William F. McDonough

35888 Center 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 of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20SgO

Re: Exemption Request Section 333 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 FAA Modernization 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 and videography, so long as such operations are conctucted within and under the conditions outlined herein or as may be established by the FAA gs required by Section 333.

As detailed in this document antj the attached Manual, the requested exemption would permit the operation of sUAS under controlled conditions in airspace that is 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 one of 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) of the Reform Act.

The name and address of the applicant is:

Myrealtor Group, LLC

Dakota D. Shannon, President

Realtor, Keller Williams Advantage

4417 State Route 725

Dayton, OH 45305

Office: 937-601-8827

Email: dakota@myrealtoroh. com

Website: dakotasells. com

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption petition
Myrealtor 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 owner and

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 well as 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 Sinclair Community College's Ground School Final Grades are Attached as

Exhibit l)' Additionally, Mr. Shannon is experienced in flying hobby aircraft for recreational

purposes.

Myrealtor Group has added a DJI Phantom 3 Professional, quadcopter UAS, equipped

with an integrated, original equipment manufacturer (OEM) digital camera, to my inventory. The

intended use of this equipment 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 occur in predetermined areas away from the public, airports, serial

ports and vehicular traffic, for community photos and videos, and within 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 safety plan 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. This will act to further safety prrotocols closer to

lightweight UAS's specific to real estate video and photography usage, as a record flight data

and other information gained to permitted flight operations to share with the FAA through any

required FAA reports to assist with future 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 national airspace system" under section 333(c) of the Reform Act

specific to the use of UAS's for real estate/realtor purposes how to conduct my operations in

compliance with the 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 enhance real 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 Petition
which will promote local economic growth through increased employment and increased tax

base' Both the public safety in mind by keeping heavier manned aircraft containing combustible

fuelthat poses potential public hazard.

UAV/UAS/UA G la rification

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 home capability, 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 that automatically 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 is2.82 pounds.

The Phantom has an additional communication link between the camera and the 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 functions eliminates 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 more precise determination of height, direction of flight, and distance from the operator

or PIC can 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 UAV as a precaution.

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 the Phantom is an automatic return home feature that automatically directs the

craft back to the point of takeoff to communication with the transmitter be lost. The phantom is

a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight times 25

minutes. Gross weight is 2.86 pounds.

The Phantom is an additional communication link between the camera and the craft on a

different. Radiofrequency for the smart phone connection. Allowing the oprerator or pilot in

command (PlC) to monitor battery level, 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 14 of 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 was the 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 for maximum of 300 feet AGL

o radius distance from controller set for maximum of 1000 feet, both to aid in direct line of sight and visual observation.

Current firmware upgrades for

o Main controller

. GPS

. Receiver

. Battery

. Zen IMU

As with several other recently accrued similar petitions at exemptions including that of

Astraeus (FAA-2014-0352), referred hereafter 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 with Trudeau Petition, Myrealtor Group, LLC, is using a UAV that had the capability

for taking off and landing in a single point, identical to a helicopter. There are no runways, aided

takeoff apparatuses, nor routes that need to be flown to areas being aerial video-recorded or photographed, allowing for a reduced and more confined area of flight.

The Astraeus Petition is for movie set involving a significant number of people, aerial

equipment, moving or action sequences, 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 the Trudeau 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 lower risk 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 states may

Myrealtor Group, LLC, Dayton, Ohio

933 Exemption Petition
requrre

flight.

repeat flights, where the stationary object, within most cases, requires only a single

Similarly, as in the Trudeau Petition, Myrealtor Group, LLc Will require property owners, written consent for 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 Exhibit lil)

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, 1 12 P 'L.95 SS 331-334, seeking relief from any current applicabte FARs operating that would prevent 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's best interest to do so. My ultra, light-weight UAS meets the definition of "small unmanned aircraft" as defined in section 331 and therefore the integration of my ultra-lightweight UAS is expressly contemplated by the Reform Act. I would like to 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 Video and 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' 112 P.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 than a 24-knot (1smph) wind. For safety, stability and fear of financial loss, I will not fly in winds exceeding 16 kph (10 mph). Built-in safety systems include a GpS mode that allows my UAS to hover in place when the radio controls are 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 point of take-off. The Petitioner has not, nor will, operate a UAS near airports, hospitals, nor police heliports, and does not operate near areas where the general public is within fifty (50) to one hundred (100) yards, depending on the location, conditigns, and weather. 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 ground point 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 line of sight, as the remote-control pilot. Utilizing battery power, rather than combustible fuels, flights generally last between five (5) to ten (10) minutes, with an altitude under one hundred

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption petition
fifty (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 within a safe

operating range to insure adequate communication between radio control ancl UAS to eliminate

potential crash, loss of control, or other hazards. Reserve batteries 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 desire to lose my investment. I have clocked

numerous practice flights in remote areas, as a hobbyist, simulating flights for future commercial

use, in order to 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 maintain adequate skills and response/reflex time, as

testamento 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 users of 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 well within

Congress'$ contemplated safety 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 estate marketing has a long

history, through manned, fixed-wing aircraft and helicopters. For small real estate companies

and the average homeowner, the expense of such aerial videography is cost prohibitive. Only

large companies and high-end realtors, or luxury homeowners can afford to absorb such an

expense; Depriving non-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 city of Dayton. Each crash resulted in the

loss of life when the combustible fuel exploded and burned on impact. Police helicopters have

made emergency, hard-landings within city limits. 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's into the national airspace system, hence the passing of the Reform

Act. Granting my exemption request furthers the public's interest through academic/visual

awareness of the geographical benefits in and around the metro Dayton 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 less than 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 Not Adversetv Affect Safetv Or How

furthers ec;onomic growth. Granting my exemption request substantially furthers the economic

impact for the metro-Dayton community for companies looking to relocate or build in the Metro- Dayton area as well as individuals looking to relocate for career advancement through academic

and geographical awareness, both of which serye as a stimulus to the Community.

