# William F. McDonough

35888Center

Ridge Road, Unit Norrh Ridgeville,

OH 44039 Phone: (440) 327-tS4Z Email:'['g

q]{rtt nt \rl*w{ }hiei@uim ni }" cowl Attorney at Law, LLC

Facsimile: 440-327 -IS 42 Website:

wl,vw" elruneliiw.us October 22,2015 U. S. Department

ofTransportation Docket Management

System 1200 New Jersey Ave, SE Washington,

DC 20SgO Re: Exemption

Request Section333 of the FAA Reform Act of the Federal

Aviation Regufations

from 14 c.F.R.

a0.23(b);

14 c.F.R.

part21; 14 G.F.R.61.11g(a)&(b); 91.2(a); e1.e(b) (21; e1.103(b);

91.109; l1s.121; 91.1sl(a);

91.203(a)&(b);

91.405(a);

91.a07@l

(11; e1,409(a)

(21; 91.a1 z(a)&(b) Dear Sir or Madam Pursuant to Section

333 of the FAAModernization and Reform

Act of 2012

(the Reform Act)and 14 C.F.R.

Part 11, Myrealtor

Group, LLC("Myrealtor

Group"), is a professional

real estate firm, and hereby

applies for an exemption

from the listed

Fecleral Aviation Regulations ("FARs") to allow commercial

operation

of its Small

Unmanned

Aircraft Systems ("sLlASs")

for aerial photography

andvideography,

so long as such operations

are conctucted

within and under the conditions

outlined herein or as may be established by the FAAgs required by Section 333. As detailed

in this document

antj theattached

Manual, the requested

exemption

would permit the operation

of sUAS

under controlled

conditions

in airspace

thatis 1) limited

2) predetermined

3) controlled

as to access,

and 4) would

provide safety enhancements

to the already best practices

safety protocols

followed

by Myrealtor

Group at each oneof its aerial photography

sites. Approval

of this exemption

would thereby enhance safety and fulfill

the Secretary

of Transportation's

(the FAA Administrator's) responsibilities

to "...establish requirements

for the safe

operation

of such aircraft systems in the national

airspace system.,, Section 333(c) ofthe Reform

Act. The name and address ofthe applicant is: Myrealtor

Group, LLC Dakota D. Shannon,

President Realtor, Keller Williams Advantage 4417State

Route 725 Dayton, OH 45305 Office: 937-601-8827 Email: dakota@myrealtoroh.

com Website:

dakotasells.

com

Myrealtor Group, LLC, Dayton, Ohio 333 Exemption petitionMyrealtor Group is writing pursuant to the FAA modernization Reform Act of 2012 procedures

contained

with 14 C. At. Art. 11, to request that Myrealtor

Group, the ownerand operator

of a small unmanned aircraft, be exempted

from the Fecleral

Aviation Regulations ("FARS') listed above, so that it may operate its ultralight weight unmanned

aircraft system ("UAS') commercially,

in airspace

regulated

by the FederalAviation Administration

(,,FAA,;. As described

herein, the Petitioner,

Myrealtor

Group's President,

Dakota D. Shannon,

is a licensed

realtor and entrepreneurial,

operating

a real estate

firm that provicles

marketing

and consulting

services to individuals,

as wellas private

and public

entities. presi<jent

shannon

has completed

pilot ground school from Sinclair

Community

College and will be tested

in the near future (Copy SinclairCommunityCollege's Ground School Final Gradesare Attachedas Exhibit l)' Additionally, Mr. Shannon

is experienced

in flying hobby aircraft for recreational purposes. Myrealtor

Grouphas added

a DJI Phantom

3 Professional,

quadcopter

UAS,equipped with an integrated,

original equipment

manufacturer

(OEM) digital camera, to my inventory.

The intended

useof thisequipment

will be for aerial

videography/photography to enhance

academic and community

awareness

for those individual

entities and companies

unfamiliar

with the geographical

layout of the greater

Dayton, Ohio metropolitan

area. Moreover,

it will be used in real-estate

research,

analysis,

and for-sale

listing photographs

and videos;

thereby enhancing the academic

research

experience

for the greater

Dayton, Ohio metropolitan

area;following exemption

approval

by the FAA. This exemption

request would permit operation of the ultralight

weight, unmanned (piloted by remote control)

and comparatively

inexpensive,

UAS in controlled

and limited airspace.

