# LewisRoca ROTHGERBER CHRISTIE
Lewis Roca R othgerber Christie LLP 1200 Seventeenth Street 3036239000 main Suite 3000 3036239222 fax Denver ,CO 80202 lrrc

. com


### March 16, 2016

Ms. Brittany Newton Program Analyst, Airmen and Airspace Rules Division U.S. Department ofTransportation Federal Aviation Administration 800 IndependenceAvenue, S.W

. Washington , D

.C

. 20591 Thomas J. Dougherty Admitted in Colorado 303.628
.9524direct 303.623.9222 fax tdougherty@lrrc.com



### Re: Petition of Imago Visual for Grant of Exemption Pursuantto Section 333 of FAA Modernization and Reform Act of2012; 

### Docket No. FAA-2015-5883 Dear Ms. Newton: Thank you foryour letterofMarch 10, 2015 concerning the above-referenced Petition of Imago Visual for a Section 333 Exemption. Your letter indicates that, pursuantto 14 C.F.R. 

### § 11.81, additional information is required concerning "the reasons why granting the request would be in the public interest; that is, howwould it benefit the public as a whole

." 

### Statement of Public Benefit In addition tothe information contained in the original Petition, particularly the discussion on pages 

### 8 through 11 explaining how each requested exemption benefits the public as a whole, would not adversely affect safety, and would provide a level ofsafety equivalenttothe existing rule, Imago Visual offers thefollowing furtherexplanation ofthe public interest and public benefit associated with the requested Exemption. The stated purpose ofthe requested Exemption is for aerial photography and videography in connection with various architectural and real estate marketing purposes. The use of unmanned aircraft for these purposes offers numerous public benefits as compared tothe alternative of using manned aircraft or not obtaining such aerial photography orvideography at all. Aerial photography and videography ofarchitectural projects and real estate offered for sale provides the public a perspective not obtainable from ground-based photography and videography. Architects and developers can obtain views of projects in relation to adjacent structures and properties that are simply not obtainable from the ground. Similarly, buyers and sellers of real estate can view properties in relation to adjacent homes, buildings, and neighborhoods in ways not otherwise possible

. These public benefits are well-recognized and have traditionally been obtained through the use of helicopters orsmall fixed wing aircraft. Thetraditional approach, however, entails significant expensethatfrequently makes such photography inaccessibleto many consumers. Forthose

2005835240_1 Albuquerque I Color ado Spr ings I Denver I Irvine I Las Vegas I LosAngeles I Phoenix I Reno I Silicon Valley I T ucson

# LewisRoca ROTHGERBERCHRISTIE Ms

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### consumers who can afford such manned-aviation services. they must still contend with time consuming scheduling requirements. Most importantly, using manned aircraft to obtain such photography places aircrews at risk and creates a substantial risk to persons and property on the ground in the event ofan accident due to the size ofthe aircraft and its airspeed

. By comparison, unmanned aircraft can provide the same public benefits at substantially reduced costs as compared to manned aircraft. Unmanned aircraft operations under a Section 333 Exemption and applicable COA and NOT AM requirements also offer the potential for more frequent flights and shorterscheduling requirements as compared to manned aircraft operations. Of particular concern tothe public, the smaller size, weight, and airspeed ofa small unmanned aircraft operating undera Section 333 Exemption present a reduced risk to persons and property on the ground in the event ofan accident. In the real estate context, the value of using unmanned aircraft to obtain these public benefits was well stated on pages 2-3 ofthe April 24, 2015 comments filed by the National Association of Realtors in Docket No. FAA-2015-0150

. (Copy enclosed and incorporated herein by reference.) Given their numerous advantages as compared tothe use of manned aircraft forthe same purposes stated in the Petition, small unmanned aircraft can facilitate greater economic activity in the architectural and real estate sectors through the expanded access to such aerial-based information

