LewisRoca 

ROTHGERBER CHRISTIE 

Lewis Roca Rothgerber Christie LLP 

1200 Seventeenth Street 303 623 9000 main 

Suite 3000 303 623 9222 fax 

Denver, CO 80202 lrrc.com 

March 16, 2016 

Ms. Brittany Newton 

Program Analyst, Airmen and Airspace Rules Division 

U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Thomas J. Dougherty 

Admitted in Colorado 

303.628.9524 direct 

303.623.9222 fax 

tdougherty@lrrc.com 

Re: Petition of Imago Visual for Grant of Exemption Pursuant to Section 333 of FAA 

Modernization and Reform Act of 2012; Docket No. FAA-2015-5883 

Dear Ms. Newton: 

Thank you for your letter of March 10, 2015 concerning the above-referenced Petition of Imago 

Visual for a Section 333 Exemption. Your letter indicates that, pursuant to 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, how would it benefit the public as a whole." 

Statement of Public Benefit 

In addition to the 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 of safety equivalent to the existing 

rule, Imago Visual offers the following further explanation of the public interest and public benefit 

associated with the requested Exemption. 

The stated purpose of the 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 to the 

alternative of using manned aircraft or not obtaining such aerial photography or videography at 

all. 

Aerial photography and videography of architectural 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 or small fixed wing aircraft. The traditional approach, however, entails significant 

expense that frequently makes such photography inaccessible to many consumers. For those 

2005835240_1 

Albuquerque I Colorado Springs I Denver I Irvine I Las Vegas I Los Angeles I Phoenix I Reno I Silicon Valley I Tucson 
LewisRoca 

ROTHGERBER CHRISTIE 

Ms. Brittany Newton 

March 16, 2016 

Page2 

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 of an accident due to the size of the 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 shorter scheduling requirements as compared to manned aircraft 

operations. Of particular concern to the public, the smaller size, weight, and airspeed of a small 

unmanned aircraft operating under a Section 333 Exemption present a reduced risk to persons 

and property on the ground in the event of an accident. In the real estate context, the value of 

using unmanned aircraft to obtain these public benefits was well stated on pages 2-3 of the 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 to the use of manned aircraft for the 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 that was previously costprohibitive for many members of the 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 that the 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 of a Section 333 

exemption. 

Furthermore, the use of unmanned aircraft for the stated purposes also offers potential benefits 

with respect to airspace operations and safety. Given that the subjects of desired 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 speeds thereby presenting 

potential safety conflicts. This potential problem is alleviated by the use of a small unmanned 

aircraft for the same purpose and operating at altitudes below 400 feet AGL pursuant to 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 of the 

type of battery-powered small unmanned aircraft that are the subject of Imago Visual's Petition. 

2005835240_ 1 
Lewis Roca Ms. Brittany Newton 

March 16, 2016 

Page3 

ROTHGERBER CHRISTIE 

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 for the stated purposes and such public benefits would not 

be obtainable. 

Additional Information in Support of Petition for Exemption 

Your March 10, 20151etter also solicits any additional information, views, or arguments 

available to support Imago Visual's Petition for Exemption. 

While not dispositive of the present Petition for Exemption, Imago Visual 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-2015-27 41 ): 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 of these Petitions, as well as numerous other Petitions for similar uses, identify the same 

or similar public benefits as set forth in Imago Visual's Petition and as supplemented in this 

letter. In view of these 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, Imago Visual 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. Thank you. 

Sincerely, ...)-,\· 

Thomas J. Dougherty 

Counsel for Imago Visual 

Encl. 

cc: Ms. Emilie Downs 

2005835240_1 
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2!115 

NATIONAL 

ASSOCIATION of 

REALTORS" 

Ualc i\. Stintun 

Chief F'\:t:cuti\T Officer 

GOVERNMENT AFFAIRS 

DIVISION 

Jerry Giovaniello, Senior Vice President 

Gary Weaver, Vice President 

Joe Ventrone, Vice President 

Scott Reiter, Vice President 

Jamie Gregory, Deputy Chief Lobbyist 

500 New Jersey 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 of Transportation 

1200 New Jersey Avenue, SE. 

Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001. 

