Brandon 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 UAS to 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. I hope to 

augment real estate listing videos, following exemption and approval by the FAA, to enhance 

any and all academic research experience for these community 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 to 
further 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 permitted flight operations to share with the FAA through any required FAA reports to 

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 

to the use of UAS's for 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 the 
national 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 and therefore the 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 of the UAS's; whether the UAS will 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 designed to slowly 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 exercise to 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 different 
temperature 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 become fully familiar with all 

controls and operations of my UAS. This includes personal instruction from individuals certified 

through Unmanned Vehicle University (www.uxuniversity.com). I have completed more than 

25 hours total flight time as sole manipulator, including at least 10 hours logged using my 

personal UAS that was of the same make and model and of multirotor type. 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 its size 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, hence the passing of the 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 size 
helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause 

catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat 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 furthers the economic impact for any community 

receiving or further acquiring growth for companies looking to relocate or build in their 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 of yet undiscovered safety protocols for Realtors that 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 prior to operation including the familiarization

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 for fire 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 operated for familiarization/competency and will 

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 scenarios that 

detect and avoid hazards should any unknown situation occur that may adversely affect the 

safety of flight from my UAS.

Checklists and Personal Protocols 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 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.

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 interference and 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 best visual 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 according to certain specifications. My UAS are, by definition, unmanned. They therefore do 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch 
lettering 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 spotter with the UAV will see the 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 attended to the operation of my 

UAS is far less than the 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 if any adverse 

factor effecting 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 relation to 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. As there are no pilots or passengers, and given the size of 
the 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 aircraft vehicle in community awareness and real estate operations, and to develop 

economic platforms for real estate to enhance the experience of those seeking to relocate to 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 both as a UAS operator and a commercial pilot.

Respectfully submitted,

Brandon Power

Brandon Power, PLLC

PO Box 25648
Prescott 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 of the UAS to be used. Specifications and operation manuals are within 

the documentation to follow this exemption petition.

Logbook Documentation: