Aug 1 8 th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Real Estate Showcase, Inc. , for an Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and

14 C.F.R. Part 11, Real Estate Showcase, Inc. (Showcase) hereby applies for an exemption from the

Federal Aviation Regulations ("FARs") identified below to allow commercial operation of small

unmanned aerial vehicles ( i.e., " small unmanned aircraft" or " UAS ”) for providing aerial photography

and videography for the commercial real estate industry as well as property mapping, inspections and 3D

compositing.

This petition for exempti on addresses pertinent FAA FAR’s and CFR’s as well as, but not
limited to, these accompanying Showcase’s documents.

1. Flight Operations Ma nual and;

2. Operations Manuals

(collectively referred to as Operations Manuals")

3. User Guide and;

4. User Manual

(collectively referred to as "Manufacturer's Manual"). 1

Showcase submits these as well as other Showcase supporting materials as confidential

documents pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or

proprietary information that the Showcase has not and will not share with others. Additionally, these

documents contain operating conditions and procedures that are not generally available to the public and

are protected from release under the Freedom of Information Act, 5 U.S.C. §552 et seq.

1 The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but

not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot
training manuals, service information letters and, safety/service bulletins).U.S. Department of Transportation Aug 18 th

, 2015 Page 2

This Petition is organized as follows:

I. Petitioner

II. Description of Proposed Operations

A. Real Estate Aerial Photography Videography

, Mapping and Inspection Service

III. Relevant Statutory Authority

IV. Showcase Proposed RE

- UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the RE

- UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification

Requirements D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91. 417(a) and (b):

Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a)

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. ConclusionU.S. Department of Transportation Aug 18 th

, 2015 Page 3

I. DESCRIPTION OF PETITIONER

Real Estate Showcase is based in Fort Myers, Florida, working in photography and videography services. Jay

Letendre has 11 years of valuable working experience in the Real Estate industry as a videographer, still photographer and technology professional. Jay’s technology professional background is in Real Estate digital publishing and IT establishing and supporting LAN/WAN networks and video production and post production.

The Company specializes in, and will continue to focus on, digital publication, photography, mobile technology business within the Real Estate Industry, specifically the videography and photography of commercial property

and real estate for sales purposes as well as property mapping, inspections, and 3D image development and production

.

The company also shoots travel videos on a limited bases for the real estate industry

. The Company’s Principal has

been building and flying sUAV Quadcopters as a hobby for more than four years without incident, spending

thousands of hours flying as well as eight years of video production experience. The Company also employs two
partners, one of whom serves as primary camera operator and director of photography. The work generated provides a major source of all of our income.

The contact information for Petitioner is as follows:

Jay Letendre

Real Estate Showcase, Inc.

17568 Homewood Rd.

Fort Myers, FL 33967

Phone: 239.287.8927

Email: Jay@trebfl.com

II. DESCRIPTION OF PROPOSED OPERATION

Showcase seeks an exemption pursuant to Section 333 of the Reform Act to operate the 3D R o botics Solo

and 3D robotics iris also k nown as, ( RE

- UASs) for the proposed operations discussed below. RE

- UAS
operations will occur under tightly controlled conditions on private property where Showcase has received
permission to operate from the landowner, controller or authorized representatives. The proposed RE

- UAS
operations will be conducted in accordance with the conditions and limitations of this Petition for
Exemption and Showcase’s Operations Manuals. As detailed in Showcase’s Operations Manuals, RE

- UAS
operations will be limited to daytime VFR conditions, within visual line

- of

- sight ("VLO S") of the operator,
in uncontrolled airspace, and will occur at least 5 nm away from an airport. Moreover, Showcase’s
Operations Manuals incorporate redundant safeguards to assure that the aircraft does not travel outside the

controlled area of RE

- UAS op erations, including GPS "geo

- fencing" technologies.