. In essence, using unmanned aircraft for aerial photography and videography of architectural projects and real estate listings provides a new service thatwas previously costprohibitivefor many members ofthe public when using manned aircraft for these purposes. The public safety benefit derived from the reduced risks associated with small unmanned aircraft operations cannot be understated. Architectural and real estate photography frequently requires manned aircraft to operate at low altitudes and reduced airspeeds to obtain the necessary quality of photography

. In these flight regimes aircraft have a reduced margin of safety as compared to operations at higher altitudes and greater airspeeds. This consideration must be combined with the fact thatthe aircraft are operating over developed areas where the subject building or property is located

. These risks are substantially reduced through use of small unmanned aircraft operating within the conditions and limitations ofa Section 333 exemption. Furthermore, the use of unmanned aircraftforthe stated purposes also offers potential benefits with respect to airspace operations and safety

. Given that the subjects ofdesired aerial photography and videography may be located in developed areas, it is possible that other manned aircraft operations will occur in the same area. As a result, slow moving and circling or hovering manned aircraft engaged in photography activities may be operating in the same airspace as other manned aircraft transiting the area at higher speedsthereby presenting potential safety conflicts

. This potential problem is alleviated by the use ofa small unmanned aircraft forthe same purpose and operating ataltitudes below 400feet AGL pursuantto a Section 333 Exemption and applicable COA. Finally, it is reasonable to conclude that small unmanned aircraft operations will result in less environmental pollution (emissions. noise, etc.) and be less intrusive to public interests as compared to manned aircraft operations for the same purpose. This is particularly true ofthe type of battery-powered small unmanned aircraft that are the subject of Imago Visual's Petition.

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# Lewis Roca Ms

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### In summary, the requested Exemption provides numerous public benefits by making aerial photography and videography more accessible to architects, project developers, buyers and sellers of real estate, and the public in general. This accessibility will promote greater economic activity and will do so while concurrently reducing the risks associated with using larger manned aircraft for the same purposes. Without the exemptions requested in the Petition, it would not be possible to use unmanned aircraft forthe stated purposes and such public benefits would not be obtainable. Additional Information in Support of Petitionfor Exemption Your March 10, 20151etter also solicits any additional information, views, or arguments available to support ImagoVisual's Petition for Exemption

. While not dispositive ofthe present Petition for Exemption, ImagoVisual notes that numerous Exemptions have been granted in connection with Petitions for uses that are substantially the same as those described in Imago Visual's Petition

. A few examples of recent Exemptions approved by the FAA for substantially similar uses include: Exemption No

. 12992 (Docket No. FAA-2015-2741 ): aerial photography, videography, and training; Exemption No

. 15301 (Docket No

. FAA-2015-6328): aerial photography, cinematography, videography, and other purposes; Exemption No. 15305 (Docket No. FAA-2015-6342) : aerial photography and videography on private property; Exemption No

. 15307 (Docket No

. FAA-2015-6343): aerial photography and videography for real estate marketing and other purposes; and Exemption No. 15253 (Docket No

. FAA-2015-6289): aerial photography for residential, commercial, industrial real estate, and other purposes. Each ofthese Petitions, as well as numerous other Petitions for similar uses, identify the same or similar public benefits as setforth in ImagoVisual's Petition and as supplemented in this letter. In view ofthese previously granted Exemptions which are substantially the same as that requested by Imago Visual, and given that granting of Imago Visual's Petition will not set a precedent, ImagoVisual respectfully submits that its Petition, as supplemented herein, is appropriate for expedited approval under 14 C.F.R. 11.87

. Please do not hesitate to contact me should you require any additional information. Thankyou . Sincerely, 

