US Department OfTransportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

October 27, 2015 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the 

reform act) and CFR Part 11, Real Estate Gallery LLC, owner and operator of Small 

Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation 

Regulations (FAR) listed below so that Real Estate Gallery LLC may operate UASs 

commercially in airspace regulated by the FAA, as long as such operations are 

conducted within and under the conditions outlined herein or as maybe 

established by the FAA as required by Section 333. 

Real Estate Gallery LLC is co-owned by Sherri Anderson and 

William Anderson. Both have Georgia Drivers licenses. Mrs. Anderson is a licensed 

Real Estate Agent. The proposed exemption is to operate the PHANTOM 3 quadcopter unmanned aircraft system (UAS) to conduct aerial videography and 

cinematography including real estate listing picture and videos under 91.119 (d) (1 ). 

Request below is added to FAA-2015-0353 due to the FAA new proposal, DOT and 

FAA Propose New Rules for Small Unmanned Aircraft Systems, published on the FAA 

website on February 15, 2015. 

As described below, the requested exception would permit the operation of light 

weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions 

for commercial use by Real Estate Gallery LLC, enhancing safety and 

fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibility 

to" establish requirements for safe operation of such aircraft systems in national 

airspace systems." Section 333(c), of the Reform Act. 

Real Estate Gallery LLC's UAS is a rotorcraft weighing less than 55 

pounds including payload. (The DJI Phantom 3 Quad Copter) It operates at a 

speed less than 50 knots and has the capability to hover and move in the vertical 

and horizontal plane simultaneously. It has an auto return mode that can be 

activated from remote control or is automatic when battery power is under 25%, if 

signal is lost between remote control and UAS or multiple GPS signals are lost. 

The UAS will operate within the line of sight with in a protected flight area as 

described below and at 200 feet AGL or less with an observer located close at 

hand as to make voice communication possible. These operations will not create 

a hazard to users of the nation airspace, public nor the environment. 

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Real Estate Gallery LLC respectfully requests the grant of an exception 

to the following specific sections of the Title 14 Code of Federal regulations 

allowing it to operate lightweight UASs for commercial use, 

14 CFR 21 , subpart H, 14 CFR 45.23 (b) 14 CFR 91 .7 (a), 91 .9 (b) (2) 

91 .103 (b), 91 .109, 91.119, 91 .121,91.151,(a), 91.203(a) 

&(b),91.405(a),91.407(a)(1), 91.409(a)&(b). 

Real Estate Gallery LLC submits this application in accordance with the 

Reform Act , 112 P .L 95 331-334, seeking relief from any currently applicable 

FAR'S operating to prevent Real Estate Gallery LLC future commercial 

use of small UASs to operate in the national airspace system as described 

below. The reform Act section 332 provides for such integration of civil 

unmanned aircraft into our national airspace system as it is in the public's interest 

to do so. Real Estate Gallery LLC UAS meets the definition of "small 

unmanned aircraft" as defined in Section 331 and therefor the integration of 

these UASs are expressly contemplated by the Reform Act. Real Estate Gallery LLC 

would like to operate its light weight UAS prior to the time period by 

which the Reform Act requires the FAA to promulgate rules governing such 

aircraft. 

The Reform Act directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in national airspace 

before completion of the rule making required under Section 332 of the reform 

Act In making this determination, the Secretary of Transportation is required to 

determine which UASs do create a hazard to users of the national airspace 

system or the public or pose a threat to national security in light of the following: 

The UASs size, speed, weight and operational capability 

Operation of the UASs in close proximity to airports and populated areas 

Operation of the UASs within visual line of sight of the operator 

Reform Act 333(a). If the secretary determines that such vehicles "may operate 

safely in National Airspace System, the secretary shall establish requirements for 

the safe operation in national airspace. 

Real Estate Gallery LLC will operate rotorcraft weighing less than 55 lbs. 

and operate at speeds less than 50 knots and have the capability to operate in 

the vertical and horizontal plane simultaneously. The UAS will operate only 

within the line of sight of the operator within a protected flight area and at 200 

feet AGL or less. These will not present a hazard to the national airspace nor the 

public. 

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The very small nature of these UASs combined with the safe guards presented 

below, will allow for the safe operation greater than that envisioned by Congress 

for the FAA to establish and by exemption allow commercial operations of UASs 

to commence immediately. Also due to the si.ze of UASs and the areas and 

altitudes they will operate. approval of this exception presents no national security 

issues and absolutely minimal safety concerns which have been mitigated 

through our rigorous risk management process. Given the clear direction given in 

Section 333 of the Reform Act, the authority contained in the Federal Aviation 

Act, as amended, the strong equivalent level of enhanced safety, reduced 

emissions utilizing UASs verses traditional aircraft as well as the economic 

impact of greatly reducing the cost of aerial photography thereby benefiting the 

greater public's interest. Accordingly, the applicant requests that the FAA grant 

the requested exemption without delay. 