A. Real Estate Aerial Photography, Videography , Mapping and Inspection Service

Showcase seeks to use UAS for the purpose of conducting aerial photography, videography

, mapping and inspection services for the real estate industry.U.S. Department of Transportation Aug 18 th

, 2015 Page 4

Company has tailored its operations to meet the requirements established by the FAA in prior grants of

exemptions authorizing the commercial use of UAS in general photography and videography and the

s ame for the production of video in the real estate industry including:

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Trudeau, Realtor® (Exemption No. 11138)

 Alon Sicherman (Exemption No. 11728)

 Sokoler Medley (Exemption No. 11341)

UAS real estate photography and videography operations will be conducted on private property in

a controlled area, away from spectators and persons not involved in the video production. UAS video

photography will be conducted during daylight hours, VFR conditions, at altitudes below 400' AGL. As

set forth below, Company ’s operations provide a superior level of safety and quality compared to
performing the same videography work using conventional fixed

- wing aircraft or helicopters.

Traditional methods of real estate video production and inspection of structures, expose videographer

- inspectors to higher risks of serious injuries, or death. Videographer

- inspectors need to
climb roof tops or otherwise perform elevated work, which exposes them to the risk of dangerous falls,

electrocution or other work related extremes. In addition, depending on the nature of the video needed

and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites

and construction facilities often involves a risk of exposure to hazardous. The use of RE

- UASs

mitigates these hazards and is ultimately a much safer method of performing these and most other

types of inspections.

RE

- UAS real estate video production and inspection of structures is much safer than traditional

manned aircraft performing the same function. Conventional operations using rotorcraft and fixed

- wing

aircraft in low level operations present very high risks with vehicles weighing thousands of pounds,

carrying passengers and large amounts of fuel. It is important to note that the use of small RE

- UAS in

this area will not only be safer and more cost effective, but the quality of collected data and information

is far superior.

RE

- UAS real estate video production and inspection of structures is more reliable, and allows for

the collection, dissemination, and storage of visual content and other sensory data with greater precision

and duration. RE

- UASs are also capable of accessing finish and structu ral quality through the use of

video and inspecting areas that would otherwise be inaccessible to humans and would be impossible to
be completed with conventional aircraft or other inspection methods.U.S. Department of Transportation Aug 18 th

, 2015 Page 5

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA
Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the natio nal airspace system."

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the following

considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's

safety regulations and minimum standards when the Administrator decides a requested exemption is in

the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. §

44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702

– 44716, et seq. ). A party
requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how i t would provide a level of safety at least

equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. REAL ESTATE SHOWCASES’ PROPOSED RE

- UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

The small RE

- UAS operations proposed by Showcase in this Petition for Exemption qualify for

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and

relevant factors are satisfied.

A. Approval is Warranted Based on the RE

- UAS's Size, Weight, Speed, and Operational

Capability

A Grant of Exemption is appropriate for operations conducted using the RE

- UASs due to its size
weight, speed, and operational capability.U.S. Department of Transportation Aug 18 th

, 2015 Page 6

 The RE

- UASs have been approved for use in prior Section 333 Grants of Exemption from the FAA. 2

 The RE

- UASs weigh less than 55 pounds, including payload.

 The RE

- UASs will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GP S
triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof.

This information will be transmitted to the pilot via telemetric data feed.

 The RE

- UASs will have system redundancies and independent functionality to ensure the overall

safety and predictability of the system. If connection to the remote control or ground control station
is lost, failsafe systems will permit the RE

- UAS to return to a predetermined location and safely
land without injury or damage.

 The r adio frequencies used for operations and control of the RE

- UAS comply with the
Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for RE

- UASs are 2.4 GHz.

If the same operations were conducted using a helicopter, the aircraft's take

- off weight would likely exceed

6,000 pounds carrying a pilot, camera operator and VO

- visual observer

- navigator. The difference in

weight between RE

- UASs and a helicopter significantly redu ces the potential harm to the participating and

non

- participating individuals or property in the event of an accident or incident. In addition, the risk to the

onboard pilot and camera operator is eliminated.

2 See e.g ., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, Corp.

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); Grant of Exemption

to Heli net Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156).U.S. Department of Transportation Aug 18 th

, 2015 Page 7

B. Approval is Warranted Based on the Operational Restrictions Set Forth in Showcase’s Operations Manuals

Showcase’s Operations Manuals and the Manufacturer's Manual for the selected RE

- UASs will

contain all the procedures and limitations necessary to safely and successfully perform the operations

specified in this Petition for Exemption. To assist the FAA in making a safety assess ment of Showcase’s

proposed operations, below is a summary of operational limitations and conditions that Showcase will

adhere to, and which will ensure an equivalent or higher level of safety to operations conducted under

current regulatory guidelines:

1. The RE

- UAS weighs less than 55 pounds, fully loaded.