Said flight would occurin predetermined areas away from the public,

airports, serial ports and vehicular

traffic, for community

photos and videos, andwithin

property boundaries,

for individual

property

owners, for videos/photos

used in real estate listings. Currenfly, similar lightweight'

remote-controlled

UAS's are legally

operated

by unmonitored

amateur

hobbyists with no safetyplan or controls in place to prevent

catastrophe,

The petitioner,

Myrealtor

Group, LLC, has personally

installed safety protocols

and controls

to avoid and prevent

public hazard, as well as manned

aircraft hazards/catastrophe.

Thiswill act to further

safety prrotocols

closer to lightweight

UAS's specific

to real estate

video and photography usage,as a record

flightdata and otherinformation

gained to permitted

flight operations

to share

withthe FAA through any required FAA reports

to assist withfuture

protocol and safety

regulation. Granting this request compofts with the Secretary of Transpoftation's (FAA Administrator's)

responsibilities

and authority

not only to integrate UAS's into the national airspace

system,but to "... Establish requirements

for the safe operation of such aircraft systems [UAS's] in the nationalairspacesystem" under section 333(c) of the Reform Act specific to the use of UAS'sfor real estate/realtor purposes

how to conduct

my operations

in compliance

withthe protocols

described

herein or as otherwise

established

by the FAA. For the reasons

stated below Myrealtor Group respectfully

requests

the grant for an exemption allowing them to operate ultra-lightweight, remote-controlled

UAS's academic community awareness to the benefits/stimulate attraction to the greater Dayton, Ohio metropolitan

area and to enhancereal estate research analysis and for sale listing

videos for property owners who cannot

afford us and said manned

aircraft are the same purpose. Both of

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption Petitionwhichwill promote localeconomic

growth through increased

employment

and increased

tax base' Both

the public

safety in mindby keeping

heavier manned aircraft containing

combustible fuelthat poses potential

public hazard. UAV/UAS/UA

G larification The UAV/UAS/UA

which Myrealtor

Group, LLC, will be operating

is the DJI phantom

3, Professional,

Quadcopter,

referred hereafter as Phantom. The inherent safety features, sophistication,

programmability,

GPS navigation,

returned

homecapability,

airporl vicinity no-fly feature, and restricted

altitude feature, as well as differentiating radio frequency

(r-f) for aircraft controller/receiver,

and for the camera,make this a much safer UAV for the purposes of this petition. This is a professional grade radio controlled UAV that has the capacity for software upgrades. lt is light,

less than 3 pounds

including

battery and camera. Incorporated into the programming

of this Phantom

is an automatic

return home feature thatautomatically

directs the craft back to the point of takeoff to communication

with the transmitter

be lost. The phantom has a cruising

speed of 15 knots,

with a maximum

speed of 29 knots. Maximum flighttimes

25 minutes.

Gross weight is2.82pounds. The Phantom

hasan additional

communication

link between the camera

andthe craft

on a different

RF for smart

phone connection.

Allowing

the operator

or pilot in command

(plC)to monitor battery level, altitude (AGL), distance

from PlC, camera

imagery,

and control

camera angle. The DJI Phantom 2 Vision

2.4 ghz transmitter/controller/receiver rf for managing

flight with a 5.8 ghz rf transmitter/receiver for video/photography functionseliminates

possible rf conflict. The software

for the Phantom

allows the operator

or PIC to set maximum altitude AGL for each flight, allowing customization

of flights

to no higher

than 100

feet, 150

feet, or 250 feet a GL as an example.The 400 foot maximum AGL can be programmed into the UAV's

software, preflight,

to ensure compliance with FAA standards,

adding to the safety capabilities of this UAV. This UAV is programed to remain

in position

when controls

are released,

maintaining altitude and GPS location. Fudher, the Phantom

has an altitude

and regular

monitoring

function that allows

the operator

moreprecise

determination

of height,

direction

of flight, and distance

from the operator or PICcan monitor

with a GPS lock

status while UAV is in flight,

with the ability

to anticipate

loss of GPS locking

so the operator

or Plc command

the UAVas a precaution. This is a professional grade radio controlled UAV that has the capacity for software upgrades. lt is light,

lessthan 3 pounds

including

battery and camera. Incorporated into the programming

of the Phantom

is an automatic

returnhomefeature

that automatically

directs the craft back

to the pointof takeoff

to communication

with the transmitter

be lost. The phantomis a cruising

speedof 15 knots,

with a maximum

speedof 29 knots. Maximum flight times25 minutes.

