**B randon Power, Realtor®, Commercial Pilot** **with multi -** **engine instrument rating**



## Section 333 Exemption Petition July 30, 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2);91.417(a)&(b) Dear Sir or Madam, I, Brandon Power, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Brandon Power, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Brandon Power, may operate my small ultra

-light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein I, Brandon Power, am a licensed Realtor within the State of Arizona and soon to be licensed in California, a licensed commercial pilot, and experienced as a Flight Service Specialist with Lockheed Martin; experienced in flying hobby helicopters for recreational purposes. I have added a hobby grade quad

-copter UASto my inventory equipped with a GoPro3+ Black camera with intent for aerial videography/cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the surrounding geographical layouts in the vicinity of their real estate locations. Ihope to augment real estate listing videos, following exemption and approval by the FAA, to enhance any and all academic research experience forthesecommunity locations. I have flown small RC electric helicopters for an extended period of time without incident. Committed to safety with each flight, my, Brandon Power’s, exemption request would permit operation of ultra

-light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. Such operations have been conducted in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing videos/photos. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I, Brandon Power, have personally instilled safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act tofurther safety protocols exclusive to lightweight UAS's specific to real estate video and

photography usage as I, Brandon Power, record flight data and other information gained through permittedflight operationsto sharewiththe FAAthrough any required FAA reportsto assist with future protocol and safety regulation. Granting my, Brandon Power’s, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific tothe use of UAS'sfor real estate/Realtor purposes. Further I, Brandon Power,will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below I, Brandon Power, respectfully request the grant of an exemption allowing me to operate ultra

-light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to specific requested locations solely for the purpose of real estate as well as enhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard. **I. Contact Information:** Brandon Power Brandon Power, PLLC PO Box 25648 Prescott Valley, AZ 86312 Office: (928)642

-3838 Mobile: (951)288

-9072 Email: brandonkpower@gmail.com **II**
. **The Specific**  **Sections of**  **Title 14**  **of the**  **Code of**  **Federal Regulations**  **From Which**  **Brandon Power**  **Requests Exemption are:** 14 CFR 21; 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). **III. The Extent of relief Brandon Power** **seeks and the Reason He Seeks Such Relief:** I, Brandon Power, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

-334, seeking relief from any currently applicable FARs operating to prevent me, Brandon Power, contemplated commercial cinematic, academic and other flight operations within thenational airspace system. The Reform Act in Section 332 provides for such integration of civil

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Brandon Power’s, ultra

-light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 andthereforethe integration of my ultra

-light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra

-light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft.Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS's;whether the UASwill be operated near airports or heavily populated areas; and, whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Brandon Power
. My UAS utilizes four (4) counter
-rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. I, Brandon Power, consider safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the GPS Mode for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost this UAS is designedtoslowly descend to point of takeoff

. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

-100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between five (5) to seven (7) minutes, with an altitude under one hundred fifty (150) feet. I, Brandon Power, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is nine (9) to twelve (12) minutes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exerciseto insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked/logged numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under differenttemperature and weather conditions. I also practice computerized simulated flights to maintain

adequate skills and response reflex time. All for the sake of safety.
I, Brandon Power, have taken the upmost extreme precautions to becomefullyfamiliarwith all controls and operations of my UAS.This includes personal instructionfrom individuals certified through Unmanned Vehicle University (www.uxuniversity.com)

. Ihave completed more than 25 hours total flight time as sole manipulator, including at least 10 hours logged using my personal UASthat was ofthe same make and model and of multirotortype
.These records are available for examination upon request. I, Brandon Power, am extremely cautious when operating my UAS/ultra

-light weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Brandon Power’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security. I, Brandon Power, am well aware and educated in the National Airspace System from both my rating as a commercial pilot as well as my experience as a Flight Service Specialist with Lockheed Martin. Because of the broad range of locations associated with aerial photography/videography, I am able provide detailed locations of any operation held within the National Airspace System. **IV. How Brandon Power’s**  **Request Will Benefit the Public as a**  **Whole:** Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through a potential catastrophic crash that many communities have or may possibly experience in the past with both civil and military aircraft