2. All operations shall 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 operation.

3. All RE

- UASs operated under the Grant of Exemption will be identified by serial number,

registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in

accordance with

14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot

- in Command

("PIC") of the RE

- UAS, and one or more Visual Observers ("Observer") as necessary to safely

conduct the mission.

5. PICs shall possess at least a Sport Pilot's Certificate and current Class III Medical Certificate.

The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in

which the PIC i s rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

issued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the Showcase’s Operations Manuals.U.S. Department of Transportation Aug 18 th

, 2015 Page 8

The Operations Manuals will be maintained and made available to the Administrator upon request. If

a discrepancy exists between the conditions and limitations in the Grant of Exemption and

Showcase’s Operations Manuals, the conditions and limitations in the Grant of Exemption shall take

precedence and must be followed. Otherwise, Showcase shall follow the procedures outlined in their

Operations Manuals.

10. Showcase may update or revise its Operations Manuals. Revisions will be tracked and a revised

copy of the Manual will be provided to the Administrator upon request. Showcase will also present an updated and revised Operations Manuals if it petitions for extension or amendment to its Grant of

Exemption. If an update or revision would affect the basis upon which the FAA grants the exemption,
Showcase will seek an amendment to its Grant of Exemption. Showcase will contact the FAA’s RE

UAS Integration Office (AFS

- 80) if questions arise regarding updates or revisions to the operating

documents.

11. Showcase’s Operations Manuals and its Grant of Exemption will be available to the PIC at the ground control station anytime the RE

- UAS is operating.

12. The PIC is prohibited from beginning a RE

- UAS flight unless (considering wind and forecast

weather conditions) there is enough power to fly to the first intended point of landing, and assuming

normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the RE

- UAS will be limited to 40

minutes or the amount of time the RE

- UAS can be flown and still maintain a reserve battery power of

no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter
navigable controlled airspace without prior written authorization and approval from the FAA. In the

event the structure being inspected exceeds 400 feet AGL, the RE

- UAS will not be operated mor e than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the

structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons

other than the PIC, VO, operator trainees or essential personnel), 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. The operator must 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;U.S. Department of Transportation Aug 18 th

, 2015 Page 9

b) The aircraft is operated near vessels, vehi cles 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).

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than three statute miles from the PIC.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current

FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is

obtained, and the operation is conducted in accordance with a NOTAM as required by the

Showcase COA. The letter of agreement with the airport management will be made available to
the Administrator upon request.

18. Prior to each flight the PIC shall inspect the RE

- UAS to confirm that it is in a condition safe

for flight. The pre

- flight inspection will account for all discrepancies, e.g. inoperable components,
items, or equipment, not already covered in the relevant sections of the operating documents. The

PIC shall not operate the RE

- UAS if the inspection reveals a condition that affects the safe

operation of the RE

- UAS until the necessary maintenance has been performed and the RE

- UAS is

found to be in a condition for safe flight. The ground control station shall be incl uded in the

preflight inspection. All maintenance and alternations must be properly documented in the RE

- UAS
records as required by Showcase’s Operations Manuals.

19. Showcase will carry out its maintenance, inspections, and record keeping requirements in

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in

the RE

- UAS records, including total time in service, description of work accomplished, and the

signature of the authorized person returning the RE

- UAS to service.

20. Any RE

- UAS that has undergone maintenance or alterations that affect the RE

- UAS

operation or flight characteristics ( e.g
., replacement of a flight critical component) must undergo a functional test flight in accordance with Showcase’s Operations Manuals. The PIC who conducts

the functional test flight must make an entry in the RE

- UAS aircraft records of the flight. The

requirements and procedures for a functional test flight and RE

- UAS record entry shall be
included in the Showcase’s Operations Manuals.U.S. Department of Transportation Aug 18 th

, 2015 Page 10

21. The RE

- UAS will be operated and maintained according to the Manufacturer's Manuals and

any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements
on Showcase’s Operations Manuals.

23. Showcase will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude

level and potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the RE

- UAS loses communication with the pilot, it will have the capability to return to a

pre

- determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the Observer.

