December 31, 2015

A real Photography

27394 Yowaiski Mill Rd.

Mechanicsvill e, Md. 20569

Phone 301

- 710

- 7324

E

- Mail bb450r@md.metrocast.net

Federal Aviation Administration:

We
, A real Photography, are writing pursuant to the FAA Modernization and Reform Act
of 2012 and the procedures contained within 14 C.F.R. 11, to request that we , Mark and Ben
Thompson DBA A real Photography
, owner and operator of small unmanned aircraft, be exempted
from the Federal Aviation Regulations ( “ FARs ” ) listed below so that we , may operate a small ultra
light weight unmanned aircraft system ( “ UAS ” ) commercially in airspace regulated by the Federal

Aviation Administration ( “ FAA ” ) in accordance with FAA UAS Regulations & Policies.

We would like to formally submit for an exemption from the following Section 333
regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a),
14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1)
and (2), 14 C.F. R. 91.417(a) and (b). t o operate the Parrot Bebop 2 Drone . This UAS will be
equipped with a detachable camera and will be transported in proper storage. This proposed
exemption would allow the operation of unmanned aircraft systems (UAS) for the purpose of aerialvideography/ photography as a service to the public/ business interests. As found in exemption No.

11138 (Trudeau),
The Bebop 2 is selected because it has proven reliable flying capabilities managed by gyro stabilized
flight, ground detection ,GPS aided navigation, a compass, blinking LEDs, failsafe mode for
returning h ome and prop guards.
This will act to further safety protocols exclusive to lightweight UAS ’ s specific to video and
photography usage as we 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 regulations.

Specific section or sections of 14 CFR which we seek relief and the reason we seek relief:

14 C.F.R. Part 21: Airworthiness Certificates
Given the size and limited operating area associated with the aircrafts to be utilized by
A real Photography , an exemption from Part 21 meets the requirements of an equivalent level of

S afety under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these
criteria demonstrates that the UA operated without an airworthiness certificate, in the
restricted environment and under the conditions proposed will be at least as safe, or safer,

than conventional aircraft operating with an airworthiness certificate without restrictions and
conditions proposed.
14 C.F.R. 45.23: Display of marks: general
The UA does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to
mark certain words or phrases. Fu rther, the tw o inch lettering is difficult to place on such asmall aircraft with dimensions smaller than the minimal lettering requirement. This quad copter i s

ste nc i l e d with our UAS certificate # FA33YL3C AX
14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command
The FAA has previously declar ed that additional manned airship experience of a

C ommercially certified pilot would not correlate to the airmanship skills necessary for similarly

P roposed operations in previously issued exemptions to this regulation through Exemption

Nos. 11062 and 1113 8.
14 C.F.R 91.7: Civil aircraft airworthiness
Currently, since there is no certificate applicable to the UAs in question, this regulation
is inapplicable.
14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements
Requires an a ircraft flight manual in the aircraft, however there are no pilots or
passengers on board this aircraft and given its size, this regulation is inapplicable. An
equivalent level of safety will be achieved by maintaining a safety/flight manual with the

opera tor.
14 C.F.R. 91.119(c): Minimum safe altitudes

We will ensure that UAS do not operate any higher than 4 00 feet at
ground level. W e will not fly over congested areas. We will plan operations before hand, for proper
flight safety, and proper height analysis as to avoid collisions.
14 C.F.R. 91.121: Altimeter settings
The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety
will be achieved by using this.
14 C.F.R. 91.151(a)(1): Fuel Requirement s for flight in VFR conditions

The UAS that we will fly are powered by el ectricity, using lithium Ion batteries that
currently have a flight limit of approximately no more than 20 minutes. Therefore, due to thelimitations of the batteries, it is curre ntly impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required
Currently, there are no procedures for providing airworthiness certificates for the

mentioned UAS. We , however will always fly safely while having the manual of the Bebop 2

14 C.F.R. 91.405(a): Maintenance Required,
14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or

alteration,
14 C.F.R. 91.409(a)(1) and (2): Inspections &

14 C. F.R. 91.417 (a) and (b): Maintenance records
Maintenance inspections may be required and should be granted since they only apply

to aircraft with an airworthiness certificate. However we will perform preflight
inspections of the UAS b efore each flight as outlined in the operating documents. We will also
follow manufacturer recommendations from said operating documents.

Public Interest
Aerial photography and videography as an available service to the public allows for a
cheaper method to capturing imagery than its alternative. Its alternative being aircraft and
helicopters. They are expensive, create lots of noise, and are much more threatening due to

size and combustible fuel. Not only do we do Real Estate Photography but al so we assist in Home
Inspections of roof

s and chimney s. This makes for a safer way than having the inspector on a ladder

2 of more stories in the air.
A real Photography would gladly offer our services upon request and with proper
coordination to any official search and rescue or emergency services organization to benefit
the public.
Also as mentioned in the Trudeau exemption, exemption No.11138:““ Manned aircraft conducting aerial film ing and photography can weigh 5,000 lbs. or

more, are operated by an onboard pilot and may carry other onboard crewmembers, as well
as 100 gallons or more of fuel. The petitioner ’ s [ UAS] weighs less than 3 lbs. The pilot and
crew will be remotely located f rom the aircraft. The limited weight reduces the potential for
harm to persons or damage to property in the event of an incident or accident. The risk of an
onboard pilot and crew during an incident or accident is eliminated with the use of a [ UAS]

for th e proposed operation. ”
Summary

We
, Mark and Ben Thompson, DBA A real Photography are seeking exemption from the following

rules:
14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R.
91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91. 151(a)(1), 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)(1) and
(2), 14 C.F.R. 91.417(a) and (b)
With the exemptions of the mentioned rules we will be seeking to make

Our drone photogra phy/videography services available to the public.
By not using combustible fuel, flying at safe heights and strictly following the

us ag e recommendations from Parrot Drones

These include but are not limited to:

● Flying the following UAS Safely

○ Parrot Bebop 2 Quad Copter

● Flying below 4 00 feet

● Proper visual inspection of UAS before flights

● Keeping mentioned UAS in visual sight at all times when in operation● Using an observer to assist if needed

● Remain well clear of and do not interfere with manned aircraft operations, and avoid

other aircraft and obstacles at all times

● Not intentionally fly over unprotected persons or moving vehicles

● Contact the airport or control tower before flying within 5 miles of an airport

● Not flying in adverse weather conditions such as high winds or reduced visibility

● Not flying under the influence of alcohol or drugs

● Ensure the operating environment is safe

● Not flying over sensitive infrastructure or property such as power stations, water

treatment facilities, correctional facilities, etc.

● Check and follow all local laws and ordinances before flying over private property

● Do not conduct surveillance or photog raph persons in areas where there is an
expectation of privacy without the individual's permission.
Respectfully,
Mark Thompso n
A real Photography

27394 Yowaiski Mill Rd.

Mechanicsville Md. 20659

Phone : 301

- 710

- 7324

E

- Mail : bb450r@md.metrocast.net