Gross weight is 2.86pounds. The Phantom

is an additional

communication

link between the camera

andthe craft

on a different. Radiofrequency for the smart phone connection. Allowing the oprerator

or pilot in command (PlC) to monitor batterylevel, altitude(AGL), and distance from PlC, camera imagery,

and control

camera angle.

Myrealtor Group, LLC, Dayton, Ohio 333 Exemption Petition

### In the Phantom Professional

Model the new feature is Failsafe

RTH which is activated automatically

should the remote

controller

signal is lost for more than three seconds. This function returns the aircraft

to the confirmed

Home Point. A complete

illustration

for this feature is located

on page 14of the Phantom

3 Professional

User Manual. (Gomplete

phantom

User Manual is Attached

as Exhibit

ll). The best

explanation

of the Phantom

sophistication

and capabilities

can be observed through a video explanation

of an earlier

model that wasthe predecessor

to the phantom

2 vision plus through link www.youtube.com/watc6?v=qajTB3g8TrU. The phantom

2 Vision plus maintained

all capabilities

defined in the video. Specific UAV/UAS/UA The particular

UAV/UAS/UA

which MyRealtor

Group will be operating

is the DJI Phantom 3 Professionar,

seriar Number p77DcE,l2o1013o. Settings

. height

limitations

set formaximum

of 300 feet AGL o radius

distance from controller set formaximum

of 1000 feet, both to aid indirect line of sight and visual observation. Current firmware upgrades for
o Main controller

. GPS

. Receiver

. Battery

. Zen IMU

As with several

other recently

accrued similarpetitions

at exemptions

including

that of Astraeus (FAA-2014-0352), referredhereafter

as the Astraeus Petition, and that of Douglas Trudeau

(FAA-2014-0481),

referred hereafter

as the Trudeau

Petition Myrealtor

Group, LLC has a number

of similarities,

distinctions,

and differences. As withTrudeau

Petition, Myrealtor

Group, LLC,is using

a UAVthat hadthe capability for taking

offand landing

in a single

point, identical to a helicopter.

There are no runways,

aided takeoffapparatuses,

nor routes

that need to be flown to areas being aerial video-recorded

or photographed,

allowing for a reduced

and more confined

areaof flight. The Astraeus

Petition is for movie

set involving

a significant

number of people,

aerial equipment,

movingor actionsequences, and a potentially

broad geographical

area where individuals

and equipment

may be in motion,requiring extensive

observation,

awareness, coordination,

and safety

precautions.

My petition

is similar

to theTrudeau

petition in that it is for video/photography

of stationary

objects requiring

briefer flights. For reporling

in tighly confined areas the stationary

setting of object

poses negatively

lowerrisk

for safety,

allowing the operator or pilot in command

(PlC)to focus primarily on stationary

objects for shorter

periods of time. With them,with the action scenes; associated

with the Astraeus

Petition, numerous

statesmay

Myrealtor Group, LLC, Dayton, Ohio

933 Exemption Petition

### requrre

flight. repeat

flights, where the stationary

object, within mostcases,

requires onlya single Similarly,

as in the Trudeau

Petition, Myrealtor

Group, LLc Will require

property owners, written consentfor aerial video/photography prior to flight. signs will be posted cautioning anyone within the vicinity

to remain

back a minimum

of 200 feet.

(Safety sign is attached

and marked as Exhibitlil) THE EXTENT

OF RELIEF

MYREALTOR

GROUP,

LLC SEEKS

AND THE REASON HE SEEKS

SUGH RELIEF: The Petitioner,

Myrealtor

Group,LLC, submits

this application

in accordance

with the Reform Act, 112 P 'L.95 SS

331-334,

seeking relief from any current

applicabte

FARs operating that wouldprevent

me, Myrealtor

Group, LLC, contemplated

commercial

cinematic,

academic, and other

flight operations

within the national

airspace

system. The Reform

Act in Section

332 provides

for such integration

of civil unmanned

aircraft systems into our national airspace system as it is in the public'sbest interest to do so. My ultra, light-weight UAS meets the definition

