Kevin Cooper

705 Powers Ferry Road #415

Marietta, GA 30067

770-355-2139

kevin@revealinghomes.com

July 7, 2015

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part

11 of the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a);

91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and

{2}; 91.417{a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Andrew

Lassiter, operator of an Unmanned Aircraft System (UAS), hereby apply, on

behalf of Keen Eye Marketing and Sea Island Media, for an exemption from the

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its

UAS, so long as such operations are conducted within and under the conditions

outlined herein or as may be established by the FAA as required by Section 333.

I would like to formally submit for an exemption from part 21, subpart H; and

Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and

(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code

of Federal Regulations (14 CFR). This proposed exemption would allow the

operation of unmanned aircraft systems (UAS) for the purpose of aerial

videography and photography real estate purposes and events.

Applicant:

Kevin Cooper

Owner

Revealing Homes, LLC 705 Powers Ferry Road #415

Marietta,GA 30067 kevin@revealinghomes.com (770) 355-2139
Commercial operation of an UAS, as described herein, which are equipped with camera

and sensors, would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate and

other related professional activities.

• Aerial video and/or photography for public and/or private use including public and

private events.

As described fully below, the requested exemption would permit the operation of a UAS

under controlled conditions in the NAS that would be a) limited, b) controlled, c)

predetermined, and d) will provide safety enhancements to the already safe operations in

the industry presently using conventional aircraft. Approval of this exemption would

thereby enhance safety and fulfill the Secretary of Transportation responsibilities to

“....establish requirements for the safe operation of such aircraft systems in the national

airspace system.”

As found in Exemption No. 11138 (Trudeau), the FAA recently approved similar use of a

PHANTOM 2 UAS. We will operate a UAS, the DJI Phantom 3 Professional, Model

W323, which is comprised of an unmanned aircraft (UA or Phantom), an attached 4K

camera and a transportable ground station.

The PHANTOM 3 is a quad-copter with a gross weight of 2.8 pounds. It is equipped with

four rotors that are driven by electric motors powered by batteries. The UA has a

maximum airspeed of 16 m/s. It will be operated over various metropolitan areas,

primarily around Atlanta, GA, to augment real estate listing videos, capture event areal

video and photography, and related business operations.

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption,

which ensures a level of safety at least equal to existing rules:

• operate UAS below 300 feet and within a radius distance of 1000 feet from the

controller to aid in direct line of sight visual observation;

• obtain permission from the owner/controller of any vessels, vehicles and structures

when operations may be conducted closer than 500 feet to any such vessels, vehicles or

structures; we will conduct a safety assessment of the risk of operating closer to those

objects and determine that it does not present an undue hazard;

• operate the UAS for 5-10 minutes per flight;

• land UAS prior to the manufacturer’s recommended minimum level of battery power;

• operate UAS during daylight hours only within visual line of sight (VLOS);

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers

and then

slowly lands if communication with the remote control pilot is lost;

• conduct all operations under the flight safety protocols (including posting a warning

sign

reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) contained

in the operating documents and will actively analyze flight data and other sources of

information to constantly update and enhance safety protocols;
• contact respective airports if operations will be within 5 miles to advise them of his

estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation; have procedures in place to

abort flights in the event of safety breaches or potential danger;

• only operate in safe environments that are strictly controlled, are away from power

lines, elevated lights, airports and densely populated areas (defined by areas depicted in

“yellow” on VFR charts and through obtaining information regarding congested areas

from the local Flight Standards District Office (FSDO);

• conduct extensive preflight inspections and protocols, during which safety carries

primary importance (reference PHANTOM Flying Flow Chart and User Manual).

Regarding UAS operational training, we have flown numerous practice flights in remote

areas as hobbyists simulating flights for future commercial use to gain familiarization

with the characteristics of the UAS’ performance under different temperature and

weather conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner consistent

with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least

10 hours logged as a UAS pilot with a multi-rotor UAS. The PIC will also have

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make

and model of UAS to be used for operations. In addition to the hour requirements, the

PIC will accomplish 3 take-offs and landings in the preceding 90 days (for currency

purposes) prior to any flight.

