U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington DC 20590

Dear Sir or Madam:

J. Michael Tate (private pilot, single engine land, cert # 3712268) dba AirVue hereby applies for an exemption from the listed Federal Aviation Regulations and any other rules necessary to al low operation of a small hobby

- s ized (approximately 5 lbs.) unmanned aircraft (UAS) in order to produce aerial video of marketed real estate at a height of 400 feet or less. The purpose of using the UAS is to gather video documentation of selected marketed real es tate in order to safely provide interested parties additional information about a selected property here

- to

- for unattainable before pur chase. Video will safely show in terested clients properties vegetation/obstructions, boundaries, roof problems, overall curb appeal, water/stream issues, general information on topography, and a sense of where the property sits in relations to roads, traf fic, and construction. Judicious use of the UAS will greatly assist prospective buyers in selecting property while posing no safety or privacy threat to the general public, the participating inspection parties, or non

- participating parties.

This reques t is similar to previous Grants of Exemption Nos 11062, 11109, 11112 and 111213 where the exemption was granted in the public interest.

1. J. Mich ael Tate dba AirVue 200 Christina Lane Kingsland, GA 31548 FAX (912) 882 7514 Phone (912 ) 322 2598 Email: tatej@tds.net

2. The specific section or sections of 14 CFR from which you seek an exemption:

Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Avia t i on Regulati ons, Seeking Exemption from 14 C.F.R. Part 2 1 Subpart H; 14 C.F.R. & 45.23 (b); 14 C.F.R. & 45.27; 14 C.F.R. && 61.113(a) and (b); 14 C.F.R. & 91.119(c); 14 C. F.R. & 91.121; 14 C.F.R. & 91.151(a); 14 C.F.R. & 91.405(a); 14 C.F.R & 91.407 (a)(1) ; 14 C.F.R. &&91.409 (a) (1) and (2); 14 C.F.R. && 91.417 (a) and (b).

3. The extent of relief you seek and the reason you seek relief:

J . Michael Tate dba AirVue am request s relief and exemption from listed Federal Aviation Regulations and any other applicable rules in order to all of the use of a small unmanned aircraft system (UAS as defined by the US Congress in Section 331, PL 112

- 95, 2014; “6) SMALL UNMANNED AIRCRAFT. The term “small unmanned aircraft” means an unmanned aircraft weighing less than 55 pounds. “ to conduct unmanned reconnaissance of specific properties toprovide additional information to prospective buyers regarding their proposed purchase. The

UAS will fly no higher than 400 feet above a selected property and will not infringe on the property r ights of adjacent or nearby properties. The UAS will remain inside the selected property and public by ways. All commercial UAS flights will be scheduled with the owner/representative and a signed document will be required for flight/photography. Every day thousands of properties are bought and sold with improper regard to topography (especially important in lowlands in SE Georgia). UAS flights will provide prospective owner wit h close

- up roof inspection, hidden flaws in design, or outright damage unava ilable from the ground . UAS flights reveal the character of the sele cted property with regard to other general property in the area thus providing the prospective buyer with otherwise unattainable information (short of more dangerous manned air craft fligh t). UAS flight might reveal unseen and unsightly industrial blight just out of sight of selected property that would be otherwise/unlikely attainable. UAS flight will reveal the selected property against a backdrop of where it (home or business) sits on the property and how it “fits in” to natural vegetation or topography. UAS would provide the platform for pictures/video on properties where dense underbrush or other dangerous obstacles might be detrimental to the health and safety of the investigating i ndividual. In short, t he use of a UAS would eliminate the risk of photographers who attempt to capture high resolution pictures of particular conditions surrounding a selected property.