of "small

unmanned

aircraft" as defined

in section

331 andtherefore

the integration

of my ultra-lightweight

UAS is expressly

contemplated

by the Reform

Act. I would liketo operate my ultra-lightweight

UAS prior

to the time period

by which

the Reform

Act requires

fhs fA/M 1s promulgate

rules governing

such aircraft. Thereby, providing

direct experience

ancj valuable information

for formal regulation

that can be administered uniformly

to all real estate related UAS aerial

Videoand photography. The Reform

Act guides

the secretary

in determining

the types of UAS's that may operate safely in our national airspace

system. considerations include: The weight,

size, speed and overall

capabilities

of the UAS's;

whether the UAS

will be operated

near airports or heavily

populated

areas; and, whether the UAS

will be operated

in the line of sight' 112P.L'95$ 333 (a). Each of these items reflects in favor of an exemption

for the Petitioner,

Myrealtor

Group, LLC. My UAS utilizes four (4) counter-rotating propellers

for balance,

control, and stability. Further, my UAS is equipped

with Gps and ,,auto

return,, safety technology' Weighing less than three (3) pounds (far below

the Ss-pound

limit); including camera with gimba,. Furthermore

the Petitioner,

Myrealtor

Group, LLC, considers safety foremost

with each flight' My small,

unmanned

aircraft is designed

to hover

in place, via Gps, and operate in less thana 24-knot

(1smph) wind. Forsafety,

stability andfearof financial

loss, I willnot fly in winds exceeding

16 kph (10 mph). Built-in safety systems

include a GpS mode

thatallows

my UAS to hover in place when the radio controlsare released. I utilize this mode for aerial videography/photography. This is the safest, most reliable, and stable mode to prevent accidents

and reduce

hazards.

When pilot

communication

is lost the UAS is designed

to slowly descend

to the pointof take-off. The Petitioner has not, nor will, operate a UAS near airports, hospitals,

nor police

heliports,

and does not operate near areaswherethe general public is within fifty (50) to one hundred

(100) yards, depending

on the location,

conditigns,

andweather. I am constantly

on alert for any manned

aircraft (i.e. police or medical

helicopters,

etc.) and am prepared

to immediately

land/abort

to the nearest

and safest

groundpoint

should a manned aircraft approach

my location,

or should I suspect

a manned

aircraft may approach

near my location' My UAS is capable of vertical

and horizontal

operations,

and is flown

only within my lineof sight,

as the remote-control

pilot. Utilizing

battery power, rather thancombustible

fuels, flights generally

last between

five (5) to ten (10) minutes, with an altitude

under one hundred

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption petitionfifty (150) feet. The Petitioner,

Myrealtor

Group, LLC,will utilize a fresh,fully-charged

battery with each flight, as a safety precaution; full flight time limit for each battery is twenty (20) to twenty-five

(25) minutes

as tested. I do not operate my UAS at, or below, the manufacturer's recommended

minimum

charge levels

for operation;

preferring

to remain

well withina safe operating

range to insure

adequate

communication

between

radio control ancl UAS to eliminate potential

crash, loss of control, or other hazards. Reservebatteries are on-hand,

with each exercise,

to insure replacement and to provide

a sufficient

safe level of opreration. I do not believe in taking risks that may cause a crash, or that would create a hazard to the public/property/manned aircraft, and have no desireto lose my investment. I have clocked numerous

practice flights in remote

areas, as a hobbyist,

simulating

flights forfuture

commercial use, in orderto gain familiarization with the characteristics of this specific

UAS's performance under various temperature

and weather

conditions. Further,

the Petitioner

has practiced

on computerized

simulated

flights to maintainadequateskills and response/reflex time, as testament

o his commitment

to public

safety. Further the Petitioner,

is extremely

cautious

when operating

the UAS/ultra-lightweight, unmanned

aircraft and will not "create

a hazard

to usersof the national airspace

system or the public." 112 P.L.95 S 333(b). Given the small

size and weight

of the UAS, it falls

wellwithin Congress'$ contemplatedsafety zone when it promulgated the Reform Act and the corresponding

directive,

to integrate

UAS's into the national

airspace

system. Petitioner's

UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national

security. HOW MYREALTOR

GROUP.

