Thomas M Hall 

226 Oakridge Dr 

Choctaw Oklahoma 73020

tom@homebuyingokc.com

P: 405-209-9612

F: 405-737-7291

The Tom Hall Group LLC 

Century 21 Goodyear Green

Dear Sir or Madam, 

Thomas M Hall aka Tom Hall of Realtor® CEO of The Tom Hall Group LLC of Century 21 Goodyear Green 

seeks exemption pursuant to the FAA Modernization and Reform Act of 2012 and the procedures 

contained within 14 C.F.R. 11, from the Federal Aviation Regulations (“FARs”) listed below so that 

Thomas Hall Realtor®, may operate their small ultra-light weight unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”). 

This petition is, in most regards, similar to granted exemption No. 11138 both in operational approach 

(closer than 500’) and equipment being utilized (DJI Phantom 3 Professional). FCC ID SS3-WM3231507#, 

Model W323A

As described herein Thomas Hall Realtor® of the Tom Hall Group LLC real estate agent licensed within 

the State of Oklahoma has added a UAS to their inventory equipped with a DJI camera with intent for 

aerial videography/cinematography to enhance community awareness for those individuals and 

companies unfamiliar with the geographical layout of real estate listings in the state of Oklahoma, and 

augment real estate listing videos; following exemption and approval by the FAA. 

Thomas Hall Realtor® of the Tom Hall Group LLC exemption request would permit operation of ultralight weight, unmanned (piloted by remote control) and comparatively inexpensive UAS in tightly 

controlled and limited airspace. Predetermined in areas away from general public, airports, heliports 

and vehicular traffic for community videos, and within property boundaries for individual homeowner 

real estate listing. Thomas Hall Realtor® has instilled safety 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 Thomas Hall Realtor® of the Tom Hall 

Group LLC records 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. 

Protocols and Controls 

Thomas Hall Realtor® of the Tom Hall Group LLC 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 Thomas Hall Realtor® of the Tom Hall Group LLC 

will conduct operations in compliance with the protocols described herein or as otherwise established 

by the FAA. 

For the reasons stated below Thomas Hall Realtor® of the Tom Hall Group LLC respectfully requests the 

grant of an exemption allowing operation of ultra-light weight, remote controlled UAS’s for community 

awareness to benefit/stimulate attraction to the Oklahoma real estate market and to enhance real 
estate listing videos for homeowners 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. 

I. Contact Information: 

Thomas Hall, Realtor® The Tom Hall Group LLC 

226 Oakridge Dr, Choctaw, Oklahoma 73020 

Mobile: 405-209-9612 

Email: tom@homebuyingokc.com

II. The Specific sections of Title 14 of the Code of Federal Regulations from which Thomas Hall 

Realtor® of the Tom Hall Group LLC requests exemption:

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).

III. The extent of relief Thomas Hall Realtor® seeks and the reason they seek such relief: 

Thomas Hall Realtor® of the Tom Hall Group LLC submits this application in accordance with 

the Reform Act, 112 P.L.95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent commercial cinematic 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. Thomas Hall Realtor® of the Tom Hall Group LLC ultra-light weight UAS meets the 

definition of “small unmanned aircraft” as defined in Section 331 and therefore the 

integration of their ultra-light weight UAS is expressly contemplated by the Reform Act. 

Thomas Hall Realtor® of the Tom Hall Group LLC would like to operate their ultra-light 

weight UAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. 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 are in favor of an 

exemption for Thomas Hall Realtor® of the Tom Hall Group LLC. Their UAS utilizes four (4) 

counter-rotating propellers for balance, control and stability. Their UAS is equipped with 

GPS and auto return safety technology. Weighing less than ten (10) pounds (far below the 

maximum 55 pound limit); including camera. 
Thomas Hall Realtor® of the Tom Hall Group LLC, considers safety as foremost with each 

flight. Their 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 they will not 

fly in winds exceeding16 kph (10 mph). Built in safety systems include a GPS mode that 

allows their UAS to hover in place when radio controls are released. When pilot 

communication is lost UAS is designed slowly descend to point of takeoff. Thomas Hall 

Realtor® of the Tom Hall Group LLC will not operate their UAS near airports, Hospitals nor 

Police heliports, and will not operate near areas where general public is within fifty to one 

hundred (50-100) yards depending on location, conditions and weather. Thomas Hall 

Realtor® of the Tom Hall Group LLC will be prepared to land/abort immediately to the 

nearest and safest ground point should a manned aircraft approach their location or should 

they suspect manned aircraft may approach near their location. Thomas Hall Realtor® of the 

Tom Hall Group LLC UAS is capable of vertical and horizontal operations, and will only be 

flown within line of sight of the operator. Utilizing battery power rather than combustible 

fuels, flights generally last between ten (10) to fifteen (15) minutes, with an altitude under 

two hundred (200) feet. Thomas Hall Realtor® of the Tom Hall Group LLC will utilize a fresh 

fully charged battery with each flight as a safety precaution; full flight time limit for each 

battery is twenty-five (25) minutes. Thomas Hall Realtor® of the Tom Hall Group LLC will not 

operate their 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 will be at hand with each exercise to insure 

replacement for sufficient safe level of operation. 

