Nizar M Kailani

Real Estate Broker

CA Bureau of Real Estate License no. 1272588 1280 North Arroyo Boulevard Pasadena, CA 91103 (626) 437‐7876 Nizar.remax@gmail.com

TO WHOM IT MAY CONCERN

This petition is being submitted on my behalf without legal cou nsel or consulting services.

Pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (the Refor m Act), and 14 C.F.R. Part 11, Nizar M Kailani, a Real Estate Broker CA Bureau of Real Estate License no. 1272588, hereby applies for an exemption from the Federal Aviation Regul ations (FARs) listed below to allow operation of our Small Unmanned Ai rcraft System (sUAS) commerci ally in airspace regulated by the Federal Aviation Administration (FAA) so long as such operation s are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Nizar M Kailani to pursue his commercial interests in providing services to clients using a sma ll advanced sUAV in the followin g areas:  Real Estate, Marketing, Land Management/Surveying.  I, Nizar M Kailani hereby states that al l sUAS flights will occur over private or controlled access property and will do so with the property own er's consent and knowledge and that only people who have consented o r otherwise have agreed to be w ithin the UAS’ radius during filming and/or photography applications.

I am able to safely and effectively fly the sUAS DJI Phantom 3 which will be used for all commercial and private purposes.  I shall also comply with local ordinances an d laws regarding the operation of sUAS, and adheres to all weather and en vironmental restrictions or li mitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local law s regarding privacy.I, Nizar M Kailani, am seeking th e exemption because I am commi tted to complying with all of the rules, guidelines, limitations, and future legislation set forth by th e FAA.  I agree to operate the sUAS in the manner that I have des cribed, and for the purposes that I have described.  Without the exemption request granted, I would be unabl e to safely and effectively ru n my business, and it is my intention to comply with the FAA and obtain a n exemption of the following re gulations.

The following contains my list of regulations from which I am s eeking exemption, and a complete list of responsibilities I assume as oper ator; it also contains informa tion regarding the aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which ex emption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 ‐ 91.417

I, NIZAR KAILANI, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBI LITIES 1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds including payl oad. Proposed operations of a ny other aircraft will require a new petition or a petition to amend this exemption.2. Operations for the purpose of closed‐set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (10 0 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to det ermine compliance with the 87 knot speed restriction. In no case w ill the UA be operated at airspe eds greater than the maximum UA operating airspeed recommended b y the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 f eet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) o f the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA‐issued airman medical certificate or U.S. driver’s li cense. 6. All operations must utilize a visual observer (VO). The UA m ust be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC mus t be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her des ignation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS a nd conduct its operations in accordance with the conditions a nd limitations stated in this g rant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrat or upon request . If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedur es outlined in the op erating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as ou tlined in its operating documen ts. The operator mayupdate or revise its operating document s. It is the operato r’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforceme nt official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must pe tition for an amendment to its grant of exemption. The FAA’s UAS Inte gration Office (AFS−80) may be contacted if quesƟons arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone ma intenance or alterations that a ffect the UAS operation or flight characteristics, e.g., replaceme nt of a flight critical compone nt, must undergo a functional test flight prior to conducting further oper ations under this exemption. Fu nctional test flights may only be conducted by a PIC with a VO and must remai n at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible f or maintaining and inspecting t he UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PI C must conduct a pre‐flight ins pection and determine the UAS is in a condition for safe flight. The pre‐flight inspection must accou nt for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection r eveals a condition that affects the safeoperation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is fo und to be in a condition for sa fe flight. 11. The operator must follow the UAS manufacturer’s maintenance , overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft compo nents. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption , a PIC must hol d either an ai rline transport, commercial, private, recreational, or sport pilot cert ificate. The PIC must also hol d a current FAA airman m edical certificate or a valid U.S. driver’s license issu ed by a state, the District o f Columbia, Puerto Ri co, a territory, a possession, or the Federal gover nment. The PIC must also meet t he flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on h is or her pilot certificate. 5 14. The operator may not permit a ny PIC to operate unless the P IC demonstrates the ability to safely operate the UAS in a manner cons istent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appro priate distances from persons, vessels, vehicles and structures. PIC qualification flight hour s and currency must be logged in a manner consistent with 14 CFR § 61.51(b) . Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience‐building) and determinin g the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated un der this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience‐building flights, all persons not essential for flight operations are considered n onparticipants, and the PIC must operate the UA with appropriate distance from nonpart icipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as define d in 14 CFR § 1.1. A ll operations must be conducted under visual meteor ological conditions (VMC). Flig hts under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airpor t reference point (ARP ) as denoted in the current FAA Airport/Facility Direc tory (AFD) or for airports no t denoted with an ARP, the center of the airport symbol as denoted on the current FAA‐published aeronaut ical chart, unless a letter of agreement with that airport’s management i s obtained or otherwise permitt ed by a COA issued to the exemption holder. The letter of agreement with the airport management mus t be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet hor izontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communicatio ns or loses its GPS signal, th e UA must return to a pre‐determined location within the private or controlled‐access property. 19. The PIC must abort the flight in the event of unpredicted o bstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (consi dering wind and forecast weather conditions) there is enough availa ble power for the UA to condu ct the intended operation and to operate after that for at least five minutes or with the reserv e power recommended by the manufacturer if greater.21. Air Traffic Organization (ATO) Certificate of Waiver or Aut horization (COA). All operations shall be conducted in accordance with an ATO‐issued COA. The exemption h older may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 6 22. All aircraft operated in accordance with this exemption mus t be identified by serial number, registered in accordance with 14 CFR part 47, and have identifi cation (N−Number) markings in accordance with 14 CFR part 45, S ubpart C. Markings must be as large as practicable. 23. Documents used by the operato r to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be avai lable to the PIC at the Ground Control Station of the UAS any t ime the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon reque st.

