrey Galindo, record flight data and other information gained through per mitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting my, Jeffrey Galindo’s, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibil ities 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 I, Jeffrey Galindo, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Jeffrey Galindo, respectfu lly request the grant of an exemption allowing me to operate ultra light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to the greater Las Vegas NV metropolitan area and to enhance real estate research anal ysis

and for

- sale listing videos for property owners 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.



### UAV/UAS/UA Clarification

The UAV/UAS/UA which I Jeffrey Galindo, will be operating is the DJI Phantom 2

Vision +, referred hereafter as Phantom. The inhe rent safety features,!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 3 Appendix!A!

– Greater!Las!Vegas!NV!Metro!Airspace

4 Appendix!B!

– Personal!Protocols!and!ControlsJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 3 of 15 sophistication, programmability, GPS navigation, return home capability, airport vicinity no

- fly feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the cam era make this a much safer UAV for the purposes of this petition. This is a hobby grade radio controlled UAV that has the capacity for software upgrades. It is light, less than 3 pounds including battery and camera. Incorporated into the programming of the Phantom is an automatic return home feature that automatically directs the craft back to point of take off should communication with the transmitter be lost. The Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight ti me is 25 minutes. Gross weight is 2.86 pounds.

The Phantom has an additional communication link between the camera and craft on a different rf for a smart phone connection. Allowing the operator or Pilot In Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, camera imagery, and control camera angle. The DJI Phantom 2 Vision +'s 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf transmitter/receiver for video/photography functions eliminates possible rf

conflict

.

The software for the Phantom allows the operator or PIC to set maximum altitude AGL for each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as an examples. The 400 foot maximum AGL can be

programm ed into the UAV's software pre

- flight to insure compliance with FAA standards. Adding to the safety capabilities of this UAV. This UAV is programmed to remain in position when controls are released. Maintaining

altitude and GPS location.

The Phantom has an altitude and radar monitoring function that allows the operator more precise determination of height, direction of flight and distance from the operator PIC. The operator or PIC can monitor GPS lock status while UAV is in flight, with the ability to ant icipate loss of GPS locking so the operator or PIC can land the UAV as a precaution.

The Phantom has many inherent safety features, including sophistication, programmability, GPS navigation, return home capability, airport vicinity no

- fly

feature and rest ricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the purposes of this petition.

This is a hobby grade radio controlled UAV that has the capacity fo r software upgrades. It is light, less than 3 pounds including battery and camera. Incorporated into the programming of the Phantom is an automatic return home feature that automatically directs the craft back to point of take off should

communication with the transmitter be lost. The Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight time is 25 minutes. Gross weight is 2.86 pounds.Jeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 4 of 15 The Phantom has an additional communication link between the camera and

craft on a di fferent rf for a smart phone connection. Allowing the operator or Pilot In Command (PIC) to monitor battery level, altitude (AGL), and distance from PIC, camera imagery, and control camera angle.

The B est explanation of the Phantom's sophistication and c apabilities can be observed through a video explanation of an earlier model that was predecessor to the Phantom 2 Vision + through link http://youtu.be/3mqj

- WBRKmE. The Phantom 2 Vision + maintains all capabil ities defined in the video.



### Specific UAV/UAS/UA

The particular UAV/UAS/UA which I

, Jeffrey Galindo, will be operating is the DJI

Phantom 2 Vision + Serial Number PH645474457

Settings

• Height limitation set for maximum of 300 feet AGL

• Radius distance from controller set for maximum of 1000 feet, b oth to aid

in direct line of site and visual observation.

Current firmware upgrades for

• Main Controller

• GPS

• Receiver

• Battery

• Zen IMU



### Similarities, Distinctions and Differences of other recen tly approved Exemptions/ Petitions

As with several other recently approved similar petitions and exemptions including that of Astraeus Aerial (FAA

- 2014

- 0352), referred hereafter as the Astraeus Petition, and that of Douglas Trudeau (FAA

- 2014

- 0481), refer red

hereafter as the Trudeau Petition

, this Jeffrey Galindo Petition has a number of similarities, distinctions and differences

.

