April 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Petition of Real Help Inc for Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012.

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Real Help Inc, hereby applies for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow commercial operations of small unmanned aerial system (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for exemption, the 

enclosed , the DJI UAS manufacturer's operations and/or instructions manual, DJI UAS User’s 

Manuals, DJI UAS Quick Start Guides, and any other requirements established by the FAA 

pursuant to Section 333 of the Reform Act. 

This exemption would permit commercial operation by Real Help Inc, which uses the DJI 

Phantom 2 Vision Plus to conduct agricultural and conservation research, real estate photography 

and videography, local promotional photography and videography to promote tourism, news 

gathering, fire and rescue. Real Help Inc’s operation under the exemption will be subject to strict 

operating requirements and conditions to ensure safety at all times and under conditions as may 

be modified by the FAA as required by Section 333.

Real Help Inc will be operated under controlled VFR conditions at low altitude in airspace that is 

permitted in accordance with Real Help Inc's approved Certificate of Authorization (COA). 

Finally, the FAA ATC will approve the airspace in which the sUAS will operate in advance. 

Real Help Inc. respectfully submits this request for an exemption because it wishes to operate 

sUASs. The operations Real Help Inc will be conducting will be in lieu of comparatively 

hazardous operations now conducted by others using fixed wing and rotary conventional aircraft. 

The FAA can have confidence that the operations will be conducted at an equivalent level or 

greater level of safety than those providers. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities 

under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such 

aircraft systems in the national airspace system.”
For your convenience, Real Help Inc has organized this Exemption request as follows:

 I. Petitioner's Description 

 II. Relevant Statutory Authority 

 III. Qualifications for Approval Under Section 333 of the Reform Act 

 IV. Description of Proposed Operations 

 V. Regulations From Which Exemption is Requested 

 VI. Public Interest 

 VII. Privacy

 VIII.Federal Registry Summary

 IX. Conclusion 

I. Petitioner's Description:

Real Help Inc, headquartered in the Village of Bigfork, Montana, is a company that wishes to 

provide sUAS support to news services, real estate photography and videography, local 

promotional photography/videography in a compliant and safe environment. Real Help Inc plans 

on providing a wide range of services as the sUAS market expands.

Real Help Inc's goal is to operate in an accident-free environment by:

 • Demonstrating a commitment by the petitioner to operate in a compliant manner. 

 • Identify hazard and risk while eliminating or controlling all these risks. Petitioner will 

intervene and report when unsafe work practices or conditions appear to exist.

 • Train all support personal involved in flight operations to perform at the highest standard 

level.

The contact information for Petitioners is as follows:

Real Help Inc

355 Swan Hill Drive

Bigfork, MT 59911

Member Managers:

Kimberly Johnson

Cell: 406-270-1269

Thomas Johnson

Cell: 406-890-8133 

II. Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned 
aircraft systems may operate safely in the National Airspace ("NAS") before completion of the 

formal UAS rulemaking, based on the following considerations:

 • The UAS's size, weight, speed, and operational capability; 

 • Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within the visual line of sight of the operator.3 

If the Secretary determines that such vehicles "may operate safely in the National Airspace 

System, the Secretary shall establish requirements for the safe operation of such aircraft in the 

National Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is in 

the public interest. A party requesting an exemption must explain the reasons why the exemption: 

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it 

would provide a level of safety at least equal to the existing rules). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 

40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service:

The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any of sections.

III. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act.

The proposed operations would permit Real Help Inc the use of small UAS under controlled 

conditions in airspace that is: (1) predetermined; and that (2) provides an Increased level of 

safety beyond that existing when fixed or rotor wing aircraft are used by others to accomplish the 

same purpose.

____________________________________________

3 Real Help Inc's submission places a duty on the Administrator to not only process applications for exemptions under

Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to

allow approval, to supply conditions for the safe operation of the sUAS. Real Help Inc welcomes the opportunity to consult

with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require modification.
Real Help Inc will use UASs that are multirotor, weighing less than 25 pounds including 

payload. They will operate, under normal conditions, at speeds not to exceed 50 mph. The 

multirotor has the capability to hover and move in the vertical and horizontal plane. Real Help 

Inc’s UASs will operate in line of sight and during daylight hours. Real Help Inc will operate at 

or below 400 feet AGL. All required permissions and permits would be obtained from territorial, 

state, county or city jurisdictions, Including local law enforcement, fire, or other appropriate 

governmental agencies prior to operating a sUAS.