My exemption will not adversely affect safety. Quite the contrary, for the reasons stated

permitting Myrealtor Group, LLC, to log in more flight time and effort in a controlled airspace,

communication with the FAA, will allow 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 the following

representations of enhancements to current aerial videography and photography for real estate:

. I anr have completed sinclair community college ground school;

' mY UIS weighs less than 5 pounds complete with the OE am digital camera;

' I only operate my UAS below 200 feet well within a 400 foot permissible ceiling set by

the FAA modernization and Reform Act of 2012;

. my UAS at only operate for 5 to 1O minutes per flight;

' I land my UAS prior to manufacturers recommended minimum level of battery power;

r I pilot my UAS through remote control only by line of sight;

' My UAS has GPS a flight safety feature whereby it covers and then slowly land

communication with the remote control pilot is lost; new line I actively analyze flight data

and other sources of information to constantly update and enhance safety protocols;

' I only operate in reasonably safe environments that are stricfly controlled and are away

from power lines, 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 flight in the event of safety breaches or potential

danger;

' The UAS that I fly, the DJI Phantom 3 Professional, has a built-in safety feature called

the "No-Fly Zones Feature" that prevents UAS from taking off or flying near busy

airports.

The Petitioner, Myrealtor Group, LLC's safety protocols provide a level of safety equal

to, or exceeding, existing rules. lt is important to note that absent the integration of commercial

UAS into our national airspace system, helicopters are the primary means of aerial video and

photography for community awareness 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 UAS and thus the potential for fire or explosion is

greatly diminished;

' Third, the small size and extreme maneuverability ofmy UAS allows me to remotely pilot

away from and avoid hazards quickly and safely;

' Lastly, given the small size and weight, even one close enough to capture amazing

images, my UAS need not be so close to the objects that they are focused 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 CFR 61.113 (a) & (b);

14 CFR 91, et seq.;

14 CFR 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 Reform Act. 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 permit the FAA to exempt UAS's from the ainruorlhiness certificate

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas

such as 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 measures for 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 with a 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 will be achieved by maintaining any such required certifications and registrations by the Petitioner, Myrealtor Group, LLC.

Applicable Codes of 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 Mark certain 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 that lcan the pilot, or anyone assisting me as a spotter with the UAS will see the markings. The FAA has previously issued exemptions tothis 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 any pilots 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 than the 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 14 C. F. R.

S 61 .1 13 (a) & (b).

14 C. F. R. S 91.119 prescribes safe altitudes for the operation of civil aircraft. ltallows

helicopters to be operated at lower altitudes in certain conditions. My UAS will never 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 safe areas 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 the size, weight, maneuverability, and speed of my UAS, an equivalent or

higher level of safety will be achieved.

E. 1 409 (A and

Maintenance I nspections

The above-cited Regulations require, amongst other things, aircraft owners and

operators to "have [the] aircraft inspected as prescribed Subparl E of this part and shall between

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 each flight.

Myrealtor Group, LLC, Dayton, Ohio

333 Exemption Petition
Petitioner requests modification, waiver, or exemption, and clarification (within reason), concerning Section 91.119 - Prohibition of Flight In Congested Areas. Such restriction puts

homeowners and other real property owners in subdivisions, at a disadvantage by limiting enhanced marketing of their homes and properties, thereby discriminating against them. Vertical takeoff and 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 allow reasonable and responsible aerial video/photography in congested areas of subdivisions and neighborhoods.

Similarly, with the Trudeau Petition, the single UAV utilized in this petition is 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 the Astraeus 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 flight conditions that may

cause stress to propellers, landing gear, etc. Thorough inspections of the UAV shall be conducted and flight response tested should a hard landing or crash occur, insuring that the

UAV can operate in a safe manner before conducting any further 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 with section 90.151 (a) the Phantom is a battery operated UAV/UAS with

battery level monitoring capability. Fully charged battery flighttime is rated at 25 minutes, with

videos/photos taking much less time to record. Operator or PIC is warned when battery level is

low.

PRIVACY

All flights will occur over controlled property with the appropriate party's consent and/or

knowledge. lmages taken will be of individuals who have also consented to being filmed or

othen'vise have agreed to be in the area where aerial photography will take 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

the requested exemptions allowing commercial operation of applicant's UASs in the real estate

industry pursuant to the Manual 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); 14 C.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

estate information, 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 more maneuverable than conventional real estate video and

photographic aircraft much less flight time. Further, Ioperate at lower altitudes and in controlled

airspace eliminating potential public risk flying to and from established 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 currently accepted 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 Reform Act 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

lower speeds within limited areas will provide an equivalent level of 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