27. The RE

- UAS will have the capability to safely abort fligh t in the case of unpredicted

obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate or a valid state

driver’s license.

29. Prior to conducting flight operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time

as a RE

- UAS rotorcraft pilot and at least 10 hours logged as a RE

- UAS pilot with a similar RE

UAS type. This requirement can be achieved by flights conducted and logged as a hobbyist.

30. Prior to conducting flight operations

, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10

logged hours as UAS pilot ope rating the make and model of UAS to be utilized for operations

under the exemption and thirty take

- offs and thirty landing s in the preceding 90 days.U.S. Department of Transportation Aug 18 th

, 2015 Page 11

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under

Special Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasai ling activities, hang gliders, etc.).

33. All UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The All UAS will not be operated from an elevated platform or moving device / vehicle.

35. 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.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of

the Act, including RE

- UASs, from its safety regulations and minimum standards when the Administrator

decides a requested exemption is in the public interest. 3

Showcase seeks an exemption from several interrelated provisions of Title 14 of the Code of

Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested

operations using a RE

- UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is

sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. 4

3 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed
pursuant to Sections 44701(a) and (b) and Sections 44702

- 44716).

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would

provide a level of safety at that provided by the rule from which you seek exemption.U.S. Department of Transportation Aug 18 th

, 2015 Page 12

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the

Reform Act that the RE

- UAS selected provides an equivalent level of safety when compared to aircraft

normally used for the same application. These criteria are met, and therefore no exemption is needed. 5 If,

however, the FAA determines that there are some characteristics of the chos en RE

- UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Showcase’s use of the RE

- UAS is safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV (A), the RE

UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of

50 knots. RE

- UAS is also equipped with safety features that will allow Petitioner to opera te the RE

- UAS

safely after experience certain in

- flight contingencies or failures. 67

5 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at pgs. 13

- 14, 22).

6 See e.g ., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA

- 2014

- 0803 at pg. 3):

"The RE

- UAS have the capability to operate safely after experiencing certain in

- flight contingencies or

failures and uses an auto

- pilot system to maintain RE

- UAS stability and control. The RE

- UAS is also able

to respond to a loss of global positioning system (GPS) or a lost

- link event with a pre

- coordinated,

predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety

features provide an equivalent level of safety compared to a manned aircraft performing a similar

operation."

7 See e.g ., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA

- 2014

- 0382 at pgs. 4

- 5):

The RE

- UAS ’ s can be operated entirely by a touch

- screen, map

- based interface. This means the operator
only needs to command the sys tem where to go, and the system does all the flying for the operator. The

RE

- UAS can be operated in both semi and fully autonomous flight modes, with the operator simply

clicking on a map to create a pre

- planned flight path for a flight. In addition, the o perator can create no fly

zones or maximum flight ranges and altitudes so the system cannot

enter areas {footnote continued}U.S. Department of Transportation Aug 18 th

, 2015 Page 13

Additionally, the RE

- UASs carry neither pilots nor passengers, carry no explosive materials or flammable liquid fuels, and operate exclusively within the parameters stated in Showcase’s

Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the

operator and will be conducted in compliance with local public safety requirements, to provide security

for the area of operation. Showcase will also provide the FAA with advance notice of all operations via

NOTAMs as required by the applicable COA. In all cases, operation of the RE

- UAS under the

proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an

airworthiness certificate.

Lastly, the RE

- UASs do not need a means to communicate with other aircraft or ATC, because

those capabilities will be possessed by the PIC and Observer, who are not onboard the RE

- UAS. 8 In

addition, no sense

- and

- avoid technology is necessary for the RE

- UASs because they will be operated at

all times in VFR conditions and within VLOS of the PIC and Operator. 9

B. 14 C.F.R. Part 27 Airworthiness Stand ards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of
normal category rotorcraft. To the extent that Company's small UASs would otherwise require

certification under Part 27, Petitioner seeks an exemption from Part 27's a irwo r th i n e ss s t a nd a rds f or the

s a me r ea sons i d e n t ified in t he re qu e st f o r e x e mp t ion f

r om 14 C. F .R. P a rt 21, Subp a rt H, supra

.