# ...)-,\·

Thomas

### J. Dougherty Counsel for Imago Visual Encl.
cc: Ms. Emilie Downs

2005835240

_1(;l)ri:-: 2!115 NATIONAL ASSOCIATION

### of REALTORS"

Ualc i\. Stintun ChiefF'\:t:cuti\T Officer GOVERNMENTAFFAIRS DIVISION Jerry Giovaniello, Senior Vice President Gary Weaver, Vice President Joe Ventrone, Vice President Scott Reiter, Vice President Jamie Gregory, Deputy ChiefLobbyist
500 NewJersey Ave., NW Washington, DC 20001-2020 Ph. 202-383-1194 Fax 202-383-7580 W\VW.REALTOR.org**~1HOU~I«< i)~f>Q-~ll,l!-11**  tV
membnrship rnay be used only by real estate pmfessioni:lls- wrw are member:> of the NATIONAL ASSOCIATION OF REAlTORS• and subscribe to its strict Code of Ethics. April24, 2015 Docket Operations, M-30 U.S. Department ofTransportation 1200 NewJersey Avenue, SE. RoomW12-140 WestBuilding Ground Floor Washington, DC 20590-0001. (Submitted electronicallyvia 

### http:// www.regulations.gov) RE: Comments on Operation and Certification ofSmallUnmannedAircraft Systems; DocketNo.: FAA-2015-0150; Notice No. 15-01. To Whom ItMay Concern: I write on behalfofmore than one million members ofthe NationalAssociation of REALTORS® (NAR) to comment on the FederalAviation Administration (FAA) Notice of Proposed Rulemaking, 'Operation and Certification ofSmall Unmanned Aircraft Systems'. Therule proposes requirements governing the use of small unmanned aircraft systems (UAS), which weigh less than 55 pounds 1

. The NationalAssociation ofREALTORS® is America's largest trade association. REALTORS® are involved in all aspects ofthe residential and commercialreal estate industries and belong to one or more ofsome 1,400 local associations or boards, and 54 state and territory associations ofREALTORS®. REALTORS® practicing commercial and residentialreal estate across the country are excited about theprospect ofusing unmanned aircraft systems (UAS) in their businesses, including by using UASs for aerial photography, videography, and property inspection. Personal safety and privacy issues related to UAS are also ofconcern to REALTORS®, and we appreciate the actions FAA has taken to further those goals. Safe operation ofthis emergent technology is a critical objective ofthese proposed rules and REAL TORS® are committed to working with the FAA to create a culture of safety surrounding the use ofthis technology. As potential end-users ofthis technology, either as operators or through hiring third-party vendors, REAL TORS® also understand the role that real estateprofessionals play in the UAS services market. NARis a supporter ofthe 

### Know 

### Before You Fjy safety campaign. NARis a participantin the FAA's Beyond Visual Line ofSight (BVLOS) Working Group. REALTORS® appreciate the FAA's leadership in this issue and look forward to being responsible users ofthis technology. NARviews the proposed rule as an excellent flrst step toward integrating UAS technology into the National Air Space (NAS) and allowing the UAS industry to flourish. The rule's risk- and safety-based approach comports with whatNAR believes is a common sense, reasonable approach to this technology. NAR supports the FAA's attempt to address different levels ofrisk posed by different sizes and uses ofUASs. The risk present in a scenario where an operator is using a small, lightweight UAS in a limited flight path to take

1Pub. L. No. 112-95, sec. 331(6).pictures ofa home or commercialbuildingis much different than in situations where bigger, heavier devices are beingused. The FAA should strive to ensure that the fmal regulations govern safety in a way that does not unnecessarily restrict the ability ofusers to access the NAS. Safety concerns should be balanced with the opportunities presented by the applications ofthis technology. The fmal rule should create a regulatory regime that is efficient and ofminimal burden to the user. The final rule should also acknowledge the different risks presented by different UAS and thevarying settings inwhich UAS will be used. I. 