Like the Astraeus and Trudeau Petition s, t his Jeffrey Galindo Petition, is for UAV operation without pilot, passengers nor pr operty on board. Understanding that the Phantom UAV is a sophisticated hobby grade quad

- copter with gross weight less than 3 pounds ; however , I Jeffrey Galindo am not requesting a waiver or exemption for a private pilot certificate, as I hold a current Private Pilot C ertificate

and a current Third Class Medical C ertificate.

As with Trudeau Petition

, I Jeffrey Galindo am using a UAV that has theJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 5 of 15 capability for taking off and landing at a single point, identical to a helicopter. There are no runways, aid ed take off apparatuses, nor routes that need to be flown to areas being aerial video recorded or photographed. Allowing a reduced and more confined area of flight.

The Astraeus Petition is for movie sets involving a significant number of people,

non

- aeri al equipment, moving or action sequences, and a potentially broad geographical area where individuals and equipment may be in motion. Requiring extensive observation, awareness, coordination and safety precautions. My Jeffrey Galindo petition is similar to t he Trudeau Petition in that it is for video/photography of stationary objects requiring briefer periods for recording in a tightly confined area. The stationary setting of objects poses a significantly

lower risk for safety, allowing the operator or Pilo t In Command (PIC) to focus primarily on stationary objects for shorter periods of time. With the movie action

scenes, associated with the Astraeus Petition, numerous takes may require repeated flights, whereas a stationary object would in most cases requi re only a single flight

.

A s with the Trudeau Petition My Jeffrey Galindo Petition will require property owner written consent for aerial video/photography prior to flight. Signs will be posted cautioning anyone within vicinity to remain back a minimum of 200 feet. Observer(s) to assist and warn/advise the PIC will be utilized in situations where spectators may be within 500 feet of the flight area.

As with the Trudeau Petition, I Jeffrey Galindo requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition of flight in congested areas. Such restriction pu ts home and other real property owners in subdivisions at a disadvantage by limiting enhanced marketing of their homes and properties; thereby discriminating against them. Vertical takeoff and landing while video recording or photographing a home can allow an enhanced perspective for view or proximity of mountains, golf course, manmade lake or other attractions not possible through ground level video recording or photography. I Jeffrey Galindo request waiver for this condition to allow reasonable and respon sible aerial video/photography in congested areas of subdivisions and neighborhoods.

As in the Trudeau Petition t he single UAV utilized in my Jeffrey Galindo Petition is a hobby grade quad

- copter that does not require an airman certificate for non

commercial flight involving less restrictive less regulated flight.

As in the Trudeau Petition t he motors, rotors, propellers, body/frame, landing pads, etc. for the UAV ut ilized in my Jeffrey Galindo Petition are not complicated. Engineering and design allows layman maintenance. Like the Astraeus and Trudeau Petitions, I Jeffrey Galindo requests waiver or exemption for markings due to the small size of the fuselage for the Phantom 2 Vision +.Jeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 6 of 15 Recording part replacement for this UAV may prove impractical or redundant due to the simplicity of the craft. As in the Therefore Petition, I Jeffrey Galindo requests waiver or exemption for maintenance records. However, pre

- flight

in spection for cracks, damage or other physical conditions that could hamper safe flight is a reasonable expectation. As well as post flight inspection that may aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. Thor ough inspection of UAV shall be conducted and flight response tested should a hard landing or crash occur. Insuring that the UAV can operate in a safe manner before conducting any further video/photography.

As with the Trudeau Petition, I Jeffrey Galindo requests waiver/exemption from Section 91.203 (a) since the Phantom is a hobby grade UAV/UAS that should not require an airworthiness certificate nor a registration certificate. Posting of special flight authorization would not be possible since the Phanto m has no cabin and is not large enough to carry a certificate. However, a special flight authorization can be maintained by the operator to make available upon request.

