Adriel Maxwell

536 Buckey e St. Vacaville Ca. 95688 (707) 724

- 4376 my nameisadriel@gmail.com May 18, 2015 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave. SE Washington, DC 20590
RE : **Exemption Request Section 333 of the FAA Reform Act**  and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I , Adriel Maxwell , a private citizen, preparing this exemption request my self, would like to apply for an exemption from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation of a small Unmanned Aircra ft Sy stems (sUAS) for aer ial imaging and video of California homes and properties for sale and inspections or special events. I have experience in fl yi ng hobby quads for recreational purposes during the past 1.5 ye ars without incident. I currentl y own a DJ I Phantom 2 quad

- copter and 3DR Solo quad copter (maximum gross weight 3 pounds each, equipped with rotors that are driven b y electric motors powered by batteries, the sUAS ’s have a maximum airspeed of 30 knots). I will use these quad copters for aerial vi deography /cine matography to augment real estate listing videos

. These afore mentioned sUAS’ s will be put into commercial use following exemption and approval b y the FAA. My exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) in predetermined areas away from general public, airports, heliports and vehicular traffic, under 400 ft. and after carefully reviewing, inspecting and examining the area of aerial observation. This would allow for community videos and w ithin property

boundaries for individual homeowner real estate listing videos/photos.
I will abide all FAA requirements to ensure this exemption will provide a level of safet y at least equal to existing rules and will only operate in a safe environment th at is strictly controlled, are away

fr om power lines, airports and densel y populated areas; and I will conduct extensive preflight inspections and protocols, during which safet y carries primary importance. **14 C.F.R. Part 21, Subpart H: Airworthiness Certi ficates 14 CFR § 91.203**  Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, Iam asking exemption from 14 C.F.R. part 21,Subpart H(Airworthiness Certificates)and§91.203 (a) and (b) (Certifications require d),subject to certain conditionsand limitations, is warranted and meets the requirements for an equivalent level of safety

under 14 C.F.R. part 11 and Section 333 of P.L . 112

- 95 (Section 333). **14 C.F.R. 45.27(a): Location of marks; non fixed**

**- wing aircraf**  **t. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks**  Furthermore I request an exemption from §45.23 Marking of the aircraft because m y UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally

two

- inch l ettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering b y placing the word “Experimental” or assigned number or name (based on a request or ruling by the FAA ) on its fuselage as required by §45.29 (f) so that any one assisting me as a spotter will see the markings.
I also ask for an exemption from §91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417 (a) and ( b) Maintenance inspections may be required and should be granted since they onl y apply to aircraft with an airworthiness certificate. But, as a safet y precaution Iwill perform a preflight inspection of my UAS before each flight as outlined in his operatin g documents. **14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command.** Under §61.113 (a) and (b) private pilots are limited to non

- commercial operations, however I can achieve an equivalent level of safety as achieved b y current regulations because m y sUAS does not carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the commercial activities out lined in 14 C.F.R. part 61, et seq., I requests an exemption from §61.113 Private Pilot Privileges and Limitations. A side note, I have alread y explored getting my pilot’s license, at the direction of the FAA, I would gladly

begin education and eventual li censing. Regarding UAS operational training, as stated previously Ihave 1.5 years ‘experience flying numerous flights as a hobbyist and that will help in the familiarization and the characteristics of UAS’ performances under different temperature and weather conditions. Ialso practice on computerized simulated flights software to maintain adequate skills and response reflex time. **14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action** If granted an exemption I agree to additional safety procedures including, but not limited to: 1) Keeping m y UAS within a radius distance of 1000 feet from the controller to both aid in direct line of sight visual observation. 2) Operate the UAS for 5

- 10 minutes per flight; land my sUAS according to the manufacturer’s recommended minimum level of battery power.3) Operate UAS onl y within visual line of sight (VLOS) & during daylight hours only

.

4) Use the UAS’s global positioning sy stem (GPS) flight safet y feature; it hovers and then s lowly

lands if communication with the remote control

. 5) Conduct all operations under m y own perso nal and flight safet y protocols. 6) Iwill operate and will actively anal yz e flight data and other sources of information to constantly

update and enhance my

safet y protocols

. 7) Contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information

. 8) Alway s obtain all necessary permissions prior to operation

. 9) Have procedures in place to abort flights in the event of safet y breaches or potential danger. Aerial videograph y for geographical awareness of real estate marketing has been around for a long time through manned fixed winged aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, m y small UAS, when used properl y, will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The operation of his UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in California

. One final comment, the use of a sUAS has already proven to increase the marketability of a home. For example please review the article published January 7, 2015 in the San Diego source entitled “drone use in real estate may increase” . The article cites the FAA’s exemption given to Douglas Trudeau, but also describes a record high price for an area home that used a drone for aerial photograph y. “When broker Kurt Wannebo added an aerial video to the listing for a Carmel Valley house, located on a large corner lo t overlooking can yons on two sides, he saw Web traffic noticeably increase.” I understand this may

be outside the scope of this request but as a real estate agent I think it’s important to point out that the use of an y tool that increases value to a home or community

(b y adding visibility

to more potential buy ers) is in the best interest of homeowners nationwide. Selling a home faster and for more money because of the use of new technology

(being safel y used and approved by the FAA) will go a long way to e nsure our econom y continues to grow. Thank y ou for y our time and consideration. Adriel Maxwell