October 22, 2015 

Federal Aviation Administration (FAA) 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

7•1 Is ·~'''I I "'""' .. ' '' -

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

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 111, Beau Skinner, a full service independent real estate Broker, hereby applies for an 

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of a Unmanned 

Aircraft Systems (UAS) commercially in airspace regulated by the FAA so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

The requested exemption would permit Beau Skinner to pursue his commercial interests in providing 

aerial data capture to clients using a small advanced UAV in the following areas: 

•',. Real Estate 

Marketing 

.Mapping 

Surveying 

Agriculture 

· inspection 

General Photography 

i !; 

Regulations from which exemption is requested: 

14CFR21; 

14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 

14 C.F.R. 91, et seq.; 

14 CFR 407 (a) (1 ); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

I, Beau Skinner am a licensed Real Estate Broker in the State of Texas ( License #593276). I have been 

flying UAV's for over a year. My most recent experience is with a DJI Phantom 2 Vision+. I have been 

flying as a hobbyist and am now ready to bring my skills to a professional level. In doing so, I consider all 

safety precautions and regulations as foremost with each flight. 
My request to operate commercially is primarily to record digital video data and other aerial 

photography data for privately owned fee simple real estate which will assist in the promotion and 

marketing of their real estate for ultimate disposition and sale. The area ofTexas where I work is not 

heavily populated and over 95% of the owners I work for are selling Farm and Ranch land away from the 

general public. These properties cannot always be easily accessed by foot and providing an aerial view of 

all boundaries and topography of the land would prove to be highly desired and essential when 

marketing these properties to the general public as well as properly informing the general public of what 

they are seeking to purchase or sell. Aerial photography and videoing has been around for a long time in 

the real estate market through manned fixed wing aircraft and helicopters. For small budget real estate 

brokers like myself and average homeowners a manned fixed wing aircraft is cost prohibitive. Only large 

companies and high end Realtors or luxury homeowners can afford such expense, depriving non-luxury 

homeowners and lower budget Realtors from a valuable marketing tool. Also, using my UAV service 

avoids the high risks of a helicopter and/or fixed wing aircraft with fuel and persons on board. The 

reduced noise and size creates a much smaller environmental impact which promotes public and 

environmental safety. 

To make sure the operation will be safely conducted; my spotter and I will survey the flight area for any 

mobile phone base stations, radio transmission towers, power lines, or any other electromagnetic 

interference that could disrupt flight. We will scan the area for any large buildings or trees that may 

affect with GPS accuracy or flight. We will verify the weather is safe for flight to avoid wind speed 

exceeding 10 m/s, snowfall, rainfall, and restricted environmental visibility. Additionally, we will go 

through the PREFILGHT CHECKLIST/maintenance and FLIGHT TEST PROCEEDURES in a secure area safe 

from persons and property. 

The DJI Phantom 2 VISION+ is equipped with a built-in stabilized HD camera and GPS safety features. 

These safety features include the ability to restrict the maximum altitude they operate above ground 

level, to limit the radial distance from the operator and to exclude them from operations within 

designated Class B, C and D airspace including "no-fly zones". This model has a failsafe function that is 

automatically engaged in the event communication is lost between the UAS and the main controller 

transmitter. At that time, the UAS will return to its point of takeoff and land safely. If the connection is 

restored, the operator can regain control of flight and land manually. 

These specifications meet or exceed the Model Aircraft Operating Standards as set below: 

The petitioner will only operate its UAS in line-of-sight of the operator and will operate at 

sites that are "sufficient distance" from populated areas within the sterile area described in 

the FOPM. Such operations will ensure the UAS will"not create a hazard to users of the 

national airspace system or the public." 

When flying the UAS within three (3) miles of an airport, airport operators will be notified 

and the operator will give the right-of-way to avoid flying in the proximity of full-scale 

aircraft. 

Maximum flight time for each operation will be 30 minutes. 

Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight 

time to safely land the UAS. 

The UAS will be pre-programmed so it will not be operated at an altitude that will exceed 

200 feet AGL, and not more tnan 100 feet above an elevated platform from which 

videography is planned. 

The UAS operated by the Petitioner weighs less than 25 pounds, including all payload. 
The UAS will operate at speeds not to exceed 50 knots, can hover and can simultaneously 

move vertically and horizontally. 

I respectfully request exemption under Section 333 to enable Beau Skinner to operate efficient, limited, 

low-risk commercial UAS operations for the activities stated respecting at all times the space and privacy 

of citizens and property while keeping airspace safe. 

Respectfully, 

Beau Skinner 

6243 FM 244 

Anderson, TX 77830 

(979)574-857 

Beau.skinner@yahoo.com