The following will be considered as the binding limitation on operations of Real Estate 

Gallery LLC. 

1. Flights will only occur in the day time hours, 

2. Flights will be operated in the visual line of sight of the operator/photographer in 

charge (PIC) and Visual Observer.(VO) 

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe 

for flight" by manufacturers recommendations, 

4. The UAS will weigh less than 5 lbs., 

5. Flights will be operated at 200 feet AGL or less. 

6. Crew will be at a minimum of operator (PIC) and an visual observer and/or camera 

operator(VO), 

7. PIC and crew will remain in contact during the flight operation, 

8. The PIC/UAS operator will perform a check of the flight area and make certain of 

the safety of all persons in the area. 

9. Consent will be obtained from all persons with in the video capabilities of the 

units to further reduce the chance of violating anyone's privacy. 

10. All required FAA clearances, will be obtained and distances from airports 

strictly observed. 

11. All UAS will have the capability to return automatically to the operator in a safe 

manner with the auto return function checked and working. 

12. Flights will only operate in VFR conditions. 

13. UAS has a function on the control to tell operator the distance away from the 

operator and its battery power remaining. 

14. Flight team will communicate by voice and the use of two-way radio if the area 

is too big to hear voice from all team members. 

15. When operating over or near a body of water the UAS will be equipped with 

flotation devices so that recovery can be made as to prevent lithium battery 

exposure to the water table. 

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91 .7(a), 91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

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procurement of necessary certificates in relation to FAR 91.203(a)(1). The site, 

weight and defined area of operations for Real Estate Gallery LLC UAS 

flights permits exception from Part 21 because they meet 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 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UASs from airworthiness certificates in consideration 

of weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. Real Estate Gallery LLC meets or exceeds each 

of these elements 

As of March 23, 2015 the FAA has stated that it will automatically grant a 

"blanker COA for flights at or under 200 AGL to any UASs operator with a 

section 333 exemption. 

14 CFR 91 .203(a&b) provides for carrying of civil aircraft certifications and 

registrations. These are inapplicable for the same reasons stated above. Any 

certifications and registration information will be maintained at the corporate 

address. 

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

FAR's this regulation is inapplicable. 

14 CFR 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 

The FAA has previously issued exemptions to this regulation in Exemptions No's 

8607,8737,8738,9299,9299A,9565,9565B,1 0167,10167 A,1 0602,10700, 11138, 12975, 

13056 12985 and 32827. Based on the above exemptions being grant for DJI Phantom 

products under the same or similar conditions, this exemption is respectively requested 

to be approved as well. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of 

civil aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. Real Estate Gallery LLC will only operate its UAS at or below 

200AGL. It will be operated on a defined AOR that has been carefully 

reviewed for hazards and minimizes the presence of any persons not essential for 

these operations. Flights will only be over private property that the owner has 

consented and all persons within this video area also give consent for this filming. 

Compared to flight operations of conventional and traditional aircraft or rotorcraft 

weighing far more than 50 lbs., operating below 500 AGL with flammable fuel, 

UASs operations present a far smaller risk to the public. 

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Approval of these 333 Exemptions allowing commercial operations of small UASs 

in the service of aerial photography will greatly enhance safety by reducing the 

overall risk associated with traditional aircraft. Traditional aerial photography 

requires large aircraft with flammable fuel to fly in close proximity of populated 

areas and people in general. With the use of small UASs of 55 lbs. or less, battery 

operated and fling below 200 feet AGL. the risk of injury to people on the ground or 

the crew has been reduced or almost erased. The granting of the use of these 

small UAS by Real Estate Gallery LLC will give the people and business 

another avenue to express themselves and to have a video record to share with 

clients, family and or friends. 

Granting Real Estate Gallery LLC the above exemption will allow for the 

expansion of UAS systems into the Mure for the safe conduct of free enterprise 

and the enjoyment of the masses. 

Real Estate Gallery LLC, respectfully requests the FAA grant its exception without 

delay. The FAA has the authority to issue the exemption sought by Real Estate Gallery 

LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT). 

Si cerely, 

~,..r,u.-u.. ~ lf-- Sherri Anderson 

Real Estate Gallery LLC 

Post Office Box 1408 

Cumming, Georgia 30028 

678-513-5124 

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