. Each potentially resulting in loss of life, and each with combustible fuel that can explode and burn on impact. Both medical and Police helicopters have made emergency hard landings within city limits. My, Brandon Power’s UAS pose no such threat since itssize and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hencethe passing ofthe Reform Act. Granting my, Brandon Power’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around any community associated with real estate transactions
. My ultra

-light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra

-light weight UAS crashing is far less than a full sizehelicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause

catastrophic devastation to the public. The public’s interest isfurthered by minimizing ecological and crashthreat by permitting aerial video/photo capture through my battery operated ultra

-light weight UAS
. Permitting me, Brandon Power, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthersthe economic impact for any community receiving or further acquiring growthfor companies looking to relocate or build intheir location of choice as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to these various communities
. **V. Reasons**  **Why Brandon**  **Power’s Exemption**  **Will Not**  **Adversely Affect**  **Safety or**  **How the**  **Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:** My, Brandon Power’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Brandon Power, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as ofyet undiscovered safety protocolsfor Realtorsthat can be embraced by various realtor associations for development in cooperation with the FAA. In addition I, Brandon Power, submit the following representations of enhancements to current aerial videography and photography for real estate: My UAS weighs less than 5 pounds complete with a small ultra

-light weight high quality GoPro 3+ Black camera; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operate for 5

-7 minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power;

 I pilot my UAS through remote control only by line of sight;
 My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;
 I actively analyze flight data and other sources of information to constantly update and enhance safety protocols through various recreational associations I’m affiliated with such as;  I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas;
 I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance;
 I utilize my knowledge as a licensed commercial pilot to analyze all airspace, rules, and regulations that may both promote safety and awareness for UAS operations
 I utilize my knowledge as a member of AMA to continue to update myself on future regulations within the UAS community that will further promote awareness, privacy, and safety I always obtain all necessary permissions priorto operation includingthefamiliarization

and use of Notices to Airmen (NOTAMS) which I have full knowledge of from my experience as a Flight Service Specialist with Lockheed Martin, as well as public organizations responsible for the safe operations of hobby

-grade UAS;
 I have procedures in place to abort flights in the event of safety breaches or potential danger. My, Brandon Power’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

-light weight UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential forfire or explosions is greatly diminished.Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom, which I am also familiar with and can utilize to increase distance promote a higher degree of safety. Accordingly, my UAS has been experimentally operatedforfamiliarization/competency andwill continue to operate at and above current safety levels. I have conducted the proper training, have utilized my experience and expertise as a commercial pilot, and performed scenariosthat detect and avoid hazards should any unknown situation occur that may adversely affect the safety of flight from my UAS. **C hecklists and Personal**  **Protocol s used for UAS operations:**  Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre

-flight preparation and during flight. The organization of such is as follows: Aerial Community and Real Estate Videos Date:____________________ Location: ___________________________________________________ Pre

-flight Inspection: Yes No Comment: _________________________________________________ Elements (circle) (circle)Comment Weather Good Fair Visibility Good Fair Wind Speed Low Medium Proximity to airport: _________________ (see attached map pinpointing approximate location of flight) Airport notified Yes No Date:_______________ Time: ______________ Phone Number: _______________________ Contact Name: ___________________________________Nearest major intersection: ______________________________________________________________

Proximity to medium traffic road: _________________________________________________________ Proximity to heavily traveled roadway road: _________________________________________________ Proximity to congested population: _______________________________________

_________________ Approx. Takeoff Time Approx. Landing Time Estimated Elevation Safety Concerns: Additional Comments: Unedited flight video/photos available for FAA upon written request within 180 days of flight: Yes No Safety for public on the ground aswell as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre

-flight preparation and during flight. **Pre -** **Flight:**

- Check batteries with voltage meter to insure fully charged and ready for use.

- Inspect batteries for damage or leakage that may affect proper operation.

- Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageable/uncontrolled flight.

- Check weather forecasts for wind advisory or other conditions that my impact flight.

- Consult five (5) mile radius map for airport vicinity.

- Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information. Inspect flight area for:

- vicinity of public safety helipads/heliports

- vicinity of medical helipads/heliports

- vicinity of light poles

- vicinity or utility wires

- vicinity of trees

- flocks of birds that may cause interferenceand potential flight impact

- vicinity of any elevated obstructions that may pose potential flight hazard

- vicinity of roadways with moderate to heavy traffic that can be distracted

- public gatherings that may attract viewers

- optional point of control for bestvisual site of UAS while in flight Takeoff and landing

- inspect area for best and safest point of takeoff and landing

- if in a subdivision or area that is within 150 feet of a residential street, post warning sign(s)/stand(s) "Attention Aerial Photography In Progress

- Remain Back 150 Feet " **In -** **flight:**

- takeoff and land from same location

- remain alert to birds, sound or aircraft, curious public, and approaching vehicles

- do not allow anyone to engage in conversation or distract the remote control pilot

- restrict flight to minimal elevation sufficient to acquire desired results

- remained prepared for emergency landing at all times

- pay attention to flight time

- if possible set a timer as a safety alert- land UAS and shut down propulsion immediately following landing

**Post -** **flight:**

- disconnect battery to prevent accidental activation of propulsion system

- secure UAS in a safe location

- remove all warning signs from public access areas **Emergency or Suspected Hazard:** Immediate land UAS at safest and closet ground location in the event that:

- manned aircraft is heard or seen in vicinity of flight

- there is a public gathering within established safety boundary wanting to observe flight

- pilot is being distracted from focusing on flight and safety

- sudden change in weather (wind bursts)

- sudden increase in vehicular traffic in vicinity of flight

- birds enter into proximity of flight

- any sudden unsafe event that can cause collision, distraction or interruption of control **VI. A Summary The FAA May Publish in the Federal Register:**  A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Brandon Power’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Brandon Power’s, current and projected UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Brandon Power

. B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked accordingto certain specifications. My UAS are, by definition, unmanned.Theytherefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two
-inchlettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering

requirement. Regardless, I will mark my UAS in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotterwiththe UAVwill seethe markings.The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a)& (b), private pilots are limited to non-commercial operations. I, Brandon Power, can achieve an equivalent level of safety because I obtain a Commercial Pilot’s license with a Multi

-Engine Instrument Rating as well as a Class I FAA Medical, and I, Brandon Power, am familiar with the Notice to Airmen Publications required for such activities that further place regard on safety due to my experience as an employee with Lockheed Martin as a Flight Service Specialist. The risks attendedtothe operation of my UAS isfar less thanthe risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Brandon Power, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Brandon Power, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above

-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.

. . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to the UAS that I, Brandon Power, possess. However, as a safety precaution I thoroughly inspect my UAS before and after each flight, immediately aborting any activity ifany adverse factoreffecting the safety of persons or property arises
. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relationto FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Brandon Power’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. Asthere are no pilots or passengers, and giventhe size ofthe UAS, this Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining all records of flight and maintenance, as well as any manual associated with the construction of the UAS. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved and documented. **In summary, Brandon Power** **seeks an exemption from the following Regulations:**  14 C.F.R. 21, subpart H; 14 C.F.R.45.23(b); 14 C.F.R. §§ 61.113 (a)& (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a)& (b) to commercially operate my, Brandon Power’s, small unmanned vehicle/lightweight unmanned aircraftvehicle in community awareness and real estate operations, and to develop economic platformsfor real estateto enhancethe experience ofthose seekingto relocateto a new geographical area or community that the UAS will offer better recognition and awareness for

. Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel, which poses potential risk to the public. Granting my, Brandon Power’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. I, Brandon Power, have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Brandon Power’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Brandon Power’s, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Brandon Power, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large as I continue to purse my passion for aviation bothas a UAS operator and a commercial pilot. Respectfully submitted,

Brandon Power Brandon Power, PLLC PO Box 25648Prescott Valley, AZ 86312

(951)288

-9072 brandonkpower@gmail.com **Details of the UAS to be used for photography/videography operations:** This is an actual image ofthe UASto be used. Specifications and operation manuals arewithin

thedocumentation to follow this exemption petition. **Logbook Documentation:**