Request	for	Section	333	Exemption	

January	31,	2016

Christi	M	Conroy

1945	Windy	Leaf	Court

Virginia	Beach,	VA	23456

C:	757-510-8123

C:	757-777-6226

I,	Christi	M	Conroy	am petitioning	the	Federal	Aviation	Administration	for	

exemption	in	accordance	with Section	333	of	the	FAA	Modernization	and	Reform	

Act	of	2012	for	Aviation	Unmanned	to	perform	Aerial	Photography	by/for	Christi	M	

Conroy, Associate	Broker	representing	Conroy	Homes	of	Berkshire	Hathaway	Home	

Services	Towne	Realty.	The	main	use	of	the	UAS	would	be	taking	real-estate	videos	

and	photos for	marketing	purposes.	The	UAS systems	that	I	will use;	is	the	Yuneec	

Typhoon	Q500	4K	and	will	be	referenced	in	this	document.

Discussion:

The	exemption	will	allow	me	to	operate	my Yuneec	Q500	4K	quad-copter

unmanned	aircraft	system	(UAS)	to	conduct	aerial	photography	and	videography	in	

Hampton	Roads,	Virginia,	to	augment	real	estate	listings to	show	boundaries	of	

properties	as	they	relate	to	the	natural	and	man	made	surroundings.

Granting	an	exemption	will	not	adversely	affect	safety.	I	will	be conducting	

operations	over	client	owned	or	controlled	land,	solely	during	daylight	hours,	at

altitudes	well	below	that	which	would	pose	a	risk	to	other	aircraft.	The	safe	

operations	of	this	UAS,	weighing	less	than	55	lbs.,	will	be	conducted	in	the	strict

conditions	outlined	as	follows and	will	provide	an	equivalent	level	of	safety	

supporting	the	grant	of the	exemptions	requested,	including	333	Aircraft	Exemption	

Status.	My	lightweight	aircraft	will	operate	at	slow	speeds,	close	to	the	ground,	and	

in	a	controlled	environment.	All	operations	will	be	within	visual	line-of-sight	(i.e.,	no	

more	than	approximately	0.2 miles	from	the	manipulator	of	the	controls,	or	pilot	in	

command	(PIC) and	less	than	400	ft	above	ground	and	never	directly	above	persons	

or	public	areas. Additional	safety	features	on	the	Yuneec	Typhoon	Q500	include	

return	to	home	and	low	battery	auto	return	and	landing.

Pre-flight	inspection	would	be	conducted	in	accordance	with	the	owner’s	manual	as	

well	as	surveying	the	local	area	for	hazards	to	flight	and	weather	conditions.

The	PIC	will	be	myself	and	I	have	a	minimum	of	30	hours	of	experience.	I	have	

personally	obtained	ten	hours	of	flight	time	in	a	civilian	aircraft.	In	addition, my	UAS	

flight	and	safety	training	has	been	provided	by	my	husband,	Kevin	Conroy,	who	is	a	

retired	Marine	Corps	helicopter	pilot.	He	has	flown	over	4500	mishap	free	flight	

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hours	and	was	designated	an	Instructor	Pilot,	training	over	150	new	pilots	in	

helicopter	flight	during	his	career.		He	is	an	expert	in	FAA	flight	regulations	and	

flight	safety. He	is	currently	a	government	civilian	service	employee	at	the	Naval	

Safety	Center,	Norfolk,	Virginia,	providing	safety	analysis	for	the	Navy.

Sections	for	requested	Exemption: Responses	provided	in	italics

Section	91.7(a)	prescribes	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	

an	airworthy	condition.	

There	are	no	specifications	on	what	makes	a	UAS	airworthy,	during	the	preflight	

checks	all	propellers	and	mountings	are	checked	for	damage	and	operation.	

Section	91.7(b)	prescribes	that	the	pilot	in	command	of	a	civil	aircraft	is	

responsible	for	determining	whether	that	aircraft	is	in	condition	for	safe	flight	and	

that	the	PIC	shall	discontinue	the	flight	when	un-airworthy	mechanical,	electrical,	or	

structural	conditions	occur.	

Preflight	checks	shall	be	completed	before	lift	off	and	continuous	monitoring of	inflight	systems	shall	be	performed	from	the	ground	station	from	the	moment	of	

powering	up	for	preflight	until	shutting	down	at	the	end	of	the	operation.

Section	91.9(b)(2)	prohibits	operation	of	U.S.-registered	civil	aircraft	unless	there	

is	available	in	the	aircraft	a	current	approved	Airplane	or	Rotorcraft	Flight	Manual,	

approved	manual	material,	markings,	and	placards,	or	any	combination	thereof.	

Supplemental	materials	will	include	equipment	and	flight	manuals	issued	with	the	

UAS.

Section	91.119 prescribes	that,	except	when	necessary	for	takeoff	or	landing,	no	

person	may	operate	an	aircraft	below	the	following	altitudes:	

(a)	Anywhere.	An	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing	

without	undue	hazard	to	persons	or	property	on	the	surface.	

(b)	Over	congested	areas.	Over	any	congested	area	of	a	city,	town,	or	settlement,	or	

over	any	open	air	assembly	of	persons,	an	altitude	of	1,000	feet	above	the	highest	

obstacle	within	a	horizontal	radius	of	2,000	feet	of	the	aircraft.	