Given the small size of the sUAS involved and the environment within which they will operate, 

this Real Help Inc’s exemption falls within the zone of safety and demonstrate an equivalent 

level of safety, in which Congress desired the FAA to permit commercial UAS operations by 

exemption pending completion of formal rulemaking. Also, due to the size of the sUAS and the 

confined area in which the sUAS will operate, approval of the application presents no hazard in 

the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in the 

public interest.

IV. Description of Proposed Operations 

To assist the FAA in its safety assessment of Real Help Inc's proposed sUAS operations, below is 

a summary of operational limitations and conditions that will ensure an equivalent or higher level 

of safety to operations conducted under current regulatory guidelines: 

 1. The sUAS will weigh less than 55 pounds. 

 2. Flights will be operated within line of sight of the PIC and visual observer. 

 3. Maximum total flight time for each operational flight will be limited to the amount of 

time the sUAS can be flown and still maintain a reserve battery power of no less than 

25%. 

 4. Flights will be operated at an altitude of no more than 400 feet AGL. 

 5. Flights will be operated at a lateral distance of least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or who 

have not signed a waiver in advance of the operation. 

 6. Minimum crew for each operation will consist of the sUAS PIC (and a Visual Observer/ 

Camera Operator when appropriate).

 7. The sUAS PIC will be the petitioners Kimberly Johnson and/or Thomas Johnson .

 8. Real Help Inc will designate a Pilot in Command ("PIC") for each mission. 

 9. The sUAS will operate only within a confined safe and uncongested area. 

 10. Prior to the operations at a particular location, a site inspection will be conducted. On the 

day of the mission the management person with operational control and the PIC will 

concur on performing the mission after reviewing all safety issue compliance.

 11. Prior to initiating each mission a briefing will be conducted in regard to the planned 

sUAS operations. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safe and uncongested area be present for this briefing. 
 12. Real Help Inc crew will use a safety and airworthiness checklist. 

 13. The sUAS will be maintained in compliance with the manufacturer’s guidelines. 

 14. In the event of an accident involving an Real Help Inc sUAS, petitioner will cease 

operations and report the accident to the NTSB and AFS-80. 

 15. PIC and VO will at all times be able to communicate by voice. 

 16. PIC, Camera Operator, VO, and Operational Personnel will have been trained and tested 

by the petitioners.

 17. All required permissions and permits will be obtained in advance from territorial, state, 

county or city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies. 

 18. In compliance with approved exemption, Real Help Inc management will submit a 

written “Plan of Activities” to the local Flight Standards District Office (FSDO) having 

jurisdiction over the area of proposed filming three days in advanced of operations during 

film or movie productions. 

 19. If the sUAS loses communications signal, the sUAS will have the capability to return to a 

per-determined location within the safe and uncongested area.

 20. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

 21. The sUAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

 22. Real Help Inc, will assure no individuals’ privacy is violated. 

 23. Procedures have been established to contact ATC prior to operating in airspace other than 

G.

 24. 

V. Regulations From Which Exemption is Requested

 A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in 

Command

 B. 14 CFR § 91.103: Preflight Action 

 C. 14 CFR § 91.113: Right-of-Way Rules 

 D. 14 CFR § 91.119 (c): Minimum Safe Altitudes 

 E. 14 CFR § 91.121: Altimeter Settings 

 F. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions 

 G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in 

Command

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the DJI sUAS’s are remotely controlled with 

no passengers or property of others on board. Real Help Inc respectfully proposes that the FAA 

should take into account the characteristics and procedures of the particular UAS.
Real Help Inc proposes that the actual operation of the DJI sUAS does not require the Pilot to 

hold a private pilot certificate. Real Help Inc proposes the following requirements:

 • Pilot in Command Requirements: 

 1. The PIC must have accumulated and logged a minimum of five hours as 

UAS pilot with the make and model of UAS to be utilized for operations

under the exemption and three takeoffs and landings in the preceding 90 days.

 2. The PIC must have successfully completed the qualification process as 

required by the petitioner, to include a knowledge and skill test.

B. 14 CFR § 91.103: Preflight Action

Real Help Inc requests an exemption from the preflight actions requirements of 14 CFR 91.113 

that prescribes the preflight actions under which aircraft may operate:

The Petitioner shall, before beginning a flight, become familiar with all available information 

concerning that flight.

 a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, 

battery charge levels alternatives available if the planned flight cannot be completed, and 

any known traffic delays of which the pilot in command has been advised by ATC;

 b) For every flight the following takeoff and landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing distance 

data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind 

and temperature.

