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.**~** t ''-:'AprilS, 2015

FAA Docket Management Facility U.S. Department ofTransportation West Building Ground Floor, Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590

Re: Exemption Request PursuantTo Section 333 ofthe FAA Reform Act of2012

NAMEANDADDRESS OF PETITIONER Above Orange County Attn: Michael Hull 21580 Yorba Linda Blvd. Yorba Linda, CA92887 714.906.0761 aboveorangecounty@gmail.com www.aboveorangecounty.comDear Exemption Manager, This application is being submitted on our own behalfwithout legal counseling or consulting services. Above Orange County is writing pursuantto the FAA Modernization and Reform Act of 2012 (the Reform Act) and the procedures contained in 14 C.

### F.R. 11, to request that Above Orange County be exempted from the FederalAviation Regulations (FARs) listed below so thatAbove Orange County mayoperate its small unmanned aircraft 

### I lightweight unmanned aircraftsystems (UAS) commercially in airspace regulated bythe FederalAviationAdministration (FAA). AboutAbove Orange County: Above Orange County has established itself as a leader in capturing high definition residential real estate aerial photography and videographywith small, unmanned aircrafts. Above Orange County has proven it's abilitytime and time again to capture high quality photography and videography safely in a variety of situations and locations. Above Orange County is an all in one stop shop for all real estate agents needs. Through owner/operator Michael Hull's 10+ years of real estate expertise and unique vision, Above Orange County is able to bring this rare opportunityto our client's doorstep. Above Orange County's motto is, "Technology is advancing the way we view the world today, so why not utilizethese greatdiscoveriesto furtherthe real estate threshold." The servicesAbove Orange County offers help ourclients listings sell both faster and for above average price. Through the use of aerial photographyAbove Orange County allows agents and potential buyers to view listings like never before. As a part of a new company aspect, a Virtual InteriorWalkthrough connects the viewerwith the home on a deeper, more significant level. Our goal is to evoke emotion through our photography and videography. A picture says athousand words, but unique professional grade photography and videography sells significantly higher and faster. To date, Above Orange County hasflown countless flights around Orange County and has done so safely and successfully. We take the skills and education for safe operations very seriously. Above Orange County has been operating consistently without incidentand would like to formally request permission to fly commercially in the United States to capture aerial real estate photography and videography.Above OrangeCounty is currently seeking exemption of: Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151 (a), 91.203(a) and (b), 91.319(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). If we have leftout any other relevant section for our intended operations, pleasefeel free to suggestthe missing section(s). Flight Operations: Above Orange Countydoes notfly above 400 feet Above Orange Countydoes notfly within 5 miles of an airport Above Orange Countystrictlyflies abovethe client's house and/or property Above Orange County always gets permission from neighboring homes and/or association roads via asigned contract Above Orange County always flies with an operator on site as well as a spotter on site Above Orange County's exemption requestwould permit its operation of lightweight, unmanned (piloted by remote control) DJI Inspire 1, DJI Phantom, DJI S-1 ,000, DJI F450, and DJI F550. Above Orange County also usesthe H3-3D Zenmuse Gimbal, and the Z15-5D3 Zenmuse Gimbal. All the aircraftsAbove Orange County uses and listed above operates electronically, carries no flammable fuel, has an integrated GPS pilot system, provides location information along with heightAGL, speed, battery life,and provides direction of travel and distancefrom pilot. In the event a loss of communication occurs, the craft has an automatic 'return to home'function and will return to the pilot/operator. In the case of a GPSfailure, the craft is able to be manuallyflown backto the pilot/operator. Preflight and post-flight checklists and examinationswill help detectany abnormalities priortoflight and afterflight. Any UAS unable to satisfy safety checklists will be removed from service until the issue can be resolved. Granting this requestwould not adversely affect safety since operations would be in accordance with current UAS rules. Suggested Public Federal Register Summary: Above Orange County is seeking an exemption to operate unmanned aircraft systems with a maximum weight of less than three pounds to perform aerial real estate photography and videography. Data gathered may include still and moving images captured with onboard cameras. This request specifically serves the public and economic interestto aide in the areas stated above. The granting of this exemption would make logical sense because of our professional approach to UAS operations, Above Orange County's clear understanding of FAA rules, Above Orange County's awareness of operational and restricted airspace, owner/operator Michael Hull's several years' experience, as well as our attitude of'safetyfirst'when it comes to flight operations. Section 333 Complianceand Appropriateness: 

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Based on the size of the craft, experience ofthe pilot, and Above Orange County's operational goals, this request appears to be well suited for approval using the criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 and will move safeflight operationsforward in accordance with the intentof Section 333. Ongoing Efforts: Forthe reasons stated in our attached petition, Above Orange County respectfully requests the grantof an exemption allowing Above Orange Countyto operate lightweight, remote controlled UAS'swithin the national airspace system and would like to workwith the FAAto develop rules and guidelinesthat can be utilized for similar commercial uses going forward.

Thankyou. Respectfully submitted,

Michael Hull Owner/Operator Above Orange County 21580 Yorba Linda Blvd. Yorba Linda, CA92887 714.906.0761 aboveorangecounty@gmail.com www.aboveorangecounty.com