February 2, 2016 REELTOUR LLC Richard Skolrood, Owner/Manager 13205 Gulf Blvd. Madeira Beach, FL 33708 Phone: (727) 482-2985 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23{b}; 14 CFR 61.113{a} and (b); 14CFR 91.7(a}; 14 CFR 91.9{b}{2}; 14 CFR 91.103; 14 CFR 91.119; 14CFR 91.121; 14 CFR 91.151{a}; 14CFR 91.203 {a} and {b); 14 CFR 91.405 (a}; 14 CFR 91.407 {a} {1} 14 CFR 91.409 {a} {2}; 14CFR 91.417{a} and {b) To Whom it May Concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, Richard Skolrood, owner/manager of REELTOUR LLC and operator of Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of UAS, so long as such operations are conducted within and underthose conditions outlined herein or as may be established by the FAA as required by Section 333. 

### Description of Requested Operations Commercial operation of UAS, as described herein, which are equipped with camera and sensors, would operate in the following manner:
• Aerial photography/video capture for public and private use ofsubjects that include architecture, real estate, engineering and other related activities. ·Aerial photography/video capture for public and private events including news gatheringwhere local permission is granted.

• Aerial photography/video capture including inspection of commercial utility infrastructure and construction sites.

• Aerial photography/video for land surveying and agriculture monitoring. • Disaster response to aid firefighters, police, and EMTs onlywhen requested. 

### Petitioner requests relieffrom the following: 14 CFR Part 21 subpart H 14 CFR 45

.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

### Description of UASs to Be Used: UAS 1: Craft Name: YUNEEC Typhoon Q500 4K

• Weight: 1700g (3.751bs

.) • Dimensions: 565mm x 330mm (22.2in x 13.0in) • Maximum Speed : 17mph

## I 27 kph (Angle Mode), 22mph 

## I 35 kph (Follow Me/Watch Me) • Maximum Ascent Speed: 11.18mph (5 m/s) • Maximum Descent Speed: 2m/s • Propulsion: Four(4) Motors • Power: 5400mAh 3S 11.1V LiPo • Controlling Mechanism :type; ST10+; Android operating system; remote controller with an Video Link Frequency Band 5.8GHz; Control Transmission Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft). Additionally, the UAS has further stability controls through the use ofGPS guidance. In the event of loss ofGPS, full manual control can be quickly obtained. • Maximum Range: 1.2 miles

.The applicant will operate UAS within Line ofSight (LOS) within a closed area as predetermined by the property owner/representative at all times. • Camera:4k Camera attached to 3-axis gimbal 

### UAS 2: Craft Name: DJI Phantom 3 Professional

• Weight: 1280g (21bs 13oz) • Dimensions: 40.36cm x 19.05cm (16in x 7.5in) • Maximum Speed: 35mph {16 m/s) • Maximum Ascent Speed: 11

.18mph (5 m/s) • Maximum Descent Speed: 6.71mph (3 m/s) • Propulsion: Four(4) Motors, (Model DJI 3510) • Power: 4480mAh 4s LiPo Lithium Polymer Battery • Controlling Mechanism: C3 remote controller with an operating frequency of2.400GHz2.483GHz. Additionally, the UAS has further stability controls through the use ofGPS guidance. In the event of loss ofGPS, full manual control can be quickly obtained. • Maximum Range: 1.2 miles. The applicant will operate UAS within Line ofSight (LOS) within a closed area as predetermined by the property owner/representative at all times. • Camera: 4k Camera attached to 3-axis gimbal 

### UAS 3: Craft Name: 3D Robotics "Solo"

• Weight: 1500g (3.3 lbs) • Motor-to-Motor Dimensions: 26cm {18in) • Maximum Speed: 55mph • Cruise Speed: 5
.7mph • Maximum Climb Rate: 11mph • Maximum Descent Rate: 5
.5mph • Propulsion: Four(4) Motors, (Model DJI 3510) • Power: 5200 mAh 14.8 Vdc Lithium Polymer Battery • Controlling Mechanism: 3DR Solo Controller with an operating frequency of2.4GHz. Additionally, the UAS has further stability controls through the use ofGPS guidance. In the event of loss ofGPS, full manual control can be quickly obtained. • Maximum Range: 0

