Adriel Maxwell

536 Buckeye St.

Vacaville Ca. 95688

(707) 724-4376

mynameisadriel@gmail.com

May 18, 2015 

U. S. Department of Transportation Docket Management System 

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 

myself, 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 Aircraft 

Systems (sUAS) for aerial imaging and video of California homes and properties for sale 

and inspections or special events.

I have experience in flying hobby quads for recreational purposes during the past 1.5 

years without incident. I currently own a DJI Phantom 2 quad-copter and 3DR Solo quad 

copter (maximum gross weight 3 pounds each, equipped with rotors that are driven by 

electric motors powered by batteries, the sUAS’s have a maximum airspeed of 30 knots). 

I will use these quad copters for aerial videography/cinematography to augment real 

estate listing videos. These afore mentioned sUAS’s will be put into commercial use 

following exemption and approval by 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 

within 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 safety 

at least equal to existing rules and will only operate in a safe environment that is strictly

controlled, are away from power lines, airports and densely populated areas; and I will 

conduct extensive preflight inspections and protocols, during which safety carries 

primary importance. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, I am asking exemption from 14 C.F.R. part 21,Subpart H(Airworthiness 

Certificates)and§91.203 (a) and (b) (Certifications required),subject to certain conditions 
and 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 aircraft. 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 my 

UAS will not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Additionally two -inch lettering 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 by 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 anyone 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 only 

apply to aircraft with an airworthiness certificate. But, as a safety precaution I will 

perform a preflight inspection of my UAS before each flight as outlined in his operating 

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 by current regulations 

because my 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 outlined 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 already explored getting my pilot’s license, at the direction of the FAA, 

I would gladly begin education and eventual licensing. 

Regarding UAS operational training, as stated previously I have 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. I also 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 my 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 only within visual line of sight (VLOS) & during daylight hours only. 

4) Use the UAS’s global positioning system (GPS) flight safety feature; it hovers and 

then slowly lands if communication with the remote control. 

5) Conduct all operations under my own personal and flight safety protocols.

6) I will operate and will actively analyze flight data and other sources of information 

to constantly update and enhance my safety 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) Always obtain all necessary permissions prior to operation. 

9) Have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

Aerial videography 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, my small UAS, when used 

properly, 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 photography. “When broker Kurt Wannebo added an 

aerial video to the listing for a Carmel Valley house, located on a large corner lot 

overlooking canyons 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 any tool that increases value to a home or 

community (by adding visibility to more potential buyers) is in the best interest of 

homeowners nationwide. Selling a home faster and for more money because of the use of 

new technology (being safely used and approved by the FAA) will go a long way to 

ensure our economy continues to grow. 

Thank you for your time and consideration. 

Adriel Maxwell