{continued from previous page}

deemed unsafe or unnecessary to fly over. The petitioner states further that the RE

- UAS has built

- in
intelligent fault handling which allows the Phantom II and S1000+ to detect a system fault while in the air
and automatically fly back to its takeoff location and land. Faults that can be detected include: loss of
communication; exceeding pre

- set wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate.

At any point if the operator is not explicitly commanding the system to move, the system automatically

holds its GPS position. The flight control system employs not only GPS positioning but a variety of
sensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long

as wind thresholds are not exceeded. Also a flight termination link

– to prevent a 'fly away' or other
potentially dangerous situation

– is available to the operator.

8 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at pg. 13).

9 Id.U.S. Department of Transportation Aug 18 th

, 2015 Page 14

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification

Requirements

Showcase seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides

that:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit,

or pilot station, in letters not less than two inches nor more than six inches high, the words

"limited," "restricted," "light

- sport, "Experimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the

cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements
was warranted provided that the aircraft "have identification (N

- Number) markings in accordance

with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." 10

Equivalent Level of Safety

All UA flown by Showcase will bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11

________________________________________

10 FAA Docket No. FAA

- 2014

- 0352.

11 See, e.g., FAA Docket No. FAA

- 2014

- 0352, at 14.U.S. Department of Transportation Aug 18 th

, 2015 Page 15

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

Showcase seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a)

(stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart

E of this part and shall between required inspections

... have discrepancies repaired as prescribed in part 43

of this chapter"). An exemption from these regulations is needed because Part 43 and these sections only

apply to aircraft with an airworthiness certificate, which the RE

- UAS to be operated under this grant of

exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

p erformed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service

Bulletins. Further, as required by Showcase’s Operations Manuals, the PIC will conduct a pre

- flight

inspection of the RE

- UAS and all associated equipment to account for all discrepancies and/or inoperable

components. Maintenance will be performed and verified to address any conditions potentially affecting

safe operation of the RE

- UAS and no flights will occur unless, and until, all flight critical componen ts of

the RE

- UAS have been found to be airworthy and in a condition safe for operation. A functional test flight

will be conducted following the replacement of any flight

- critical components. As required by Showcase’s

Operations Manuals, the PIC who conduc ts the functional test flight will make an entry in the RE

- UAS

aircraft records of the flight.

Showcase’s Operations Manual also includes requirements to follow the manufacturer ’ s RE

- UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control

surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including

batteries), ground control station, hazard accessories, and spare parts. Further, Showcase’s Operations

Manuals also includes procedures to document and maintain a record of the RE

- UAS maintenance,

preventative maintenance, alterations, and stat us of replacement /overhaul component parts, and the total

time in service of the RE

- UASs used under this Grant of Exemption. As a whole, the maintenance and

inspection procedures required in Showcase’s Operations Manuals ensure that an equivalent or highe r level of safety will be achieved.U.S. Department of Transportation Aug 18 th

, 2015 Page 16

PILOT

- IN

- COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Showcase seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders

from flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC

will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for hire.

In this case, while the UASs will be operated as part of a commercial operation, it carries neither passengers

nor cargo.

In the Grant of Exemption to Astraeus Aerial 12

, the FAA determined that the unique characteristics of

RE

- UAS operation outside of controlled airspace did not warrant the addition cost and restrictions

attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate.

The fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot

would not lead to any add itional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The Showcase restrictions have placed on its RE

- UAS operations meet or exceed the restrictions

similarly imposed on Astraeus Aerial. Showcase will operate on private property away from persons and

property not involved in the operation. Showcase will also obtain an ATO issued COA prior to conducting

any operations under this Grant of Exemption. All operations will be conducted in accordance with

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements. A NOTAM will als o be issued as required by the applicable COA.

In addition to these flight restrictions, Showcase will further ensure safe operation by requiring that

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft

operators but also in the unique aspects of RE

- UAS flight. As set forth in the Operations Manuals, pilots

will have experience not only in RE

- UAS operations generally but have logged flight time in the specific

make and model used for the operations before they are permitted to participate in commercial flights on behalf of Showcase. The pilot qualification, training, and currency requirements in the Operations Manuals

ensure that Showcase pilots are competent and proficient in the RE

- UAS they are operating

. Showcase’s

training and qualification requirements are consistent with those contained in prior FAA Section 333

Grants of Exemption, and will provide a higher level of competency and proficiency for its pilots and will

ensure at least an equivalent level of safety.