### Applications ofUAS Technologyin Real Estate The potential applications for UAS technology in the real estate industry are plentiful. The images and videos obtained using UAS technology are the next step in consumer information for the digital age. A residential real estate practitioner can use a video or images obtained through UAS technology to create a robust web-based listing for a property that can be viewed by potential purchasers. Buyers can see the interior and exterior ofthe home, and views afforded by differentvantage points that currently are too difficult or expensive to access. The aerial imagery made possible through UAS technology will bring a newlevel ofsophistication and accessibility to images and information, and make it available to both the real estate practitioner and their clients. This imagery is an incredible tool for potential homeowners moving to a different city, buying a second home, or trying to streamline the research process necessary to buy a newhome. Being able to easily view the information obtained through the use ofUAS technology 

### will help better inform the consumer. Just as digital photography made it easier to create high-quality, affordable images, real estate practitioners look forward to using UAS technology to take their listings into the next level in technical creativity and quality. Many structures are notwell suited for conventional photography due to their size, height, or unconventional shape. Introducing UAS technology

### will bevery helpful to commercialreal estate practitioners who work with properties such as strip malls, office parks, parking lots, or farms. Commercial properties such as a shopping center, an office building, or a restaurant often can'tbe seen as a whole in a single image. Using images taken from an UAS can help the real estate practitioner efficiently market complex properties. The ability ofa potentialbuyer or tenant to examine a several thousand square foot office building, including exterior walls, parking structures, roof, and other fixtures from the safety and comfort of his or her office is an invaluable advantage afforded by the use ofUAS technology. Building owners and propertymanagers can use an UAS in similar ways to inspect and maintain properties. Sending an UAS to the roofofa building to examine its condition regularly or after a storm is faster and safer than sendingup a person. Owners and managers canget information about hard-to-access parts oftheir buildings faster, cheaper and safer by using an UAS instead ofa person. This is not only a useful tool for routine maintenance, but an indispensable asset after avandalism incident, storm or other natural disaster. Owners and managers using an UAS can getbetterinformation aboutbuilding damage faster, can communicate quickly and effectively with their insurance companies, and ideally get their properties back to normal after a destructive event using the information gained from one or a few short UAS flights to gather information and unages. Traditionally these properties have been photographedusing a helicopter or small plane to obtainimages. Using an UAS is less expensive, less time consuming, and less dangerous to everyone involved. The same benefits also apply to land sales. Real estate practitioners oftenwork on deals with properties that are hundreds or thousands ofacres offarmland, timber, or undeveloped land. Potentialbuyers can see the topography, geography, hydrogeology features, as well as examine whatplants are growing and what animals live on the property. Reviewing the images collected from an UAS is more efficient and safer than spendinghours or days driving around a property or even flying above itin a chartered plane or helicopter. Any consumer making a real estate purchase or entering into a lease can benefit from the images obtained by using an UAS. Theimages are another tool for a real estate professional to help a consumer make an informed decision about the property he

2or she is consideringpurchasing. UAS-obtainedimages are a cost-effective way to getmore information to the consumer, when compared with previous methods for aerial photography such as a helicopter or small airplane. Justlike online listings and 360 degree virtual tours changed the way real estatepractitioners do business and serve their clients, UAS-obtained imagery is a new advancement oftechnology that

### will allow brokers and agents to better serve their clients, and allow consumers to make better informed decisions. 

### II. Discussion ofthe Proposed Rule NARis pleased to see the FAA moving forward with its integration ofUAS into the NAS. Like the FAA, NAR is committed to the safety ofall citizens and users ofthe NAS. A one-size-fits-all approach

### will not effectively integrate technology as diverse as UAS into a complex air space. NAR supports FAA's approach to address the varying needs ofthe UAS community and the NAS. NARis committed to educatingits members about the importance ofsafety in UAS operations. The consumer power that REAL TORS®have as users ofUAS technology and UAS services puts them in a unique position as an influential market participant. REAL TORS®want to use these services and theywant to work with responsible operators or becomeresponsible operators themselves. REALTORS® support FAA's efforts to create a safety-focused community ofUAS users and service providers. So far, NAR has focused its conversation on UAS use in real estate on safety for all involved. Ourparticipationin the 