LLC'S REQUEST

WILL BENEFIT

THE PUBLIC

AS A WHOLE: Aerial videography

for geographical

awareness

and for real estatemarketing has a long history, through manned,

fixed-wing

aircraft and helicopters.

For small real estate

companies and the average

homeowner,

the expense

of suchaerial

videography

is cost prohibitive.

Only largecompanies

and high-end

realtors, or luxury

homeowners

can afford

to absorb

such an expense; Deprivingnon-luxury homeowners

and lower-budget

realtors from a valuable marketing

tool. Manned

aircraft pose a threat

to the public

through the potential,

catastrophic, crashes that the Dayton

community

has experienced

in the past with commercial aircraft and medical herlicopter

cashes in the near

vicinity of the cityof Dayton. Each crash resulted in the loss of life when the combustible

fuelexploded

and burned

on impact. Police

helicopters

have made emergency,

hard-landings

within citylimits. My UAS poses no such threat since the size, and lack o1'combustible

fuel, alleviates

any potential

threat to the public. Congress has already proclaimed that it is in the public's interest to integrate commercially

flown UAS'sinto

the national

airspace

system, hence the passing

of the Reform Act. Granting my exemption request furthersthe public's interest through academic/visual awareness

of the geographical

benefits in and around

the metroDayton

area. My ultra,

lightweight UAS is battery powered

and created

no emissions

that can harm the environment. The consequence

of my ultra,

light-weight

UAS crashing

is far lessthan a full-sized helicopter,

or fixed wing aircraft; both of which are heavy, contain combustible fuel, and can cause catastrophic

devastation

to the public. The public's

interest is furthered

by minimizing

ecological

and crash

threats by permitting aerial video/photography captured through my battery-operated, ultra, light-weight,

UAS. Permitting

the Petitioner,

Myrealtor

Group, LLC, to immediately

fly within

the national

airspace

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption Petition

### Reasons Whv Mvrealtor

Group, LLC Exemption

Will NotAdversetv

Affect Safetv Or How furthers ec;onomic

growth. Granting my exemption

request substantially

furthers theeconomic impact for the metro-Dayton

community

forcompanies

looking to relocate

or build inthe Metro- Dayton area as well as individuals

looking to relocate

for career advancement

through academic and geographical

awareness,

both ofwhich serye asa stimulus

to the Community.

My exemption

will not adversely

affect safety. Quitethe contrary,

for the reasons

stated permitting

Myrealtor

Group, LLC, to log in moreflight

time and effort

in a controlled

airspace, communication

with the FAA,

willallow

me to contribute

to the innovation

and implementation

of new and novel,

as of yet undiscovered safety protocols

for realtors

that can be embraced by the NAR (National Association of Realtors, httr::l/www.RHALTSR.nrro/) for development in cooperation

with the FAA. In addition

the Petitioner,

Myrealtor

Group, LLC, submits thefollowing representations

of enhancements

to current

aerial videography

and photography

for realestate:

. I anrhave

completed

sinclair community

college ground school; ' mYUIS

weighs less than 5 pounds

complete

with the OE am digital

camera; ' I only

operate my UAS below

200feet well within a 400foot permissible ceiling set by the FAA modernization and Reform

Act of 2012;

. my UASat only

operate for 5 to 1O

minutes per flight; ' I land

my UASprior

to manufacturers

recommended

minimum

level of battery

power; r I pilot

my UAS through remote control onlyby line

of sight; ' My UAS has GPS a flight safety feature whereby

it covers and then slowly

land communication

withthe remote

control pilotis lost;new line I actively analyze flight data and other

sources of information

to constantly

update and enhance

safety protocols; ' I onlyoperate

in reasonably

safe environments

that are stricfly

controlled

and are away from powerlines,

elevated

lights, airports and actively

populated

areas; ' I conducted

then said preflight

inspections

and protocol,

during which safety carries primary importance;