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated with the UA, we feel

an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §

91.203(a) and (b) (Certifications required), subject to certain conditions and limitations,

is warranted and meets the requirements for an equivalent level of safety under 14 CFR

part 11 and Section 333 of P.L. 112-95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller

than the minimal lettering requirement. Regardless of this, we can mark the UAS in the

largest possible lettering by placing the word “Experimental” on its fuselage as required

by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft

without an airworthiness certificate, since there is currently no certificate applicable to

our operation, this regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a)

and (b) Maintenance inspections since they only apply to aircraft with an airworthiness

certificate. However, as a safety precaution we will perform a preflight inspection of the

UAS before each flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in

the aircraft, however since there are no pilots or passengers on board the aircraft and
given its size, this regulation is inapplicable. We believe an equivalent level of safety will

be achieved by maintaining a safety/flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation

of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain

conditions. We will not operate our UAS above the altitude of 300 feet above ground

level (AGL) and will also only operate in safe areas away from the public and traffic,

thus “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 the UAS,

an equivalent or higher level of safety will be achieved.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the

UAS utilizes electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR

conditions.

The UAV is 100% electric and two low battery alerts are issued - per the operating

documents, the UAV will be landed at the first alert. Also, our flights will last only 5-10

minutes each, and the UAS has an automated function, which results in immediate

landing when a low battery is detected. The PIC

will not begin a flight unless (considering wind and forecast weather conditions) there is

enough power to fly to the first point of intended landing and, assuming normal cruising

speed, land the UA with 30% battery power remaining.

Public Interest

Aerial photography and videography for real estate and events are proven strategies to

enhance marketing efforts and increase business success. The industry is not new.

However, until recently it was conducted through the use of costly manned aircraft, a

prohibitive business activity for small companies. By granting this exemption I would be

able to provide affordable services.

Further, the small UAS will pose no threat to the public given its small size and lack of

combustible fuel when compared to larger manned aircraft. Additionally, the operation of

our UAS will minimize harm to the environment economic growth by providing

information to companies and the public looking to relocate or build in the metro areas

we service. Public and private events serviced by our business enhance vibrancy and add

culture to the community and its citizens.

Summary

We will comply with all of the following conditions and limitations should this

exemption be provided:

1) Operations will be limited to the following aircraft described in the operating

documents, which is a quad-rotor aircraft weighing 2.8 pounds: Phantom 3 Unmanned

Aircraft System.

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 400 feet above ground level

(AGL), All altitudes reported to ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command

(PIC) at all times.
5) All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to

communicate verbally at all times. The PIC will be designated before the flight and will

not transfer his or her designation for the duration of the flight. The PIC will ensure that

the VO can perform the functions prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and made

available to the Administrator upon request. Any revisions to the operating documents

will be presented to the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the

UAS will not be operated until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight. The Ground Control Station will be

included in the preflight inspection. All maintenance and alterations will be properly

documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight

characteristics,

e.g. replacement of a flight critical component, will undergo a functional test flight.

The PIC who conducts the functional test flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all

discrepancies,

i.e. inoperable components, items, or equipment, not already covered in the relevant

sections of the operating documents.

10) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in

accordance with the operating documents. Maintenance, inspection, and alterations will

be noted in the aircraft records, including total flight hours, description of work

accomplished, and the signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot

certificate and at least a current third-class medical certificate. The PIC will 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.

15) Prior to operations conducted for the purpose of aerial videography/photography and

for real estate listing videos and public and private events and similar operations, the PIC

will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a

minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours

logged as a UAS pilot with a multi-rotor UAS.

16) Prior to operations conducted for the purpose of aerial videography/photography and

for real estate listing videos and public and private events and similar operations, the PIC

will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a
minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used

in operations. The PIC will accomplish 3 take-offs and landings in the preceding 90 days.

17) The PIC will not operate the UAS for the purpose of aerial videography/photography

and for real estate listing videos and public and private events and similar operations,

unless the PIC has demonstrated and logged in a manner consistent with 14 CFR

61.51(b), the ability to safely operate the UAS in a manner consistent with the operating

documents, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All

operations will be conducted under visual meteorological conditions (VMC).

19) The UA will not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart.

20) The UA will 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.

21) If a UA loses communications or loses its GPS signal, it will return to a

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing

point and land the UA with 30% battery power remaining.

24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations, and also request a Notice to

Air-man (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior

to the operation.

25) Before conducting operations, the radio frequency spectrum used for operation and

control of the UA will comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC

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

documents will be made available to the Administrator or any law enforcement official

upon request.

27) The UA will remain clear and yield the right of way to all manned aviation operations

and activities at all times.

28) The UAS will not be operated by the PIC from any moving device or vehicle.

29) The UA will not be operated over congested or densely populated areas.

30) Flight operations will 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. We will 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 and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has granted permission 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, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not

present an undue hazard to those persons per § 91.119(a).

31) All operations will be conducted over private or controlled-access property with

permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

32) Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported

to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov.

If you have questions or need additional information, please contact me at

kevin@revealinghomes.com or (404) 355-2139.

Thank you,

Kevin Cooper

Owner

Revealing Homes, LLC