### Know Before You Ffy safety campaign is merely part ofour efforts to talk aboutUAS with safety as a key priority. Through education sessions, materials, and web site content, NAR has informed its members about the safety precautions necessary when using this technology. NAR believes that more education on UAS rules is needed within the FAA and the industry overall. Because so much ofthe authority for integrating UAS into the NAS 

### will fall to FAA regional offices, NAR urges the FAA to ensureits regional offices are educated about the requirements governing UAS use. The FAA should also useits position to lead industry education about requirements governing UAS use. With so many differentindustries competing to work with UAS technologies in a myriad ofways, the conversation has been clouded about whatis truly necessary to create a regulatory framework thatboth protects safety ofusers ofthe NAS and citizens, and also allows for these varied uses ofthe technology. Increasedindustry education about safety standards from the FAA, the voice of safetyin aviation, will go a long way toward creatinguniform standards within the industry. Creating a regulatory regime in which commercial UAS operations can be safely integrated into the NAS is the first step toward realizing thepotential ofthis technology. The industry best practices that spring up around the rules will be the real proofof success in this arena. These bestpractices could include operator education, insurance programs and an ongoing dialogue among UAS users, FAA headquarters, and the FAA's regional offices. A. Safety

1. Operations andAccountability NAR believes that transparency and accountability ofUAS operations are essential to the successful integration ofthis new technology into the NAS.Just as cars, boats, airplanes and other movable machines have registration requirements, so should UASs. To understand the identity ofthe owner and operator ofthe machine is to create a culture ofaccountability within the UAS user community. We support the Rule's registration andmarkingrequirements and believe this is a logical step in furthering the FAA's safety objectives.

11. Bystanders NAR appreciates the common-sense approach that the FAA has taken in addressing the safety ofbystanders to the UAS operation. Prohibiting flight over non-participants, except in the case ofpeople standing under protective structures, is a solid starting point for a discussion on bystander safety. But more guidance is needed 

### in terms ofthe operator's obligations for communicatingwith bystanders that an UAS flight 

### will occurin the 3area. NAR believes that one ofthe first steps ofa safe UAS flight is providing adequate notice to people nearby the operationwho are not directly participatingin the operation ofthe UAS. Developing a properprotocol that will acknowledge safety and privacy concerns for both the operator and bystanders is essential for successful integration ofUAS into the NAS. Manyreal estate applications ofUAS technology could take placein populated areas. There is currently no standardized protocol for notice to bystanders before or during an UAS flight. NAR asks theFAA to provide greater detailregardingwhatis expected ofUAS operators when providing notice to, communicatingwith, and protecting the safety ofindividuals who are at or near the location ofthe UAS operation. For example, how much notice is required to clear an area ofbystanders before the flight takes place? How should the notice be given? Given that the battery life ofmany UAS is limited to 30 minutes orless, for how long should an area be required to be cleared ofbystanders? Since the UAS has the capability to fly over neighboring structures that are not the dedicated subject ofthe UAS flight, within whatdistance should bystanders be provided notice? The safety ofUAS flight over bystanders is a critical element ofthe safe operation ofUAS technology. Until a standardized protocol for notice is developed, notice procedures will vary from operator to operator. As Section 333 waivers become morewidely available and until the FAA rules for small UASs are fmalized, this will result in a patchwork ofpractices. Citizens and consumers should be able to have a single set of standards so that notice protocols are predictable across the country. Predictabilityin the marketwill lend itselfto the accountability and best practices discussed above. REALTORS® are committed to creating a culture of safety around the use ofthis technology, and effective communicationwith non-participants 

### will bevery important to the success ofthis technology. NAR is committed to workingwith the FAA to identify common fact patterns in these situations and to help create solutions that will work for bystanders and UAS operators alike. NAR supports policies that lead to predictability uniformitywhen it comes to safety and privacy ofcitizens. Consistent application ofnotice policies for UAS operation is a critical aspect ofthe safe integration ofUAS into the NAS.