. I will obtain all necessary

permissions

prior to operation; ' I have procedures

in place to abort flightin the event

of safety

breaches

or potential danger; ' The UASthat I fly,the DJI Phantom 3 Professional,

has a built-in

safety feature called the "No-Fly

Zones Feature"

that prevents

UASfrom taking

off or flyingnear busy airports.
The Petitioner,

Myrealtor

Group, LLC's safety protocols provide a level of safetyequal to, or exceeding,

existing rules. lt is important

to note that absent

the integration

of commercial UAS intoour national airspace

system, helicopters

are the primary

means of aerial video and photography

for communityawareness and real estate. While the safety record of such helicopters

is remarkably

astounding,

there has been

local incidents

involving

loss of life, as well as extensive

property damage;

it is far safer

to operate

a battery-powered

ultralight weight UAS for the reasons

listed below:
' First,

the potential

loss of life is diminished

because

UASs carry no people

on board

and I only operate my UAS in specific

areas away from mass

populations;

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption Petition' Second, there is no fuel

on Board

a UASand

thus the potential

forfire or explosion

is greatly diminished; ' Third,

the small

size andextreme

maneuverability

of my UASallows

me to remotely

pilot away from and avoidhazards quickly and safely; ' Lastly,

given the small

size and weight, even oneclose

enough to capture

amazing images, my UAS need

not be so close

to the objects

that theyarefocused

on through the technology

and use of post-editing software

allowing pan and zoom. Accordingly,

my UAS has been experimentally operated

for familiarization/competency and will continue

to operate

at, or above,

current safety levels. The specific sections of Title 14 of the Code of Federal Regulations from Which Petitioner,

Myrealtor

Group, LLC, Requests Exemption

are: 14 CFR21; 14 CFR 45.23(b), 14 CFR61.113

(a) & (b); 14 CFR 91, et seq.; 14CFR ao7 G) (); 14 CFR 409(a) (2); and 14 cFR 417(a)

& (b).
14 C. F'R' 21 and 14 C. F. R. 91: Airworthiness Gertificate,

Manuals

and the Like. 14 C'F.R.21. Subpart H, entitled Ainuorthiness Certificate, sets forth requirements for procurement

of necessary

airuuorthiness

certificate

in relation

to FAR S 91.203

(aX1) The size, weight, and enclosed

operational

area of my UAS permits exemption

from part2l because

the Petitioner's

UAS meets (and exceeds) an equivalent

level of safety pursuant to Section

333 of the ReformAct. The FAA is authorized to exempt aircraft

from the airworthiness certificate requirement

under both the Act (49 U. S. C. 544701 (f)) and Section 333 of the Reform

Act. Both pieces of legislation permitthe FAA to exempt UAS'sfrom the ainruorlhiness certificate requirement

in consideration

of the weight,

size, speed, maneuverability

and proximity

to areas suchas airports

and dense

populations.

The Petitioner,

Myrealtor

Group, LLC's UAS meets,

or exceeds,

each of the elements.
14 C.F'R.

91.7(a) prohibits the operation

of an aircraft

without an airworthinesrs

certificate.

As no such certificate

will be applicable

in the form contemplated by the FARs,

this Regulation

is inapplicable.
14 C.F.R.

S 91.9(b) (2) requires an aircraft

flight manual in the aircraft.

As there

are no pilots

or passengers,

and given

the size of the UAS's,

this Regulation

is inapplicable.

An equivalent

level of safety will be achieved

by maintaining

a safety/flight

manual delineating

areas of where

safety can be defined.

The FAA has previously issued exemptions

to this regulation

in Exemption

Nos. 8607, 8737,

8738, 9299, 92994, 9565, 95658, 10167. The Phantom employs

a maintenance program that involves regular software updates and curative measuresfor any damaged hardware.

Therefore,

an equivalent

level of safety will be achieved. 14 C'F.R' S 91.121 regarding altimeter

settings

is inapplicable

insofar as my UAS utilizes electronic

global positioning

systems witha barometric

sensor.

Myrealtor Group, LLC, Dayton, Ohio 333 Exemption Petition

### 14 C'F'R' S 91'203 (a) and (b) provides

for the carrying

of civil aircraft certifications

and registrations.

They are inapplicable

for the same reasons described

above. The equivalent

level safety willbe achieved

by maintaining

any such required certifications

andregistrations

bythe Petitioner,

Myrealtor

Group, LLC.

Applicable

Codesof Federal

Regulation

require aircraft to be marked

according

to certain specifications.

My UAS,

by definition,

unmanned.

They therefore

do not have

a cabin, cockpit, or pilot station on which Markcertain

words or phrases.

Further, two-inch lettering difficult place on such a small aircraft with dimensions

Moeller then minimal

letterint requirement.