24. The UA must remain clear a nd give way to all manned aviatio n operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving devi ce or vehicle. 26. All Flight operations must b e conducted at least 500 feet f rom all nonparticipating persons, 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 protecti on. If a situation arises where nonparticipating persons leave suc h protection and are within 5 00 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonpartici pating persons; and b. The owner/controller of any vessels, vehicles or structures has gra nted permission for operating closer to those objects and the PIC has ma de a safety assessment of the r isk of operating closer to those objects and determined that it does not present an undue hazard. The PI C, VO, operator trainees or essential persons are not considered nonpa rticipating persons under this exemption. 27. All operations shall be condu cted over private or controlle d‐access property with permission from the property owner/controller or authorized representative. Per mission from property owner/controller or authorized representative w ill be obtained for each flight t o be conducted. 28. Any incident, accident, or flight operation that transgress es the lateral or vertical boundaries of the operational area as defined by the applicable COA must be repor ted to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the NaƟ onal TransportaƟon Safety Board (NTSB) per instructions containe d on the NTSB We b site: www.nts b.gov.

SIMILAR EXEMPTIONSThey are similar in all/or many material respects to relief pre viously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs ar e often seen as superior to he licopters as an aeri al video gathering platform due to the smaller devices cheaper equipment and perso nnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safet y. Nizar M Kailani is petitioning fo r an exemption t o operate a DJ I Phantom 3 with a built‐in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no‐fly zone fe ature.

The DJI Phantom 3 also has a fa ilsafe function that is triggere d in the event communication is lost between the sUAS and the main controller transmitter. At that t ime, the sUAS will return to its point of takeoff and land safety. If the c onnection is restored, the PIC can regain control of flight and land manually.

These specifications meet with th e Model Aircraft Operating Sta ndards as set below:

The petitioner will only operate its sUAS in line‐of‐sight of a pilot and/or observer and will operate at sites that are `sufficient distan ce' from populated areas withi n the sterile area described in the FOPM. Such operations will ensure that the sUAS will "not create a ha zard to users of the national airspace system or the public." When flying the sUAS within three (3) miles of an airport, air port operators will be notified and the operator will give the right‐of‐wa y to avoid flying in the prox imity of full‐scale aircraft. Maximum flight time for each operation will be 30 minutes. Flights will be terminated when battery levels reach 25%, allo wing sufficient reserve flight time to safely land the sUAS. The sUAS will be programmed so it will not be operated at an a ltitude that exceed s 400 feet AGL, and not more than 200 feet above an el evated platform from which vi deography is planned. Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

The sUAS PIC will be an FAA licen sed airman holding a minimum of a Private Pilot certificate and a current FAA medical certificate.The sUAS operated by the petitioner weighs less than 25 pounds , including all payload (i.e. camera, lens, and stabilized gimbal). The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally.

Given the small size of the sUAS and the restricted sterile en vironment within which it will operate, SkyVideoCT’s operations adhere t o the Reform Act's safety requi rements.