111. Operator andVisual Observer The FAA has proposed creating two new crewmember positions for UAS operators. The operator is the person who manipulates the flight controls ofa small UAS. Thevisual observer is a personwho assists the small unmanned aircraft UAS operator in seeing and avoiding other air traffic or objects aloft in flight or on the ground. NAR supports this proposition, as it reflects the unique nature ofthe UAS operation and the machine itself. In this regime, the operatorwould bear the brunt ofthe regulatory burdenvia education, certiftcation, and safety compliance. This makes sense, as itwould be the operator who has controlofthe machine. Thevisual observer is an option the operator can choose, depending on the circumstance ofthe operation. NAR supports this flexibility, as not all flights will require an observer. NAR also supports the flexibility built into therule by not requiring the operator to get an airman certiftcate. Keeping a low regulatory burden for this as-needed positionis a reasonable decision. NAR asks the FAA to be more specific in whatis required for the methods ofcommunicationbetween the operator andvisual observer. Operators should have some degree ofchoice in how they workwith a visual observer, who is ostensibly a partner in the operation, but some guidance would be helpful. NAR does not believe thatitis necessary that the observer should be required to stand close enough to the operator to allow for unassisted verbal communication, as communication-assistingdevices are available, reliable and efftcient at enabling communication between the operator and visual observer. Further, the FAA acknowledges that the visual observer could be used to extend the flexibility ofthe UAS operation, so any requirement to mandate the observer to stand within a certain physicalproximity to the operator would defeat that stated purpose.
4B. TrainingofOperator NAR supports the FAA's proposal to create a separate class ofairman certificate for UAS operations, and to establishtesting standards within this operator class. This action balances the need for industry standards and regulations with therealities ofoperating an UAS within the NAS. NAR understands the FAA's role in regulating access to the NAS, both through the machines and technology used, and the people who are operating them. NAR understands that the FAA works cooperatively with other agencies to ensure the safety ofthe NAS through sharing information such as pilotbackground checks and operator safety records. We also understand the national security implications ofdevices and people within the NAS. For these reasons, we support the FAA's efforts to create operational standards and official records for users ofUAS technology. The education, testing, re-testing, reporting, and drug and alcohol screenings containedwithin the proposalrepresent a well-structured regulatory regime governing theuse ofUAS within the NAS. Integrating UAS safety into the successfulFAA framework for pilot safety, education and testingis a reasonable and logical step and addresses the national security concerns inherentin operating an UAS in the NAS. NARbelieves that industry-wide educational, performance, and accountability standards will make for a safe integration ofUAS into the NAS, and 