(Submitted electronically via http:// www.regulations.gov) 

RE: Comments on Operation and Certification of Small Unmanned Aircraft Systems; 

Docket No.: F AA-2015-0150; Notice No. 15-01. 

To Whom It May Concern: 

I write on behalf of more than one million members of the National Association of 

REALTORS® (NAR) to comment on the Federal Aviation Administration (FAA) Notice of 

Proposed Rulemaking, 'Operation and Certification of Small Unmanned Aircraft Systems'. 

The rule proposes requirements governing the use of small unmanned aircraft systems 

(UAS), which weigh less than 55 pounds1. 

The National Association of REALTORS® is America's largest trade association. 

REALTORS® are involved in all aspects of the residential and commercial real estate 

industries and belong to one or more of some 1,400 local associations or boards, and 54 

state and territory associations of REALTORS®. REALTORS® practicing commercial and 

residential real estate across the country are excited about the prospect of using 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 of concern to REALTORS®, and 

we appreciate the actions FAA has taken to further those goals. Safe operation of this 

emergent technology is a critical objective of these proposed rules and REAL TORS® are 

committed to working with the FAA to create a culture of safety surrounding the use of this 

technology. As potential end-users of this technology, either as operators or through hiring 

third-party vendors, REAL TORS® also understand the role that real estate professionals play 

in the UAS services market. NARis a supporter of the Know Before You Fjy safety campaign. 

NARis a participant in the FAA's Beyond Visual Line of Sight (BVLOS) Working Group. 

REALTORS® appreciate the FAA's leadership in this issue and look forward to being 

responsible users of this technology. 

NAR views 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 what NAR believes is a common sense, 

reasonable approach to this technology. NAR supports the FAA's attempt to address 

different levels of risk posed by different sizes and uses of UASs. The risk present in a 

scenario where an operator is using a small, lightweight UAS in a limited flight path to take 

1 Pub. L. No. 112-95, sec. 331(6). 
pictures of a home or commercial building is much different than in situations where bigger, heavier devices are being used. 

The FAA should strive to ensure that the fmal regulations govern safety in a way that does not unnecessarily restrict the ability 

of users to access the NAS. Safety concerns should be balanced with the opportunities presented by the applications of this 

technology. The fmal rule should create a regulatory regime that is efficient and of minimal burden to the user. The final rule 

should also acknowledge the different risks presented by different UAS and the varying settings in which UAS will be used. 

I. Applications ofUAS Technology in 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 of the home, and 

views afforded by different vantage points that currently are too difficult or expensive to access. The aerial imagery made 

possible through UAS technology will bring a new level of sophistication 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 new home. Being able to easily view the information obtained through the 

use of UAS 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 not well suited for conventional photography due to their size, height, or unconventional shape. 

Introducing UAS technology will be very helpful to commercial real 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't be 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 of a potential buyer 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 of UAS technology. 

Building owners and property managers can use an UAS in similar ways to inspect and maintain properties. Sending an UAS 

to the roof of a building to examine its condition regularly or after a storm is faster and safer than sending up a person. 

Owners and managers can get information about hard-to-access parts of their buildings faster, cheaper and safer by using an 

UAS instead of a person. This is not only a useful tool for routine maintenance, but an indispensable asset after a vandalism 

incident, storm or other natural disaster. Owners and managers using an UAS can get better information about building 

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 photographed using a helicopter or small plane to obtain images. 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 often work on deals with properties that are hundreds or 

thousands of acres of farmland, timber, or undeveloped land. Potential buyers can see the topography, geography, 

hydrogeology features, as well as examine what plants are growing and what animals live on the property. Reviewing the 

images collected from an UAS is more efficient and safer than spending hours or days driving around a property or even flying 

above it in 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. 

The images are another tool for a real estate professional to help a consumer make an informed decision about the property he 

2 
or she is considering purchasing. UAS-obtained images are a cost-effective way to get more information to the consumer, 

when compared with previous methods for aerial photography such as a helicopter or small airplane. 

Just like online listings and 360 degree virtual tours changed the way real estate practitioners do business and serve their 

clients, UAS-obtained imagery is a new advancement of technology that will allow brokers and agents to better serve their 

clients, and allow consumers to make better informed decisions. 