Regardless,

I will mark

its UASs

in the largest

possible lettering by placing

the woTd "EXPERIMENTAL"

on its fuselage as required

by 14. C.F.R.S 4S.Zg (f)so thatlcan the pilot, or anyone

assisting me as a spotter

with the UAS will seethe markings.

The FAAhas previously

issued exemptions

to this regulation

through Exemptions

Nos. g73g, 10167.10167A and 10700.

Pursuant to 14 C. F R S 61.113 (a)& (b),

private pilots are limited

to noncommercial operations'

The Petitioner,

Myrealtor

Group, LLC, can achieve in the equivalent

level of safety as achieved

by current

Regulations

because my UAS does not carry anypilots

or passengers. Further, while helpful, a pilot's license will not ensure

remote control piloting skills. The risks attendant

to the operation

of my UAS is far less

thanthe risk levels

inherent in commercial activities outlined in 14 C. F R. S 61,et seq. Thus, allowing the petitioner,

Myrealtor

Group, LLC, to operate

my UAS meeting, and exceeding,

current safety levels in relation

to 14C. F. R. S61 .1 13 (a) & (b).

14 C. F. R. S 91.119

prescribes

safe altitudes for theoperation

of civil aircraft. lt allows helicopters

to be operated

at lower altitudes in certain

conditions.

My UAS willnever

operate at an altitude

greater than 200AGL;

safely below the standard

of 400 AGL. The petitioner, Myrealtor

Group, LLC, will however,

operate my UAS in safeareas

away from the public

and traffic, providing

a level of safety at least equivalent

to or below

those in relation

to minimum safe altitudes' Given thesize, weight, maneuverability,

and speed of my UAS,

an equivalent

or higher level of safety willbe achieved. E.1 409 (A and 

### Maintenance

I nspections

The above-cited

Regulations

require, amongst other things, aircraftowners and operators

to "have[the]

aircraft inspected

as prescribed

Subparl E of this partand shallbetween required

inspections,

except as provided

in paragraph

(C) of this section,

have discrepancies repaired

as prescribed

in part 45 of this chapter..." These Regulations only apply to aircraft with an airworthiness certificate.

They will not, therefore,apply to the petitioner,s UAS. However,

as a safety

precaution

I inspect my UAS before

and after

eachflight.

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption PetitionPetitioner requests

modification,

waiver, or exemption,

and clarification

(within reason), concerning

Section 91.119 - Prohibition

of FlightIn Congested Areas. Such restriction puts homeowners

and other real property owners in subdivisions, at a disadvantage

by limiting enhancedmarketing of their homes and properties, thereby discriminating against them. Vertical takeoffand landing

while video-recording, or photographing

a hqme can allow an enhanced

perspective

for viewing,

or proximity

of mountains,

golf aorir"r, manmade lakes, or other attractions'

not possible

through ground-level

photography

I am requesting

waiver for this condition

to allowreasonable

and responsible

aerial video/photography

in congested

areas of subdivisions

and neighborhoods. Similarly,

with the Trudeau Petition, the single UAV utilizedin this petitionis a professional

quad-copter

that does not require an airman

certificate

for non-commercial

flight involving

less-restrictive,

less*regulated

flight. Likewise,

as in the Trudeau

Petition, the motors,

rotors, propellers,

body/frame,

landing pads,etc' for the UAS utilized in this Petition

are not complicated. Engineering

and design allows layman maintenance.

As in theAstraeus

and Trudeau

petitions,

I am requesting

waiver or exemptions

for markings

due to the small size of the fuselage for the DJI phantom 3 Professional,

Quadcopter. Recording

parts replacement

for this UAV may prove impractical, or redundant,

due to the simplicity

of the craft. Therefore, as in the Astreaus

and Trudeau

petitiorrs

I am requesting a waiver or exemption for maintenance

records. However,pre-flight inspection

for cracks, damage

or other physical

conditions

that could hamper

safe flight/operation

is a reasonable expectation;