### will create a well-disciplined industry from the start. The FAA's proposed testing regime is a practical solution to creating industry safety and knowledge standards while making entrance into the UAS industry a possibility for many. The FAA understands that some operators come to the UAS space with extensive piloting experience, while others may have minimal or no piloting experience. However, the UAS operations contemplated under this rule have very different requirements and challenges than flying a mannedvehicle. Because the FAA already has a testing regime setup for pilots ofmanned aircraft, it follows that the UAS operators would receive the same treatment. The Initial Knowledge Test, as proposed, covers many ofthe essential basics required to properly and safely operate UAS. Administering the test at testing centers throughout the United States will ensure uniform test administration, content and standards. Requiring all users ofthe UAS to demonstrate aeronautical knowledge is a basic effort toward safety that will protectindividuals on the ground and UAS operators. The Recurrent Knowledge Test every 24 months fits inwith current FAA safety requirements. The same standard should be extended to UAS operators. C. Visual Line ofSight/BeyondVisual Line ofSight NAR recognizes the obstacles in addressing beyondvisual line of sight (BVLOS) safety operations. NARhas been working through some ofthese issues through its participation in the FAA's BVLOS Working Group. Maintaining visual contactwith the aircraft is the essential element to the safety precautions builtinto the observer/operator partnership, especially as most UAS lack sense-and-avoid technology. However, many applications for UAS use in real estate could bein BVLOS situations, such as fllrning or photographing a farm, ranch or officebuilding. NAR encourages the FAA to consider some alternate solutions.
First, NAR suggests that the FAA consider a tiered system for BVLOS operations depending on the location ofthe flight path, the populationwithin the flight path, and any other infrastructure or other hazards within the flight path. It's not hard to imagine the hazards ofan UAS that has strayed from the operator's sight within a more populous area such as a suburban community or a downtown area. But for manyreal estate professionals who workin more rural settings and deal with properties such as farmland, ranches orwoodlands, the risk is much less. Creating some sort ofregulatory framework for situations where a BVLOS flight wouldbe acceptable would solve many challenges for real estate professionals and UAS operators in these situations. Second, while the FAA has specifically prohibited a 'daisy-chain' ofobservers workingwith a single operator ofan UAS, NAR suggests that the FAA consider a relay system ofoperators rather than observers in aBVLOS flight 5situation. The main difference between the observer and the operator in the schema that the FAA has presentedis that the operator actually has control ofthe machine and visual contact, where the observer has only visual contact with the machine. Since maintaining control ofthe machine is the key challenge here, it is worth consideringthe possibility ofmultiple operators who could relay control ofthe machine to one another as the circumstance dictates. Many ofthe larger parcels ofland, taller structures and unique structures that real estate professionals work with would bewell-suited to UAS imagery, but only ifthe BVLOS conditions can be addressed. In a relay situation, the multiple operators could both observe and control the machine, rather than merely observe. The real-time corrections necessary to perfect an UAS flight could be made instantaneously, rather than the observer communicatingwith the operator and there being a lag in the time the correction is orally given and then made within the operation. The safety challenges surrounding BVLOS operations are complex, and NAR supports the FAA's efforts to work through them. NARlooks to the FAA for leadership to create rules within this rulemaking context thatwould supportthe safe use ofUAS in a BVLOS setting. D. Micro UAS Category NARis pleased to see that the FAA recognizes the unique nature ofmicro UAS2

. Many consumer UAS currendy fit into this category and the numbers 

### will only expand as the technology becomes more affordable and easier to use. As many other countries have established this same structure in their UAS regulations, it is only natural thatthe United States follows suit. Even though the U.S. airspace is distinctive in terms ofits complexity and variety, there are regulatory models from other countries already integrating UAS in their airspace and from which the FAA could and does take inspiration. NAR appreciates the FAA's creativity in looking to other, successful regulatory models. The micro UAS are smaller, lighter, and have shorter battery lives than the UAS contemplated in the NPRM. Because the risk presentedby these micro UAS is lesser than the risk presented by small UAS, NAR supports the FAA's attempts to create a regulatory schema that acknowledges and accommodates the different risk factors. 

### III. Conclusion NARis committed to workingwith the FAA to create a culture ofsafety surroundingthe use ofUAS, while still enabling users to employ the technology with ease and efficiency. NAR's participation the 

### Know Before You Fly campaign and the FAA BVLOS Working Group are two examples ofNAR's efforts to raise NAR members' awareness of safety issues surrounding UAS operations, andwe will continue to pursue the conversation on UAS safety in the years ahead. NAR believes that the FAA's proposed rule goes a long way toward successfully integratingUAS into the NAS. NAR supports the FAA's efforts and looks forward to the FAA addressing NAR's comments and questions oudined in this letter. Sincerely,

Chris Polychron 2015 President, National Association ofREALTORS®

2A micro UAS as proposed in the NPRMis an UAS that weighs no more than 4.4 lbs. 6