12 Exemption No. 11062 (FAA Docket No. FAA

- 2014

- 0352).U.S. Department of Transportation Aug 18 th

, 2015 Page 17

OPERATING PARAMETERS OF THE RE

- UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the RE

- UASs, Showcase seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be
operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the

requirements of Part 21 are waived or found inapplicable. 13 Accordingly, Petitioner requests that the
requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. 03(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

... (2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual

material, markings, and placards, or any combination thereof.

Pu rsuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin

or cockpit entrance so that it is legible to passengers or crew.

13 See id. at 13

- 14, 22U.S. Department of Transportation Aug 18 th

, 2015 Page 18

Given the small size and configuration of the RE

- UASs, it would be impossible to keep

airworthiness documents and other aircraft manuals on board the RE

- UAS because there is simply no room

and the RE

- UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E.
Griffith, Attorney, AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and

(b) is met if the pilot of the unmanne d aircraft has access to the RE

- UAS flight manual, registration
certificate, and other required documents from the ground control station from which he or she is operating

the aircraft. 14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the
pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be
achieved by ensuring that the pilot has access to the documents at the ground control station from which he

or she is pilotin g the RE

- UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Showcase seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar

with specific information before each flight, including information contained in the FAA

- approved Flight

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA

- approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Showcase’s Operations Manuals

and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or inoperable components in accordance with the Showcase’s Operations Manuals, including

checklists covering Pre

- Flight, Launch, Landing, and Post

- Flight procedures. The PIC will also be required

to review weather, flight requirements, battery charge, landing and takeoff distance, UA performance data,

a nd contingency landing areas

— before initiation of flight. Showcase’s Operations Manuals and the

Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all

times while operating the RE

- UAS.

I. 14 C.F.R. § 91.109( a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and
Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA

2014

- 0352 at 16

- 18.U.S. Department of Transportation Aug 18 th

, 2015 Page 19

Showcase seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that

"[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight

instruction unless that aircraft has fully functioning du al controls." RE

- UASs and remotely piloted aircraft,

by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a device that communicates with the aircraft via radio communications. Accordingly, an ex emption will

be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the RE

- UASs that Showcase intends to use, an equivalent level of safe

training can still be performed without dual controls because no pilot or passengers are aboard the RE

UAS, and as required by the Showcase’s Operations Manuals, all persons will be a safe distance away in

the event that the RE

- UAS experiences any difficulties during flight instruction. Moreover, as required by

the Showcase’s Operations Manuals, all flight training will be conducted in controlled and sterile

environment. As a whole, the safety procedures provided for in Showcase’s Operations Manuals ensure that the proposed RE

- UAS operat ions provide an equivalent or higher level of safety than that provided by

the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Showcase requests an exemption from the minimum safe altitude requirements of 14 C.F.R. §

91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate,
including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less

than those minimum altitudes when it can be operated "without hazard to persons or property on the

surface," provided that "each person operating the helicopter complies with any routes or altitudes

specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed RE

- UAS operations will normally need to occur below 400 feet AGL. In circumstances where the RE

- UAS is used to inspect a structure whose height

exceeds 400 feet AGL, the RE

- UAS will not be operated more than 100 feet above the highest point on the structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or Observers(s) may need to be l ess than 500 feet away from the RE

- UAS.

15 Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's
proposed RE

- UAS operations will not occur over congested areas, and therefore an exemption from §
91.119(b) will not be necessary. See e.g ., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a tree Aerial (FAA

- 2014

- 0534 at 15).U.S. Department of Transportation

Aug 9 th

, 2015
Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights

proposed herein, and given the lack of flammable fuel with the RE

- UASs, any risk associated with

these operations is far less than those that presently exist with conventional aircraft. An equivalent

level of safety will be achieved given the size, weight, and speed of the RE

- UASs, as well the

controlled location where the operations will occur. In order to avoid any risk to manned aircraft,

flight operations will be restricted to 400 feet AGL or below, or when inspecting a structure whose

height exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet

horizontally of the structure.

