December 31, 2015

A real Photography

27394 Yowaiski Mill Rd. 

Mechanicsville, 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). to 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 aerial 
videography/ 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 home 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

Safety 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. Further, the two inch lettering is difficult to place on such a
small aircraft with dimensions smaller than the minimal lettering requirement. This quad copter is 

stenciled with our UAS certificate # FA33YL3CAX

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a

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

Proposed operations in previously issued exemptions to this regulation through Exemption

Nos. 11062 and 11138.

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 aircraft 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

operator.

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

We will ensure that UAS do not operate any higher than 400 feet at

ground level. We 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 Requirements for flight in VFR conditions

The UAS that we will fly are powered by electricity, using lithium Ion batteries that

currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the
limitations of the batteries, it is currently 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 

14C.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 before 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 also we assist in Home 

Inspections of roofs and chimneys. 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 filming 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 from 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 the 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 photography/videography services available to the public. 

By not using combustible fuel, flying at safe heights and strictly following the

usage recommendations from Parrot Drones

These include but are not limited to:

● Flying the following UAS Safely

○ Parrot Bebop 2 Quad Copter

● Flying below 400 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 photograph persons in areas where there is an

expectation of privacy without the individual's permission.

Respectfully,

Mark Thompson

A real Photography

27394 Yowaiski Mill Rd.

Mechanicsville Md. 20659

Phone: 301-710-7324

E-Mail: bb450r@md.metrocast.net