(c)	Over	other	than	congested	areas.	An	altitude	of	500	feet	above	the	surface,	

except	over	open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft	may	

not	be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.	

(d)	Helicopters,	powered	parachutes,	and	weight-shift-control	aircraft.	If	the	

operation	is	conducted	without	hazard	to	persons	or	property	on	the	surface—

(1)	A	helicopter	may	be	operated	at	less	than	the	minimums	prescribed	in	

paragraph	(b)	or	

(c)	of	this	section,	provided	each	person	operating	the	helicopter	complies	with	any	

routes	or	altitudes	specifically	prescribed	for	helicopters	by	the	FAA;	and	

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(2)	A	powered	parachute	or	weight-shift-control	aircraft	may	be	operated	at	less	

than	the	minimums	prescribed	in	paragraph	(c)	of	this	section.	

Due	to	altitude	limitations	and	the	desire	to	avoid	passenger-carrying aircraft	it	is	

requested	to	maintain	a	maximum	ceiling	of	400’	with	typical	heights	being	below	that	

dependent	on	angles	and	shots	for	photographic	use.

Section	91.405(a)	requires,	in	pertinent	part,	that	an	aircraft	operator	or	owner	

shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	of	the	same	part	and	

shall,	between	required	inspections,	except	as	provided	in	paragraph	(c)	of	the	same	

section,	have	discrepancies	repaired	as	prescribed	in	part	43	of	the	chapter.	

There	are	no	current	maintenance	requirements	for	UAS	of	this	type.

Section	91.151(a)	prescribes	that	no	person	may	begin	a	flight	in	an	airplane	under	

VFR	conditions	unless	(considering	wind	and	forecast	weather	conditions)	there	is	

enough	fuel	to	fly	to	the	first	point	of	intended	landing	and,	assuming	normal	

cruising	speed,	(1)	during	the	day,	to	fly	after	that	for	at	least	30	minutes	[emphasis	

added].	

Section	91.203(a)	prohibits,	in	pertinent	part,	any	person	from	operating	a	civil	

aircraft	unless	it	has	within	it	(1)	an appropriate	and	current	airworthiness	

certificate;	and	(2)	an	effective	U.S.	registration	certificate	issued	to	its	owner	or,	for	

operation	within	the	United	States,	the	second	copy	of	the	Aircraft	registration	

Application	as	provided	for	in	§	47.31(c).	

Section	91.203(b)	prescribes,	in	pertinent	part,	that	no	person	may	operate	a	civil	

aircraft	unless	the	airworthiness	certificate	or	a	special	flight	authorization	issued	

under	§	91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	

passengers	or	crew.	

Section	91.407(a)(1)	prohibits,	in	pertinent	part,	any	person	from	operating	an	

aircraft	that	has	undergone	maintenance,	preventive	maintenance,	rebuilding,	or	

alteration	unless	it	has	been	approved	for	return	to	service	by	a	person authorized	

under	§	43.7	of	the	same	chapter.	

Section	91.409(a)(2)	prescribes,	in	pertinent	part,	that	no	person	may	operate	an	

aircraft	unless,	within	the	preceding	12	calendar	months,	it	has	had	an	inspection	

for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	part	21	of	this	

chapter.	

There	are	currently	no	airworthiness	certificates	for	the	UAS	to	be	used	and	also	as	

there	is	no	cabin	cockpit	or	passenger	compartment	on	the	UAS	it	is	not	possible	to	

store	certificates	on	board	the	craft.

Public	Interest	

Aerial	photography	and	videography	for	geographical	awareness	and	for	real	estate	

marketing	has	been	around	for	a	long	time	through	manned	fixed	wing	aircraft	and	

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helicopters,	but	for	small	business	owners,	its	expense	has	been	cost-prohibitive.	

The	cost	prohibition	does	not	permit	seasonal	or	repeated	over	flights	for	many	

institutions,	which	could	mean	several	years	between	a	regions	being	

photographed.	Small	areas	of	study	could	be	repeatedly	photographed	permitting	in	

depth	study	of	an	areas	change	in	geomorphology	through	the	seasons	and	after	

storm	events.	Granting	this	exemption	would	allow	this	service	to	be	provided	at	a	

much	lower	cost,	allowing	for	a	much	greater	utilization.	Further,	this	small	UAS	will	

pose	no	threat	to	the	public	given	its	small	size	and	lack	of	combustible	fuel	when	

compared	to	larger	manned	aircraft.

Supporting	Information:	

The	following	information	is	provided– contained	in	this	petition	and	supporting	

documentation	including:

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Thank	you	in	advance	for	your	time	and consideration	of	my	petition.

Warm	regards,

Christi	Conroy,	Associate	Broker

ABR,	CRS,	GRI,	SFR,	REALTOR

Berkshire	Hathaway	HomeServices	Towne	Realty

2117	General	Booth	Boulevard

Virginia	Beach,	VA	23454

Office:	757-821-1130	x118

Fax:	 757-821-1139

Cell:	 757-510-8123

www.ChristiConroy.com

Email: ConroyHomes@gmail.com

Licensed	in	the	Commonwealth	of	Virginia

dotloop verified

01/31/16 1:15PM EST Christi Conroy 4WN5-45GK-XIOX-8LM9

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