Real Help Inc will not operate sUAS’s under IFR conditions, or when the ceilings are below

1000 feet and the visibility is below 3 statute miles. DJI’s sUAS’s do not have published

approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance

data. 

Equivalent Level of Safety

The PIC along with the person having operational control must assure that the weather will be

adequate to complete the mission in VFR condition. Since Real Help Inc operates in rural 

Montana where the density altitude may exceed 2000 feet, UAS performance may be effected. 

When used in those locations the intended sUAS will be test flown at gross weight to test 

performance limitations

prior to conducting sUAS operations. 

C. 14 CFR 91.113: Right-of-Way Rules
Real Help Inc request an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance 

by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this 

section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may 

not pass over, under, or ahead of it unless well clear.

Real Help Inc will operate small pilotless UAS’s and cannot comply with these rules as they 

have been written. 

Equivalent Level of Safety

Real Help Inc will operate sUAS’s at or below an altitude of 400 feet AGL, well below the 

normal operating altitude of other aircraft. Real Help Inc specifies that a Pilot in Command with 

experience will perform each mission and have knowledge of the avoid rules. It’s the 

responsibility of the PIC to cease operations and land the UAS immediately whenever and 

aircraft comes into the vicinity creating a potential threat or safety concern. Operations will not 

recommence until the potential threat is clear or safety concern has been resolved.

D. 14 CFR. § 91.119: Minimum Safe Altitudes

Real Help Inc requests an exemption from the minimum safe altitude requirements of 14 CFR 

91.119 that prescribes the minimum safe altitudes under which aircraft may operate:

 • Over any congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

 • Over other than congested areas at an altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it 

can be operated "without hazard to persons or property on the surface," provided that "each 

person operating the helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA." 

To provide the intended operations, the sUAS is normally operated below 400 feet AGL. 

Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral 

distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from 

people not associated with the operation. 

Equivalent Level of Safety

Compared to flight of normal aircraft, Real Help Inc’s multi-rotor aircraft weigh a maximum of 

25 pounds, and given the lack of flammable fuel, any risk associated with these operations is far 

less than those that presently exist with conventional aircraft. An equivalent level of safety will 

be achieved given the size, weight, and speed of the UAS, as well as the location where it is 

operated. As set forth in the Operations Manual, the sUAS will be operated in a safe and 

uncongested area, where buildings and people will not be exposed to operations without their 
pre-obtained consent. Because of the advance notice to the property owners and participants, all 

affected individuals will be well aware of the planned flight operations.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that 

are subject to the minimum safe altitude regulations. Finally, the successful safety record of the 

DJI sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer 

operating environments.

E. 14 C.F.R. § 91.121: Altimeter Settings

Real Help Inc seeks an exemption from 14 CFR 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because the 

sUAS does not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety

An equivalent level of safety will be achieved by following these procedures: 1. Real Help Inc 

will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. 2. 

Moreover, the PIC will use the GPS altitude indicator to constantly monitor the sUAS's height, 

thus ensuring operation at safe altitudes. 

F. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

Real Help Inc requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

 a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and

assuming normal cruising speed –

(1) During the day, to fly after that for at least 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The batteries powering Real Help Inc's UAS’s provide approximately 10-18 minutes of powered 

flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flights could not be 

conducted. Given the limitations on the sUAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a safety margin based on a reserve amount of 

battery life is needed.

Real Help Inc will not be conducting any sUAS flights at night. 

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the sUAS. All flights will be planned to terminate with no less 

than 25% reserve battery power still available. This restriction would be more than adequate to 

return the sUAS safely to its planned landing zone from anywhere in its confined area of 
operation even in the event of an unexpected occurrence. Operation of the sUAS with less than 

30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was intended 

to alleviate given the size and speed of the small UAS, and the proximity of the flight operation 

to the landing zone. Moreover, operation will be limited to controlled areas where only people 

and property owners, or official representatives will be allowed. 

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Real Help Inc also seeks an exemption from the maintenance inspection requirements contained 

in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating 

that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections...have discrepancies repaired as 

prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 

43 and these sections only apply to aircraft

with an airworthiness certificate, which the sUAS will not have. 