.5 miles. The applicant will operate UAS within Line ofSight (LOS) within a closed area as predetermined by the property owner/representative at all times. • Camera: GoPro Hero connected to 3-axis gimbal

### Public Benefit. Both UASs, given their size, stability, and manner of propulsion, are more safe to the general public than the operation offull-sized aircraft carrying flammable fuel. With the reduction ofenvironmental impact, noise, and safety hazards in the operations compared to full-sized aircraft, the grant ofthe requested exemption is of benefit to the general public as awhole. The proposed operations will adhere to the Reform Act's safety requirements


### REELTOUR LLC 

### I Richard Skolrood /Operatorwill only operate the UASs within the parameters set forth below:

• Operation within line ofsight. • Operation at sites that are sufficient distance from populated areas, which will not create a hazard to users ofthe National Airspace System (NAS) orthe general public. • When flying UASs within 5mi ofan airport, operatorwill notify airport operators. Operator will also give the right ofway to avoid flying in the proximity offull-scale aircraft. • Flights will be terminated at 25% battery powerto ensure enough powerfor UAS to land properly and safely. • The UAS will be programmed so that itwill not exceed an altitude of400ft above ground, will operate in FAA Class GAirspace, and will travel no furtherthan 1000 ft from operator
. • The UAS will not exceed speeds of35 mph. • All required permits will be obtained from state and local government priorto operation. • Operatorwill not operating UAS over open-air assemblies of people or moderately travelled roadways. 

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. with max payload, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area under permission

. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. The FAA will have advance notice ofall operations. These safety enhancements provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F

.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load.

### 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter " N" and the registration number is displayed on limited, restricted or light-sport category aircraft orexperimental 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 2 inches nor more than 6 inches high, the words "limited," "restricted,"

"lightsport," "experimental," or "provisional," as applicable

. Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have no entrance to a cabin, cockpit or pilot station on which the word "Experimental" can be placed

. Given the size ofthe UAS, two-inch lettering will be impossible. The word " Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45

.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 

### 14 C.F.R. § 61.113 (a) 

### and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation or hire

.An equivalent level ofsafety can be achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will equate to the safe operation ofthe UAS. 

### 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regu lation requires that no person may operate a civil aircraft unless it is in airworthy condition

.As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness

. Given the size ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety will be provided

. 

### 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91

.9 (b) (2) provides: No person may operate a U

.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis 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. The UAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual atthe ground control point where the pilot flying the UAS will have immediate access to it. 

### 14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.

### 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 feet above ground level, or not more than 200 feet above an elevated platform from which filming is planned, an exemption may be needed to allow such operations

.As set forth herein, the UAS will never operate at higherthan 400ft AGL with the exception that in circumstances where the UAS is used to survey or photograph astructure whose height exceeds 400ftAGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will, however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent
. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property ownerand participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs

. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraft that must comply with Section 91.119

. 

### 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

... to the elevation ofthe departure airport or an appropriate altimetersetting available before departure

." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 

### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions 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 afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes." The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151 , UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame forflight in daylight ortwilight VFR conditions is reasonable. Richard Skolrood, owner/manager of REELTOUR LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) wasintended to alleviate given the size and speed ofthe small UAS

.Additionally, limiting UAS flights to 10 minutes would greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 20 minutes or25% of battery power- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 

### 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: {a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.. . . {b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or aspecial flight authorization issued under §91.715 is displayed at the cabin orcockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no more than 55 lbs

. and is operated without an onboard pilot

.As such, there is no ability or place to carry certification and registration documents orto display them on the UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them; to the extent they are applicable to the UAS. 

### 14 C.F.R. §91.405 (a); 407(a)(1);409(a) (2); 417(a) &(b): Maintenance Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that this section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to the applicant

. Maintenance will be accomplished by the operatorthe flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry asmall payload and operate only in restricted areas for a limited period oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 400ft AGL. The operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed

. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety

. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order priorto initiating flight and perform required maintenance needed

. Conclusion Summary I, Richard Skolrood as owner/manager of REELTOUR LLC, respectfully request exemption under Section 333 to enable low-risk UAS operations forthe activities stated above, with respect to the privacy and the safety ofcitizens in the area ofoperations

.