As set forth in the Operations Manuals, the RE

- UASs will be operated in a restricted area, and all

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless

that person is in a position where he or she is shielded from the RE

- UAS and any possible debris resulting

from RE

- UAS failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet of the RE

- UAS leaves a shielded position. Further, RE

- UAS

operat ions will occur at least 500 feet away from vehicles or structures unless the property owner /controller has granted permission and the PIC has made a safety assessment of the risk of operating
closer to those objects and, operations near the PIC or Observ er will not present an undue hazard per §

91.119(a). Adherence to these restrictions in Showcase’s Operations Manuals will ensure operations can be conducted without compromising safety. 16

K. 14 C.F.R. § 91.121: Altimeter Settings

Showcase seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the

departure airport or barometric pressure An exemption is required to the e xtent that the RE

- UASs do not

have a barometric altimeter, but rather a GPS altitude read out.

16 See e.g. , Grant of Exemption No. 11138 to Douglas Trudeau (FAA

- 2014

- 0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such

protection. The operator must also 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. When considering how to immediately cease operations, the

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations

may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any

such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety

assessment of the risk of operating closer to those objects and determines that it does not present an undue

hazard.U.S. Department of Transportation

Aug 9 th

, 2015
Page 21

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121

can be achieved in circumstances where: (1) the RE

- UASs will be operated below 400 feet AGL or

below 17 , (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground

- based on

- screen display and, (4) where prior to each flight, a zero altitude initiation point is

established for the PIC to confirm accuracy of the onboard GPS. 18

The RE

- UASs that Showcase intends to use for the proposed operati ons will meet all these

operational characteristics. Moreover, as required by Showcase’s Operations Manuals, the PIC will be

required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section

333 Grants of Exemption, th e RE

- UASs Showcase to use, and the safety mitigation procedures contained

in the Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of

Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Showcase requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR con ditions unless (considering wind

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing

and, assuming normal cruising speed

–

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on RE

- UAS battery power means that no meaningful flight

operations can be conducted while still maintaining a 30

- minute battery reserve. An exemption from the

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17 If the height of the structure being inspected exceeds 400 feet AGL, the RE

- UAS will not be operated
more than 100 feet above the highest point on the structure.

18 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA

- 2014

- 0352 at 21).U.S. Department of Transportation

Aug 9 th

, 2015
Page 22

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by
prohibiting the PIC from beginning a RE

- UAS flight unless (considering wind and forecast weather
conditions) there was enough power to fly to the first intended point of landing and, assuming normal
cruising speed, to fly after that for at leas t 10 minutes. In reaching this conclusion, the FAA considered that

the RE

- UAS batteries for the RE

- UAS provided provide approximately 20 minutes of powered flight (with

payload) and provided battery level and battery time remaining in minutes and seconds t o the PIC. 19 The

FAA also considered the fact that the RE

- UAS operating manual states: “s tart every flight with a fully
charged battery in the aerial vehic le”, and that in the event that the RE

- UAS should run low on power, the

PIC will be alerted and can land the RE

- UAS as soon as possible. Like the VDOS Grant of Exemption,

Showcase’s use of the RE

- UAS, combined with the requirements of Petitioner's Operations Manuals,
ensure that an equivalent level of safety can be achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by

prohibiting the PIC from beginning a flight with the RE

- UAS unless (considering wind and forecast

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point

and land the UA with 25% battery power remaining. Showcase will adhere to this limitation for RE

- UAS

flights.

The RE

- UAS includes a low battery warning system and the amount of battery reserve power remaining is transmitted to the PIC via telemetric data feed, which downlinks from the RE

- UAS to a ground

- based

- on

- screen display. 20 As required by Showcas e’ s Operations Manuals, the PIC will promptly
fly the RE

- UAS back to the home launch location or pre

- determined abort location where the RE

- UAS
may safely land, while still maintaining a minimum of 25% reserve battery power. Showcase submits that
the procedu res requiring flights to be safely terminated once the batteries fall below 25% capacity,
combined with the requirement that flights only be conducted within a secure, isolated area, using a RE

UAS weighting less than 55 pounds, and within VLOS of the PIC and Observer(s), ensure that the
proposed operation will provide an equivalent or higher level of safety to that provided by the regulations

from which exemption is sought.

