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 operato r 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 ope rate UASs commercially in airspace regu lated 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 Ande rson and William Anderson. Both have Georgia Drivers licenses. Mrs

. Anderson is a licensed Real Estate Agent. The proposed exe mption is to operate the PHANTOM 3 quad
copter 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 proposa l, 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 (l ess than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by Real Estate Gallery LLC , enhancing safety and fulfilling the Secretary ofTransportation 's (the FAA Administrato r's) responsibility to" establish requirements for safe operation of such aircraft systems in national airspace systems." Section 333(c), ofthe 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 multip le GPS signals are lost. The UAS will operate within the line of sight with in a protected fl ight 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 northe environment.
1Real Estate Gallery LLC respectfully requests the grant of an exception to the following specific sections ofthe Title 14 Code of Federal regulati ons 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 th is 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 govern i ng such aircraft. Th e 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 , th e 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 ofthe following : The UASs size , speed , weight and operational capability Operation ofthe UASs in close proximity to airports and populated areas Operation ofthe UASs within visual line of sight ofthe operator Reform Act 333(a). Ifthe secretary determines that such vehicles "may operate safely in National Airspace System , the secretary shall establish requirem ents 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

.

2The 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 wi ll only occur in the day time hours, 2

. Flights will be operated in the visual line of sight ofthe 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 (P IC) 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 ofthe 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 ofthe 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 oftwo-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
3procurement of necessary certificates in rel ation 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 becau se they meet an equivalent level of safety pursuant to Section 333 ofthe 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 ofthe Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consid e r ation ofweight, s ize, speed, mane uverability and proxim ity to areas such as airports and dense populations. Real Estate Gallery LLC meets or exceeds each ofthese elements As of March 23 , 2015 the FAA has stated that it will automatically grant a "blanker COA for flights at or under 200 AG L to any UASs operator with a section 333 exemption . 14 C FR 91

.203(a&b) provides for carrying of civil aircraft certifications and regi strations. These are inapplicable for the same reasons stated above. Any certifications and registration information will be maintained at the corpor ate address

. 14CFR91 .7 (a) prohibits the operation of an aircraft without an airwo rth iness certificate. As no such certificate will be applicable in the form contemplated by FAR's this regu lati on is inapplicabl e. 14 CFR 91

.9(b)(2) requires an aircraft flight manual in the aircraft

. As there are no pilots or passengers , and given th e size ofthe 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, 1 2975, 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 we ll. 1 4 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 200AG L. It will be operated on a defined AOR that has been carefully reviewed for hazards and minimizes th e presence of a ny persons not essential for these operations. Flights will only be over private property that the own er has consented and all persons within thi s video area also give consent for this filming. Compared to flight operations of conventional an d traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with flammable fuel , UASs operations present a far smalle r risk to the public.

4Approval ofthes e 333 Exemptions a llowing comme rcia l operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associ ated with traditi onal aircr aft

. Trad itiona l aerial photogr aphy r equires 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 ope rated and fling below 200 feet AGL. the risk of injury to people on th e ground or the crew has been redu ced or almost erased. The granting of the use of these small UAS by Real Estate Gallery LLC w ill 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 th e above exemption will allow for the expansion of UAS systems into the Mure for the safe conduct of free enterprise and the enjoyment ofthe 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 Rea l Estate Gallery LLC Post Office Box 1408 Cumming, Georg ia 30028 678-513-5124

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