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AprilS, 2015 

FAA 

Docket Management Facility 

U.S. Department of Transportation 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

NAME AND ADDRESS OF PETITIONER 

Above Orange County 

Attn: Michael Hull 

21580 Yorba Linda Blvd. 

Yorba Linda, CA 92887 

714.906.0761 

aboveorangecounty@gmail.com 

www.aboveorangecounty.com 
Dear Exemption Manager, 

This application is being submitted on our own behalf without legal counseling or 

consulting services. 

Above Orange County is writing pursuant to 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 Federal Aviation Regulations (FARs) listed 

below so that Above Orange County may operate its small unmanned aircraft I 

lightweight unmanned aircraft systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA). 

About Above Orange County: 

Above Orange County has established itself as a leader in capturing high definition 

residential real estate aerial photography and videography with small, unmanned 

aircrafts. Above Orange County has proven it's ability time 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 1 0+ years of real estate expertise and unique 

vision, Above Orange County is able to bring this rare opportunity to our client's 

doorstep. Above Orange County's motto is, "Technology is advancing the way we view 

the world today, so why not utilize these great discoveries to further the real estate 

threshold." 

The services Above Orange County offers help our clients listings sell both faster and 

for above average price. Through the use of aerial photography Above Orange County 

allows agents and potential buyers to view listings like never before. As a part of a new 

company aspect, a Virtual Interior Walkthrough connects the viewer with the home on a 

deeper, more significant level. 

Our goal is to evoke emotion through our photography and videography. A picture says 

a thousand words, but unique professional grade photography and videography sells 

significantly higher and faster. 

To date, Above Orange County has flown 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 incident and would like to formally request permission to fly commercially in the 

United States to capture aerial real estate photography and videography. 
Above Orange County 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, 91.1 09(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 left out any other relevant section for our intended operations, please feel free to 

suggest the missing section(s). 

Flight Operations: 

Above Orange County does not fly above 400 feet 

Above Orange County does not fly within 5 miles of an airport 

Above Orange County strictly flies above the client's house and/or property 

Above Orange County always gets permission from neighboring homes and/or 

association roads via a signed contract 

Above Orange County always flies with an operator on site as well as a spotter on site 

Above Orange County's exemption request would 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 uses the H3-3D Zenmuse Gimbal, and 

the Z15-5D3 Zenmuse Gimbal. 

All the aircrafts Above Orange County uses and listed above operates electronically, 

carries no flammable fuel, has an integrated GPS pilot system, provides location 

information along with height AGL, speed, battery life,and provides direction of travel 

and distance from 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 

GPS failure, the craft is able to be manually flown back to the pilot/operator. 

Preflight and post-flight checklists and examinations will help detect any abnormalities 

prior to flight and after flight. Any UAS unable to satisfy safety checklists will be removed 

from service until the issue can be resolved. Granting this request would 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 interest to 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 
'safety first' when it comes to flight operations. 

Section 333 Compliance and Appropriateness: 

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Based on the size of the craft, experience of the 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 

safe flight operations forward in accordance with the intent of Section 333. 

Ongoing Efforts: 

For the reasons stated in our attached petition, Above Orange County respectfully 

requests the grant of an exemption allowing Above Orange County to operate 

lightweight, remote controlled UAS's within the national airspace system and would like 

to work with the FAA to develop rules and guidelines that can be utilized for similar 

commercial uses going forward. 

Thank you. 

Respectfully submitted, 

Michael Hull 

Owner/Operator 

Above Orange County 

21580 Yorba Linda Blvd. 

Yorba Linda, CA 92887 

714.906.0761 

aboveorangecounty@gmail.com 

www. aboveorangecounty.com