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the DJI User’s Manuals. The operator will ensure that the sUAS is 

in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. The operator is the person most familiar with the aircraft and best suited 

to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight 

operations will only take place in pre-designated areas for limited periods of time during daylight 

hours, creates less risk than that associated with conventional rotorcraft performing the same 

operation.

VI. PUBLIC INTEREST

Granting Real Help Inc an exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those propose in this petition. Real Help Inc would like to help facilitate 

safe integration of sUAS’s into mainstream USA in the following areas:

 • Agriculture and Conservation 

Real Help Inc would introduce and demonstrate to farmers of all types that the sUAS can 

aid commercial agriculture, land management and conservation efforts by assessing 

crops, mapping flood zones, measuring snow pack and more. The sUAS can fly pre-saved 

missions via the fully automated ground station, which allows for time-lapse photos of 

fields, crops and known land tracts. It also can accurately recreate the same pattern during 

all seasons, providing invaluable data for land and soil management. Using HD video, 

HD photos, and IR cameras allows for detailed analysis and recording. With photo 
rendering software, 3D maps and topography can be used in conjunction with time-lapse 

photos to create highly detailed maps for erosion, flood mapping and other critical aspects 

of land management. 

 • Real Estate 

The sUAS can be used in all areas of real estate, including agricultural, vacant land, 

commercial, residential and industrial properties. Using a sUAS, real estate professionals 

can create promotional videos, photos and unique shots that normal camera aspects 

cannot capture. The remote platform is great for new planning, zoning and large 

developments. Simple and easy-to-use video and photos allow for multiple height 

pictures and elevation views.

 • Movies and Videography 

Whether the shot requires unique views and expansive panning or extreme altitude with 

radical views, the UAS is designed to hold up under demanding conditions. Because of 

the autopilot feature with pre-designed mission management and R/C control interrupt, 

the pilot and camera operator can easily create the ultimate shot with HD video or HD 

still photos. When working close in on a closed set the hazards to the actors are greatly 

reduced due to the size of the sUAS.

 • News Gathering 

Similar to movies and videography, each news assignment may require a completely 

different shot or view of a scene. With budgets for traditional helicopter use being greatly 

reduced, the UAS is the perfect solution to allow for easy news gathering for a fraction of 

the cost. The sUAS can and will be operated in a safe manner away from the public, 

while the traditional helicopter must hovers over persons and property increasing the 

danger to individuals.

 • Fire and Rescue 

Real Help Inc would introduce and demonstrate to fire and rescue personnel the sUAS’s 

reliability and the capability to perform in extreme situations. The ability to offer real 

time HD and IR video facilitates placing personnel and equipment in the right places. 

Real Help Inc's mission is to assist governmental agencies safely into the NAS.

VII. Privacy

Real Help Inc knows that many individual have concerns about privacy from the operations of 

sUAS’s. Real Help Inc has created a privacy notice that informs residents, commercial property 

owners, churches, schools, and governmental organizations of our intent to conduct commercial 

drone operations in proximity to their property.

VIII. Federal Registry Summary
Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Real Help Inc seeks an exemption from the following rules:

14 CFR Part 61.113 (a) and (b); 14 CFR 91. 103; 14 CFR 91.113; 14 CFR 91.119; 14 CFR 

91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR; 91.409(a)(2); 14 

CFR 91.417(a) and (b).

Approval of this exemption request allows Real Help Inc to conduct commercial operations with 

small and lightweight unmanned aerial systems. Real Help Inc's vision is to enhance safety of 

sUAS operations in the NAS while reducing risk to the general public and property owners.

The DJI sUAS, weighing less than 25 pounds and powered by batteries, eliminates virtually all 

of the risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is 

transported to the designated mission area and set up there. The sUAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety, supporting the grant 

of the exemptions requested herein, including exempting the applicant form the requirements of 

several regulations and allowing commercial operations. These lightweight sUAS's operate at 

slow speeds, close tot he ground and in a safe and uncongested environment. As a result, they 

are far safer than conventional aerial survey and inspection operations conducted with fixed wing 

aircraft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned.

Kimberly Johnson, Owner/Petitioner

Real Help Inc

Cell Phone: 406-270-1269

Email: kimberly@getrealhelp.com

Thomas Johnson, Owner/Petitioner 

Real Help Inc 

Cell Phone: 406-890-8133 

Email: thomas@getrealhelp.com