In compliance with Section 90.151 (a) the Phantom is a battery operated

UAV/UAS with b attery level monitoring capability. Fully charged battery flight time is rated at 25 minutes, with videos/photos taking much less time to record. Operator or PIC is warned when battery level is low.



### Canadian Precedent

Recently Transport Canada relaxed UA S regulations to place less restriction on sUAS under 2 kg (4.4 lbs). Petitioner’s sUAS weighs 2.86 lbs per manufacturer.

I Jeffrey Galindo respectfully requests review of Transport Canada's latest exemption for sUAS operation for portions that can be ado pted and adapted to apply in United States NAS. Providing guideline and penalties for infractions, violations, and failure to comply.

Attachments A & B are from Transport Canada's Exemption for sUAS under 2 kg (4.4 pounds).



### Contact Information:

Jeffrey Galindo, Principal Real Estate Strategies LLC, 3011 Brighton Creek Ct Las Vegas, NV 89135 Office: (702) 659

- 9005 Mobile: (702) 290

- 6458

Email: JGalindo@TheNewHomePros.com

The Specific Sections of Title 14 of the Code of Federal Regulations From WhichJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 7 of 15 Jeffrey Galindo Requests Exemption are:

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).



### The Extent of relief Jeffrey Galindo seeks and the Reason He

Seeks Such Relief:

I, Jeffrey Galindo, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, Jeffrey Galindo, c ontemplated commercial cinematic, academic 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 pub lic’s interest to do so. My, Jeffrey Galindo’s, ultra light weight UAS meets the definition of “small unmanned aircraft”

as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I wou ld like to operate my

ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be

administ ered uniformly to all real estate related UAS aerial video and photography. 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 o verall 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 reflect in favor of an exemption for me, Jeffrey Galindo. My UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than three (3 ) pounds (far below the maximum 55

- pound limit); including camera w ith gimbal.

I, Jeffrey Galindo, consider safety as foremost with each flight. My small

unmanned 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 I will not fl y in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. I utilize this mode for aerial videography/photography. This is the safest, most reliable

and stable mod e to prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areasJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 8 of 15 where general public is within fift y to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rathe r than combustible fuels, flights generally last between five (5) to ten (10) minutes, with an altitude under one hundred fifty (150) feet. I, Jeffrey Galindo, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is twenty (20) to twenty five (25) minutes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate

communica tion between radio control and UAS to eliminate potential for crash,

loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization wit h the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.

I, Jeffrey Galind o’s, am extremely cautious when operating of my 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 my UAS it falls well w ithin Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's

into the national airspace system. Jeffrey Galindo’s UAS, used in hobby flight, has a demonstrable safety record and does not po se any threat to the general public or national security.



### How Jeffrey Galindo’s 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. Depr iving

non

- luxury homeowners and lower budget REALTORs from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that the Tucson community has experienced in the past with military

aircraft and medical helicopter crashes within the city of Tucson. Each resulting in loss of life. Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My,Jeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 9 of 15 Jeffrey Galindo's, UAS pose no such th reat since size and lack of combustible fuel alleviates any potential threat to the public.

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 t he Reform Act. Granting my, Jeffrey Galindo’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the metro Tucson area. My ultra lightweight UAS is battery powered

and creates no emi ssions that can harm the environment. The consequence of my 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 my battery operated ultra lightweight UAS's. Permitting me, Jeffrey Galindo, to immediately fly within national air space furthers ec onomic growth. Granting my exemption request substantially furthers the economic impact for the metro Tucson community for companies looking to relocate or build in the Tucson metro area as well as individuals looking to relocate for career advancement thr ough academic and geographical awareness. Both of which serve as a stimulus to the community.