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA

- 2014

- 0382 at 10).

20 The RE

- UAS ground control station displays, the RE

- UASs position, navigation route, tail number,
altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and orientation relative to the RE

- UAS.U.S. Department of Transportation

Aug 9 th

, 2015
Page 23

VI. DRUG AND ALCOHOL PROGRAM

Showcase will have policies in place to ensure that no person may participate in RE

- UAS flight

operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

The public interest will be served by granting Showcase’s Petition for Exemption. Congress has

established a national policy that favors early integration of RE

- UAS into the NAS in controlled, safe

working environments such as those proposed in this Petiti on. Granting this Petition for Exemption helps

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act

— the FAA Administrator's

assessment of whether certain RE

- UAS may operate safely in the NAS before completion of the statutorily

re quired rulemaking.

The proposed RE

- UAS operations in this Petition for Exemption significantly improve safety and

reduce risk harm or serious injury to inspecting engineers. Traditional methods of real estate video

production and inspection of structures, expose videographer

- inspectors to higher risks of serious injuries,

or death. Videographer

- inspectors need to climb roof tops or otherwise perform elevated work, which

exposes them to the risk of dangerous falls, electrocution or other work related extreme s. In addition,

depending on the nature of the video needed and inspection, proximity to equipment, and other mechanical

hazards associated with industrial sites and construction facilities often involves a risk of exposure to

hazardous. The use of RE

- UASs mitigates these hazards and is ultimately a much safer method of

performing these and most other types of inspections.

The use of small RE

- UASs also enhances safety and reduces risk because, unlike manned aircraft
weighing thousands of pounds, carrying crew in addition to flammable fuel, the RE

- UASs carry no passengers or crew. Further, in the unlikely event of an accident, Showcase small battery powered RE

UASs presents significantly less danger to persons on the ground when compared to operations by

c onventional manned aircraft. 21 As Petitioner's RE

- UASs are battery powered, the public will also benefit
from a reduction in harmful emissions associated with conventional aircraft performing in the same functions proposed herein.

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA

- 2014

- 0783 at 12): Manned helicopters conducting aerial videography can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner ’ s UAs wil l weigh less than 55 pounds

with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or

property in the event of an incident or accident. The risk to an onboard pilot and crew during an incident or

accident is eliminated with the use of a UA S for the aerial f light operation s ."U.S. Department of Transportation

Aug 9 th

, 2015
Page 24

Lastly, as recognized by the FAA in prior Section 333 Grants of Exe mption to videographers, RE

- UASs provide an additional tool for the real estate industry, adding a greater degree of flexibility, which

supplements the current capabilities offered by manned aircraft. 22

VIII. PRIVACY

All Showcase’s RE

- UAS operations will be conducted in accordance with applicable federal,

state, or local laws regarding privacy. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission fr om land owner/controller or authorized representative will be obtained for each flight to be conducted.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL

REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a);

91.119 (c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a)

& (b).

The exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent real estate aerial photography and

inspection with conventional fixed

- wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

Showcase’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act
of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation

within VLOS and national security. The proposed RE

- UAS operations will benefit the public as a whole by

improving safety and reducing risk by alleviating human exposure to danger. In consideration of the

foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting

the requested exempt ions allowing Showcase use its RE

- UASs for providing aerial photography

videography and mapping for the real estate industry, as well as property inspections, and 3D compositing.

22 See e.g ., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA

- 2014

- 0794 at 18).U.S. Department of Transportation

Aug 9 th

, 2015
Page 25

We thank you for your prompt consideration of our requested exemptions.

Respectfully Submitted,

Jay Letendre

Real Estate Showcase, Inc.

17568 Homewood Rd.

Fort Myers, FL 33967

Should you have any questions, or if you need any additional information to support the requested exemptions, please contact the undersigned at:

Real Estate Showcase, Inc.

Phone: 239.287.8927

Email: Jay@trebfl.com

(The following attached items contain and commerc ial information exempt from disclosure under the
Freedom of Information Act, 5 U.S.C. § 522 et seq. , and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

Attachments:

1. General Operations Manual

2. PIC Operating Manual

3. Showcase Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. Maintenance Manuals