as is post-flight

inspection,

that may aid in identifying flightconditions

that may cause stress to propellers, landing gear, etc. Thorough inspections

of the UAV shall be conducted

and flightresponse

tested should a hard landing

or crashoccur,

insuring that the UAV can operate

in a safe manner

before conducting

anyfurther

video/photography. Myrealtor

Group,LLC, as with the Trudeau Petition,

requests

a waiver

or exemption from Section

91.203 (a) since

the Phantom

is a professional-grade UAV/UAS

that should

not require an ainruorthiness certificate,

or a registration

certificate. posting of special flight authorization

would not be possible

since the Phantom

has no cabin

and is not large

enough to carry said certificate. However, a special

flight authorization

can be maintained

by the operator to make available

upon request. In compliance

withsection

90.151 (a)the Phantom

is a battery

operated

UAV/UAS

with battery levelmonitoring

capability. Fully

charged battery flighttime is ratedat 25 minutes, with videos/photos

takingmuch lesstime to record. Operator or PIC is warned

when battery

levelis low. PRIVACY All flights

will occur over controlled property with the appropriate

party's consent and/or knowledge.

lmages takenwill be of individuals who have also consented to being

filmedor othen'vise

haveagreed

to be in the area

whereaerial

photography

willtake place.

Satisfaction

of the criteria

provided

in Section

333 of the Reform

Act of 2e12-size,weight,

Myrealtor Group, LLC, Day'ton, Ohio 333 Exemption petition

### speed, operating

capabilities,

proximity to airports

and populated

areas and operation

within visual line of sight and national security -provide more than adequate justification

for the grant of therequested

exemptions

allowing commercial

operation

of applicant's

UASs in thereal estate industry pursuant totheManual

appended

hereto.

14 c.F.R. 21,

subparl H;14 c. F. R. 4s.23 (b); 1a c. F. R.61.133

(a) and(b);

M c.F.R. S 91.7 (a)', 14 c.F.R. S 91.e (b) (2); 14 c.F.R. S e1.103

(b); 14 c.F.R. S 109; 14 c.F.R. S 91.119; 14 C'F'R. S 91.121;14

C.F.R. S 91.151

(a) ; 14 C.F.R. S 91.203

(a) and (b); 1a C.F.R. $ 91.405

(a); 14 C.F.R. S91.407

(a) (1); 14C.F.R.

S 91.409

(a) (2); and, 14 c.F.R S 91.417 (a) &(b) to commercially operate my small, unmanned vehicle/ultra-lightweight, unmanned aircraft vehicle in community

awareness

and real estate

operations,

and to develop

economic platforms

for real estate

to enhance

the understanding

and experience

of those seeking real estateinformation,

or to relocate

to the greater

Dayton metropolitan

area. Currently,

area awareness

and real estate aerial videography/photography relies primarily

on the use of larger

aircraft running on combustible

fuel, posing

potential

risk to the public. Granting

the Petitioner,

Myrealtor

Group,LLC's request for exemption

will reduce

the current risk levels and thereby enhance safety. My UAS craft does not contain potentially explosive

fuel, smaller, lighter, and moremaneuverable thanconventional

real estate video and photographic

aircraft muchless

flight time.Further,

I operate

at lower altitudes

and in controlled airspace

eliminating

potential

public risk flying to and fromestablished

airfields. The Petitioner,

Myrealtor

Group, LLC, has been inform ally analyzing

flight information and will compile

safety protocols

and the implementation of a flight

operatiorrs

manual for real estate usage that exceeds currentlyaccepted means and methods for Safelight. Formal collection

of information

shared with the FAA will enhance the FAA's internal

efforts to establish protocols

for complying

with the FAA Modernization and ReformAct of 2012.There are no personnel

on onboard

my UAS and therefore the likelihood

of death

or serious

bodily injury is significantly

diminished

the operation

of my UAS,

weighing

less than 5 pouncts

and traveling

at lowerspeeds

withinlimited

areas will provide

an equivalent

levelof safety

as that achieved under current FARs. Accordingly

the Petitioner,

Myrealtor

Group, LLC, respectfully requests

that the FAA grant my exemption

request as I am willing

to cooperate

in sharing

information

to benefit

the FAA,safety

of manned

aircraft, and the general

public at large. Respectfully

submitted,

North Ridgeville,

OH 44039 (440)327 - 1542 Telephone (440)327 -1225 Facsi m i le TricountylawOhio@gmail.com Email Counsel for Myrealtor

Group, LLC

Myrealtor Group, LLC, Dayton, Ohio 333 Exemption Petition 

### 35888 Center R e Road,

Unit g