4. How your request would benefit the public as a whole:

a. Safety of real estate personnel is a paramount consideration. Persons attempting to gain high

- resolution video/p ictures are at risk of injury by attempting to capture images outside their safety zone. i.e. Pictures of risky marsh land or swamps. Pictur es requiring addition al elevation to gain perspective. Pictures of roofs , porches, lakes, docks or vegetation relevant to the sale of the property. Pictures involving open water settings requiring boats/docks. The easy production of otherwise risky photography minimizes impacts on the general public.

b. High resolution video/photography from UAS can be instantly transmitted to interested parties for immediate resolution of pre

- purchase questions thus simplifying and shortening the decision making process for everyone. Conf lict resolution c ould be minimized for the general public

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c. Aerial photography can be accomplished quickly and easily with little or no impact on the surrounding neighborhoo d. Modern UAS utilizes sufficiently quiet motors that unless nearby and outside, the general population would be unaware of activity. Given the amount of data that can be captured in under 12 minutes, UAS offers immense advantage to conventional data

co llection at minimal interference or inconvenience to the general public.

d. Given the history of buying and selling properties in the United State s, UAS will ultimately benefit a large proportion of the general public. As technology advances, the ab ility of UAS to enhance the buying and selling of property will touch everyone. The real estate market benefits daily from new technology. UAS of every property will ultimately be as common asphotos from inside the house. The general population will be nefit from these advances by

having greater knowledge before the sale and a clearer understanding of what they are buying.

e. UAS could serve as the ultimate guarantor when property is destroyed by disaster. Insurance agencies c ould have the necessa ry proof of condition of a property...pre

- disaster. Claims could be resolved quicker and recovery could be accomplished quicker. An elevated before and after photo of a demolished roof could be resolved immediately given sufficient high resolution proof.

5. Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule.

Safety would be th e prime motivating factor . If the mission to gather information for prospective real estate buyers and sellers cannot be accomplished safely th en the mission must be aborted. Realizing that while new technological implementation can not be adopted with absolutely no risk, given the below protocols, the implementation of UAS for the R ealty /Surety market can be accomplished with minimal risk and would be safer than existing methods for procuring high resolution video/images suitable for public use

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a. The UAS would be operated only by me, James Michael Tate, a private pilot, certi ficate number 3712268 issued 10 August 2013. I am fully certified to own and operate a single engine land aircraft. I have a comprehensive knowledge of aviation requirements including airspace restrictions, checklists requirements, and meteoro logical con ditions required to flight. I am fully prepared to exercise mandatory safety policies with regard to the safe operation of UAS.

b. All operations will utilize a visual observer in addition to pilot

- in

- command (PIC).

c. The visual observer and PIC will be in constant verbal contact at all times during flight operations.

d. As PIC, I will wear a high visibility safety vest identifying me as the pilot of the UAS.

e. Height limitations will be enabled on the UAS to limit the aircraft from ascending higher than 400 feet on any occasion. Though unlikely to occur, special altitude consideration will be consider ed in areas of airfield departure/arrival . In these extre mely limited cases considered near airports, the airport FBO will be c ontacted for a go/no go flight . No flights will occur on airfield property.

f. Property owners will sign a consent form prior to UAS operations. Non

- participating
pe rsons will not be allowed vulnerable inside property confines during the flight.

g. The UAS will not fly near obstructions to flight. i.e. in

- flight aircraft , road traffic, power lines, towers (or guywire).h. The UAS will always be in line of site with the PIC and the visual observer. Over t he

ground speed will be limited due to the nature of the mission (video/still images). All flights will be in accordance with manufacturers specifications with all flight s carefully choreographed beforehand from beginning to end.

i. The UAS wil l be less than 5 lbs and will not ex ceed ground speeds of 30 knots.

j. The UAS will not carry any explosive material or flammable liquids.

k. Each UAS flight will end at 20 minutes or less or when the battery indicates 25% remaining time (whichever occurs first).

l. The UAS flight will be preceded by an in

- depth pre

- flight checklist and follow all manufacturer protocols. Manufacturer manual will always be readily available and the operation manual will be strictly adhered to.

m. A logbook will be maintained for e ach flight including the duration, location, and anomalies for the flight.