Thomas Hall Realtor® of the Tom Hall Group LLC will exercise extremely caution when 

operating of their 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 their 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. Thomas Hall Realtor® of the Tom Hall Group LLC UAS, used in 

hobby flight, has a demonstrable safety record and does not pose any threat to the general 

public or national security. 

IV. How Thomas Hall Realtor® of the Tom Hall Group LLC 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.. 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 Thomas Hall Realtor® of the Tom Hall Group 

LLC exemption request furthers the public interest through visual awareness of the 

geographical benefits in Oklahoma. Their ultra-light weight UAS is battery powered and 

creates no emissions that can harm the environment. The consequence of their 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 their battery operated ultra-light weight UAS's. Permitting 

Thomas Hall Realtor® of the Tom Hall Group LLC to immediately fly within national air space 

furthers economic growth. Granting their exemption request substantially furthers the 

economic impact for the Oklahoma City Oklahoma community for companies looking to 

relocate or build in the area as well as individuals looking to relocate, both of which serve as 

a stimulus to the community. 

V. Reasons why Thomas Hall Realtor® of the Tom Hall Group LLC exemption will not adversely 

affect safety or how the exemption will provide a level of safety at least equal to existing 

rule: Thomas Hall Realtor® of the Tom Hall Group LLC exemption will not adversely affect 

safety. The following represents enhancements to current aerial videography and 

photography for real estate: Their UAS weighs less than 10 pounds complete with a small 

ultra-light weight high quality DJI Long Range V2.0 camera; • Thomas Hall Realtor® of the 

Tom Hall Group LLC will only operate their UAS below 200 feet (within the 400 foot 

permissible ceiling set by the FAA Modernization and Reform Act of 2012); 

 UAS only operates for 10-15 minutes per flight; 

 Will land their UAS prior to manufacturer recommended minimum level of battery power; 

 Will pilot their UAS through remote control only by line of sight; 

 Thomas Hall Realtor® of the Tom Hall Group LLC will utilize safety with radio controlled 

aircraft operation;

 UAS has GPS a flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost; 

 Pilot will actively analyze flight data and other sources of information to constantly update 

and enhance safety protocols; 

 Will only operate in reasonably safe environment, away from power lines, elevated lights, 

airports and actively populated areas; 

 Will conduct extensive pre-flight inspections and protocol, during which safety carries 

primary importance; 

 Will obtain all necessary permissions prior to operation; and, 

 Will have procedures in place to abort flights in the event breaches or potential danger of 

safety Thomas Hall Realtor® of the Tom Hall Group LLC safety protocols provide a level of 

safety equal to or exceeding existing rules. The potential loss of life is diminished because 

UAS's carry no people on board and only operates in specific areas away from mass 

populations. There is No fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished. The small size and extreme maneuverability of the UAS allows for it to 

be remotely piloted away from and avoid hazards quickly and safely. 

VI. 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 and weight of Thomas 

Hall Realtor® of the Tom Hall Group LLC UAS permits exemption from Part 21 because their 

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. Thomas Hall Realtor® of the Tom Hall Group 

LLC UAS meets 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 manual 

delineating areas of where safety can be 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 the 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 Thomas Hall Realtor® of the Tom Hall Group LLC .

14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. 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, Thomas Hall Realtor® of 

the Tom Hall Group LLC 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 the pilot, or 

anyone assisting the pilot 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. 

1. 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. Their UAS will never 

operate at an altitude greater than 200 AGL; in accordance with the standard of 400 

AGL. Thomas Hall Realtor® of the Tom Hall Group LLC will operate their 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 the UAS, an equivalent or higher level of safety will be 

achieved. 

2. 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 Thomas Hall Realtor® of the Tom Hall Group LLC, UAS. However, as a 

safety precaution Thomas Hall Realtor® of the Tom Hall Group LLC pilot will inspect their 

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 and weight of Thomas Hall Realtor® of the Tom Hall Group LLC 

UAS permits exemption from Part 21 because Thomas Hall Realtor® of the Tom Hall 

Group LLC, UAS meets an equivalent level of safety pursuant to Section 333 of the 

Reform Act. 

Respectfully Submitted, 

Thomas Hall Realtor® of the Tom Hall Group LLC

226 Oakridge Dr, Choctaw Oklahoma 73020