December 05 , 2015

Petition of Steven L Dobyns, Realtor and ATP certified pilot with CL-65 Type Rating, for Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012.

To Whom I t May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Steven L Dobyns, hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed, the DJI UAS manufacturer's operations and/or instructions manual, DJI UAS User’s Manuals, DJI UAS Quick Start Guides, and any other requirements established by the FAA pursuant to Section 333 of the Reform

Act.

This exemption would permit commercial operation by Steven L Dobyns, which uses DJI Phantom 3 Professional, and DJI Phantom 2 Standard to conduct real estate photography and videography, local promotional photography and videography, and aerial mapping and survey. Steven L Dobyns’ operation under the exemption will be subject to strict operating requirements and conditions to ensure safety at all times and under conditions asmay be modified by the FAA as required by Section 333.

UAS’s operated by Steven L Dobyns will be operated under controlled VFR conditions at low altitude in airspace that is permitted in accordance with Steven L Dobyns’ approved Certificate of Authorization (COA).

Steven L Dobyns respectfully submits this request for an exemption because it would enhance services provided to clients in the selling of their real estate properties. The FAA can have confidence that these operations will be conducted at the highest level of safety and only with written approval of property owners. Steven L Dobyns has thousands of hours of Pt.121 experience and will conduct these operations with same level of safety.

For your convenience, Steven L Dobyns has organized this Exemption Request as follows:

I. Petitioner's Description

II. Description of Proposed Operations III. Regulations From Which Exemption is Requested

IV. Public Interest

V. Privacy

IX. Conclusion

I. Petitioner's Description:

Steven L Dobyns is Realtor in Cincinnati, Ohio and member of the Cincinnati Board of Realtors and wishes to provide aerial photography and videography to aid in selling real estate, with the possibility of providing data to mapping and surveyingprofessionals and crop information to local farmers. Steven L Dobyns intends to operate in a compliant and safe environment. and plans on providing a wide range of services as the sUAS market expands.

Steven L Dobyns welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require modification.

II. Description of Proposed Operations

Steven L Dobyns will use UASs that are multi-rotor, weighing less than 55 pounds including payload. They will operate, under normal conditions, at speeds not to exceed 50 mph. The multi rotors have the capability to hover and move in the vertical and horizontal plane. Additionally the DJI Spreading Wings has redundancy built in that allows it to maintain safe flight even with the loss of a motor. They will be operated in “line of sight” and during daylight hours. Steven L Dobyns will operate at or below 400 feet AGL. All photography taken will be with the written permission of the homeowner and used to help market and sell that property. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, Including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant of therequested exemptions is also in the public interest.

Below is a summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 55 pounds. 2. Flights will be operated within line of sight of the PIC and visual

observer. 3. Maximum total flight time for each operational flight will be
limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 30%. 4. Flights will be operated at an altitude of no more than 400 feet
AGL. 5. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advance of the operation. 6. The sUAS PIC will be the petitioner Steven L Dobyns, ATP

Rated.7. The sUAS will operate only within a confined safe and noncongested area. 8. Prior to the operations at a particular location, a pre-flight inspection of the vehicle will be conducted and analysis of the current weather conditions to make certain the flight will be safe. 9. Steven L Dobyns will use a safety and airworthiness checklist. 10. The sUAS will be maintained in compliance with the manufacturer’s guidelines. 11. All required permissions and permits will be obtained in advance from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.12. If the sUAS loses communications signal, the sUAS will have the capability to return to a pre-determined location within the safe and non-congested area. 13. The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergencies. 14. Steven L Dobyns will assure no individuals’ privacy is violated. 15. Procedures have been established to contact ATC prior to operating in airspace other than G.

16. All operations will utilize a visual observer. the UAS will be operated within VLOS of the pic and VO at all times. The PIC and VO will be able to communicate at all times. Steven L Dobyns will be the PIC and will ensure that the VO can perform the duties required of the VO.

III . Regulations From Which Exemption is Requested

A. 14CFR 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a) and (b)

I V. PUBLIC INTEREST

The service provided by this photography will benefit the public and will done safely.

They will dramatically enhance the marketing efforts of the people selling the properties. They’ll be able to show angles and features that can’t be captured by normal cameras. And they’ll help buyers get a better eye on what they’re wanting to buy.

These photos will be taken only in safe conditions at low altitudes.V. Privacy

Steven L Dobyns will only photograph property with written permission of the owners.

VI Conclusion

Steven L Dobyns

8955 E Kemper Rd

Montgomery, OH 45249

513-328-8229

sldobyns@gmail.com

ATP Rated Pilot

Realtor, Comey & Shepherd Realtors