n. A take

- off and landing zone will be designated prior to each flight sufficiently removed from obstructions in order to obtain stable flight during critical operations.

o. Radio frequenc ies will comply with the FCC.

p. The UAS wi ll have J. Michael Tate dba AirVue contact information and the federal exemption number prominently displayed.

q. UAS flights will be conducted during daylight hours under visual met eorological conditions. i.e. not operated less than 500 feet below a cloud, less than 2000 feet horizontally from a cloud, or less than 3 miles visibility.

r. J. Michael Tate dba AirVue will maintain a $1,000,000 liability insurance policy while operating the UAS.

s. In accordance with the manufacturer’s operating manual, UAS the PIC will perform extensive pre

- flight checks prior to each flight to ensure the UAS is functioning properly. In the event that the UAS fails flight check, the UAS will be grounded until it complies with manufacturer specifications and deemed safe to fly.

t. The UAS will have a flight termination option and an automatic return to preselected landing zone should communications be lost.

These safety protocols ex ceed the FAA safety rules published in the Model Aircraft Operations Limits in the FAA Modernization and Reform Act of 2012.6. A summary we can publish in the Federal Register stating

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a. The rule from which you seek the exemption: and b. A brief description of the exemption you seek.

J. Michael Tate dba AirVue is seeking exemption from : Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. & 45.23(b); 14 C.F.R. & 45.27; 14 C.F.R. && 61.113(a) and (b); 14 C.F.R. & 91.119(c); 14 C.F.R. & 91.121; 14 C.F.R. & 91.151(a); 14 C.F.R. & 91.405(a); 14 C.F.R & 91.407(a)(1); 14 C.F.R. &&91.409(a)(1) and (2); 14 C.F.R. && 91.417 (a) and (b).

A brief description of the exemption I seek is as follows:

I seek exemption from the above listed rules. I will adhere to much more stringent safety measures previously described by the Model Aircraft Operations Limits according to the FAA Modernization and Reform Act of 2012. Many, if not most, of the rules don’t apply to the UAS since no pilot or passengers can be carried and the UAS to be used is 5 lbs or less. The UAS will not carry flammable liquid fuels or explosive material since it is powered by batteries. The small size and limited carry capacity of the UAS I desire limits its purpose primarily to functions such as carrying a light weight camera for short flights of 20 minutes or less. This camera capacity is the sole func tion that I seek to obtain. I propose to utilize the camera function to augment the Real Estate Market by providing high resolution video and still photography of marketed properties. These still shots and vide o are invaluable for the purchaser of real e state since they provide additional information to the buyer that would here

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- fore not have been available except perhaps by manned aircraft with exceptional telephoto lenses. The UAS technology with its ability to quickly, easily, and safely fill this void is, in many occasions, near priceless for potential buyers. Given the safety parameters limiting its use (i.e qualified operator, a visual observer, line of site operations, altitude limitations, designated take off and landing area, return home func tion in the event of communications loss, speed restrictions, short duration of flight, light weight, no flammables, and other restrictions I have delineated ) this new technology will provide otherwise unattainable product and prove to be safer than any ot her known information gathering method available today.

This exemption request is similar to the previously granted exemptions 11062, 11109, 11112 and 11213where the exemption was granted in the public interest.

7. Any additional information, views, or arguments available to support your request.

Flight platform is based on the accepted industry standard DJI Inspire 1, model FC350 supporting a high resolution camera providing 4K video and 12 megapixel resolution. A full description and s pecification ca n be found at WWW.dji.com /product/inspire/spec.8. If you want to exercise the privileges of your exemption outside the U.S., you must state the

reason.

I do not wish to exercise the privilege of my exemption outs ide the U.S.

Respectfully submitted,

J. Michael Tate Dba AirVue 200 Christina Lane Kingsland, GA 31548 Phone 912 882 7514 Cell 912 322 2598 Fax 912 882 7514 Email tatej@tds.net