II. Discussion of the Proposed Rule 

NARis pleased to see the FAA moving forward with its integration of UAS into the NAS. Like the FAA, NAR is committed 

to the safety of all citizens and users of the 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 of the UAS community 

and the NAS. 

NARis committed to educating its members about the importance of safety in UAS operations. The consumer power that 

REAL TORS® have as users of UAS technology and UAS services puts them in a unique position as an influential market 

participant. REAL TORS® want to use these services and they want to work with responsible operators or become responsible 

operators themselves. REALTORS® support FAA's efforts to create a safety-focused community of UAS users and service 

providers. So far, NAR has focused its conversation on UAS use in real estate on safety for all involved. Our participation in 

the Know Before You Ffy safety campaign is merely part of our efforts to talk about UAS 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 U AS rules is needed within the FAA and the industry overall. Because so much of the 

authority for integrating UAS into the NAS will fall to FAA regional offices, NAR urges the FAA to ensure its regional offices 

are educated about the requirements governing UAS use. The FAA should also use its position to lead industry education 

about requirements governing UAS use. With so many different industries competing to work with UAS technologies in a 

myriad of ways, the conversation has been clouded about what is truly necessary to create a regulatory framework that both 

protects safety of users of the NAS and citizens, and also allows for these varied uses of the technology. Increased industry 

education about safety standards from the FAA, the voice of safety in aviation, will go a long way toward creating uniform 

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 the potential of this technology. The industry best practices that spring up around the rules will be the real 

proof of success in this arena. These best practices 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 and Accountability 

NAR believes that transparency and accountability of UAS operations are essential to the successful integration 

of this new technology into the NAS. Just as cars, boats, airplanes and other movable machines have 

registration requirements, so should UASs. To understand the identity of the owner and operator of the 

machine is to create a culture of accountability within the UAS user community. We support the Rule's 

registration and marking requirements 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 of bystanders to 

the UAS operation. Prohibiting flight over non-participants, except in the case of people standing under 

protective structures, is a solid starting point for a discussion on bystander safety. But more guidance is needed 

in terms of the operator's obligations for communicating with bystanders that an UAS flight will occur in the 

3 
area. NAR believes that one of the first steps of a safe UAS flight is providing adequate notice to people nearby 

the operation who are not directly participating in the operation of the UAS. Developing a proper protocol that 

will acknowledge safety and privacy concerns for both the operator and bystanders is essential for successful 

integration of UAS into the NAS. 

Many real estate applications of UAS technology could take place in populated areas. There is currently no 

standardized protocol for notice to bystanders before or during an UAS flight. NAR asks the FAA to provide 

greater detail regarding what is expected of UAS operators when providing notice to, communicating with, and 

protecting the safety of individuals who are at or near the location of the UAS operation. For example, how 

much notice is required to clear an area of bystanders before the flight takes place? How should the notice be 

given? Given that the battery life of many UAS is limited to 30 minutes or less, for how long should an area be 

required to be cleared of bystanders? Since the UAS has the capability to fly over neighboring structures that are 

not the dedicated subject of the UAS flight, within what distance should bystanders be provided notice? 

The safety of UAS flight over bystanders is a critical element of the safe operation of UAS technology. Until a 

standardized protocol for notice is developed, notice procedures will vary from operator to operator. As 

Section 333 waivers become more widely available and until the FAA rules for small UASs are fmalized, this 

will result in a patchwork of practices. Citizens and consumers should be able to have a single set of standards 

so that notice protocols are predictable across the country. Predictability in the market will lend itself to the 

accountability and best practices discussed above. 

REALTORS® are committed to creating a culture of safety around the use of this technology, and effective 

communication with non-participants will be very important to the success of this technology. NAR is 

committed to working with 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 uniformity when it comes to safety and privacy of citizens. 

Consistent application of notice policies for UAS operation is a critical aspect of the safe integration of UAS 

into the NAS. 

111. Operator and Visual Observer 

The FAA has proposed creating two new crewmember positions for UAS operators. The operator is the person 

who manipulates the flight controls of a small UAS. The visual observer is a person who 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 of the UAS operation and the machine 

itself. 