### Reasons Why Jeffrey Galindo’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My , Jeffrey Galindo’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Jeffrey Galindo, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me

to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for REALTORs that can be embraced by the

NAR 5

, and GLVAR 6 , for development in cooperatio n with the FAA. In addition I, Jeffrey Galindo, submit the following representations of enhancements to current aerial videography and photography for real estate:

• I am a current and licensed private pilot with a current Third Class

Medical Certificate

• My UAS weighs less than 5 pounds complete with the OEM digital

camera ;

• I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);

• My UAS only operate for 5

- 10 minutes per flight;!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 5 National Association of REALTOR s, http://www.REALTOR.org/

6 Greater!Las!Vegas!Association!of! REALTOR s,!http://www.lasvegasrealtor.comJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 10 of 15 • I land my UAS prior to manufacturer recommended minimum level of

batte ry power;

• I pilot my UAS through remote control only by line of sight;

• My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

• I actively analyze flight data and other sources o f information to constantly update and enhance safety protocols;

• I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas;

• I conduct extensive pre

- flight i nspections and protocol, during which safety carries primary importance;

• I always obtains all necessary permissions prior to operation; and,

• I have procedures in place to abort flights in the event of safety breaches or potential danger.

• The UAS that I fly ; the Phantom 2 Vision + has a built in safety feature called the “No Fly Zones Feature” 7 that prevent the UAS from taking of or flying near busy airports.

My, Jeffrey Galindo’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helic opters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra light weight UAS.

• First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations.

• Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatl y diminished.

• Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely.

• Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom.

Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above cur rent safety levels.!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 7 No Fly Zones, http://www.dj i.com/fly

- safe/category

- mc (see Appendix F Users Manual)Jeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 11 of 15 

### A Summary The FAA May Publish in the Federal Register:

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 proc urement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Jeffrey Galindo’s, UAS permits exemption from Part 21 because my 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 ex empt 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. My, Jeffrey Galindo’s, current UAS meet or exceed each of the

elements.

1 4 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 fl ight 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 8 delineating areas of where safety can be defined.10 The 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 insof ar as my 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 me, Jeffrey Galindo.



### 14 C.F.R. § 45.23: Marking of The Aircraft.!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 8 Appendix C

- Safety/Flight ManualJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 12 of 15 Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My 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, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required b y 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me 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.



### 14 C.F.R. § 61.113: Priv ate Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

commercial operations. I, Jeffrey Galindo, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less

than the risk levels inherent in the commercial activities outlined i n 14 C.F.R. § 61, et seq. Thus, allowing me, Jeffrey Galindo, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).



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

14 C.F.R. § 91.119 prescribes safe altitudes for t he operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Jeffrey Galindo, will however operate my 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 my UAS, an equivalent or higher level of safety wi ll

be achieved.



### E. 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 certifi cate. They

will not , therefore, apply to my, Jeffrey Galindo's, UAS. However, as a safetyJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 13 of 15 precaution I inspect my 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 Cer tificates, 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, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Jeffrey Galindo’s, UAS meets 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 t he 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 s uch as airports and dense populations . My UAS meets or exceeds 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 FA Rs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will b e achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any da maged hardware. Therefore, an equivalent level of safety

will be achieved.



### In summary, Jeffrey Galindo seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § .109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91. 409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Jeffrey Galindo's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and real estate operations, and to develop e conom ic platforms for real estate to enhance

the understanding and experience of those seeking real estate information or to

relocate to the greater Las Vegas metropolitan area.

Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. PosingJeffrey Galindo, REALTOR®, Las Vegas NV

- Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas

NV Section 333 Exemption Petition Page 14 of 15 potential risk to the public. Granting my, Jeffrey Galindo’s, request for exemption

will reduce curr ent risk levels and thereby enhance safety

. My UAS craft does

not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I op erate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields

.

I, Jeffrey Galindo, have been informally analyzing flight information and will compile safety protocols and the implementation of a fl ight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA

M odernization and Reform Act of 2012. There are no personnel on board my, Jeffrey Galindo’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Jeffrey Galindo’s, operation of my UAS, weighing less than 5 pou nds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs.

Accordingly I, Jeffrey Galindo, (Licensed Private Pilot Certificate Number 3514267) respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Jeffrey Galindo, Principal Real Estate Strategies LLC,

3011 Brighton Creek Ct Las Vegas, NV 89135 Office: (702) 659

- 9005 Mobile: (702) 290

- 6458

Email: JGalindo@TheNewHomePros.com