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 granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the 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 the petitioner to operate an unmanned aircraft 

system (UAS) to conduct 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. 

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 would be detrimental to the petitioner. However, the FAA 

received one comment made to the docket, the commenter expressed privacy concerns about 

data collection on or near his property. 
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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, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested 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 material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

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

 They are similar in all material respects to relief previously requested 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 situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant 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. Jeffrey 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) and (2), and 91.417(a) and (b), to 
3 

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 Galindo is hereafter referred to as the operator. 

Failure to comply with any of the conditions and 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 require a new petition or a petition 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 restriction. 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 PIC 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 permitted 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 ensure 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 the 
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Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised 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 questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations 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 functional 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. The 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 manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot 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 flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles 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 experience-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 during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants 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 conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility 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 airport 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 private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight 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 for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance 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 under the terms of the attached COA. 
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22. All aircraft operated in accordance 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 the 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 the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way 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 protect 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 structures 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 essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller 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 Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 
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If this exemption permits operations for the 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 over the area of proposed filming. The 3-day 

notification may be waived with 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 responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

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

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

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating 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 all 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 Service 
Jeffrey Galindo, REALTOR®, Las Vegas NV - Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas 

NV Section 333 ExemptionPetition

 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, Jeffrey Galindo, am a licensed REALTOR, a Principle 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 (PRIVATE PILOT CERTIFICATE 

NUMBER 3514267)1 with a current THIRD CLASS MEDICAL CERTIFICATE2. 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 included 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 research 

experience for the greater Las Vegas NV metropolitan area. 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1 Appendix J – Private Pilot Certificate

2 Appendix J – Medical Certificate Third Class
Jeffrey Galindo, REALTOR®, Las Vegas NV - Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas 

NV Section 333 ExemptionPetition

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I have held a Private Pilots 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 committed 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 controlled and limited airspace3. 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 controls4 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 permitted 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) responsibilities 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, respectfully 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 analysis 

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 inherent safety features, 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 3 Appendix!A!– Greater!Las!Vegas!NV!Metro!Airspace

4 Appendix!B!– Personal!Protocols!and!Controls
Jeffrey Galindo, REALTOR®, Las Vegas NV - Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas 

NV Section 333 ExemptionPetition

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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 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 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 time 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 

programmed 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 anticipate 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 restricted 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 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 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 ExemptionPetition

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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), and distance from 

PIC, camera imagery, and control camera angle.

The Best explanation of the Phantom's sophistication and capabilities 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 capabilities 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, both 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 recently 

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), referred 

hereafter as the Trudeau Petition, this Jeffrey Galindo Petition has a number of 

similarities, distinctions and differences. 

Like the Astraeus and Trudeau Petitions, this Jeffrey Galindo Petition, is for UAV 

operation without pilot, passengers nor property 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 Certificate 

and a current Third Class Medical Certificate.

As with Trudeau Petition, I Jeffrey Galindo am using a UAV that has the 
Jeffrey Galindo, REALTOR®, Las Vegas NV - Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas 

NV Section 333 ExemptionPetition

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capability for taking off and landing at a single point, identical to a helicopter. 

There are no runways, aided 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-aerial 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 the 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 Pilot 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 require only a 

single flight.

As 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 puts 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 responsible aerial video/photography in congested areas of 

subdivisions and neighborhoods. 

As in the Trudeau Petition the single UAV utilized in my Jeffrey Galindo Petition

is a hobby grade quad-copter that does not require an airman certificate for noncommercial flight involving less restrictive less regulated flight. 

As in the Trudeau Petition the motors, rotors, propellers, body/frame, landing 

pads, etc. for the UAV utilized 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 ExemptionPetition

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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 

inspection 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. Thorough 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 Phantom 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 battery 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 UAS 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 adopted 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 Which 
Jeffrey Galindo, REALTOR®, Las Vegas NV - Section 333 Exemption Petition

Jeffrey Galindo, REALTOR®, Las Vegas 

NV Section 333 ExemptionPetition

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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, contemplated 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 public’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 would 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 

administered 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 overall capabilities of the UAS's; Whether 

the UAS will be operated near airports or heavily populated areas; and, Whether 

the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these 

items 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 with 

gimbal.

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

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 mode 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 areas 
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where general public is within fifty 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 rather 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 

communication 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 with 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 Galindo’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 within Congress’s contemplated safety zone when 

it promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. Jeffrey Galindo’s UAS, used in hobby flight, 

has a demonstrable safety record and does not pose 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. Depriving 

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, 
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Jeffrey Galindo's, UAS pose no such threat 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 the 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 emissions 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 economic 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 through 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 

NAR5, and GLVAR6, for development in cooperation 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 REALTORs, http://www.REALTOR.org/

6 Greater!Las!Vegas!Association!of!REALTORs,!http://www.lasvegasrealtor.com
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• I land my UAS prior to manufacturer recommended minimum level of 

battery 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 of 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 inspections 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 helicopters 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 greatly 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 current 

safety levels.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 7 No Fly Zones, http://www.dji.com/fly-safe/category-mc (see Appendix F Users Manual)
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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 procurement 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 exempt UAS's 

from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense 

populations. My, Jeffrey Galindo’s, current UAS meet or exceed each of the 

elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual8 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 insofar 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 Manual
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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 by 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: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial 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 in 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 the 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 will 

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 certificate. They 

will not, therefore, apply to my, Jeffrey Galindo's, UAS. However, as a safety 
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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 Certificates, Manuals and The Like. 14 C.F.R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, 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 the 

Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense populations. 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 FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no 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 

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 damaged 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 economic 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. Posing 
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potential risk to the public. Granting my, Jeffrey Galindo’s, request for exemption 

will reduce current 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 operate 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 flight 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 

Modernization 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 pounds 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