In this regime, the operator would bear the brunt of the regulatory burden via education, certiftcation, and 

safety compliance. This makes sense, as it would be the operator who has control of the machine. The visual 

observer is an option the operator can choose, depending on the circumstance of the operation. NAR supports 

this flexibility, as not all flights will require an observer. NAR also supports the flexibility built into the rule by 

not requiring the operator to get an airman certiftcate. Keeping a low regulatory burden for this as-needed 

position is a reasonable decision. 

NAR asks the FAA to be more specific in what is required for the methods of communication between the 

operator and visual observer. Operators should have some degree of choice in how they work with a visual 

observer, who is ostensibly a partner in the operation, but some guidance would be helpful. NAR does not 

believe that it is necessary that the observer should be required to stand close enough to the operator to allow 

for unassisted verbal communication, as communication-assisting devices 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 of the UAS operation, so any requirement to mandate the 

observer to stand within a certain physical proximity to the operator would defeat that stated purpose. 

4 
B. Training of Operator 

NAR supports the FAA's proposal to create a separate class of airman certificate for UAS operations, and to 

establish testing standards within this operator class. This action balances the need for industry standards and 

regulations with the realities of operating 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 of the NAS through sharing 

information such as pilot background checks and operator safety records. We also understand the national security 

implications of devices and people within the NAS. For these reasons, we support the FAA's efforts to create 

operational standards and official records for users of UAS technology. 

The education, testing, re-testing, reporting, and drug and alcohol screenings contained within the proposal represent 

a well-structured regulatory regime governing the use of UAS within the NAS. Integrating UAS safety into the 

successful FAA framework for pilot safety, education and testing is a reasonable and logical step and addresses the 

national security concerns inherent in operating an UAS in the NAS. NAR believes that industry-wide educational, 

performance, and accountability standards will make for a safe integration of UAS 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 manned vehicle. 

Because the FAA already has a testing regime set up for pilots of manned aircraft, it follows that the UAS operators 

would receive the same treatment. The Initial Knowledge Test, as proposed, covers many of the 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 of the UAS to demonstrate 

aeronautical knowledge is a basic effort toward safety that will protect individuals on the ground and UAS operators. 

The Recurrent Knowledge Test every 24 months fits in with current FAA safety requirements. The same standard 

should be extended to UAS operators. 

C. Visual Line of Sight/Beyond Visual Line of Sight 

NAR recognizes the obstacles in addressing beyond visual line of sight (BVLOS) safety operations. NAR has been 

working through some of these issues through its participation in the FAA's BVLOS Working Group. Maintaining 

visual contact with the aircraft is the essential element to the safety precautions built into the observer/ operator 

partnership, especially as most UAS lack sense-and-avoid technology. However, many applications for UAS use in 

real estate could be in BVLOS situations, such as fllrning or photographing a farm, ranch or office building. 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 of the 

flight path, the population within the flight path, and any other infrastructure or other hazards within the flight path. 

It's not hard to imagine the hazards of an 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 many real estate professionals who work in more 

rural settings and deal with properties such as farmland, ranches or woodlands, the risk is much less. Creating some 

sort of regulatory framework for situations where a BVLOS flight would be 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' of observers working with a single operator of an 

UAS, NAR suggests that the FAA consider a relay system of operators rather than observers in a BVLOS flight 

5 
situation. The main difference between the observer and the operator in the schema that the FAA has presented is 

that the operator actually has control of the machine and visual contact, where the observer has only visual contact 

with the machine. Since maintaining control of the machine is the key challenge here, it is worth considering the 

possibility of multiple operators who could relay control of the machine to one another as the circumstance dictates. 

Many of the larger parcels ofland, taller structures and unique structures that real estate professionals work with 

would be well-suited to UAS imagery, but only if the 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 

communicating with 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. NAR looks to the FAA for leadership to create rules within this rulemaking context that would 

support the safe use of UAS in a BVLOS setting. 

D. Micro UAS Category 

NARis pleased to see that the FAA recognizes the unique nature of micro 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 that the 

United States follows suit. Even though the U.S. airspace is distinctive in terms of its 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 presented by 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 working with the FAA to create a culture of safety surrounding the use of UAS, 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 of NAR's efforts to raise NAR members' awareness of safety issues surrounding 

UAS operations, and we 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 integrating UAS 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 of REALTORS® 

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

6