Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Extent of relief I seek, and why

14 CFR Part 21 subpart H

The UAs to be operated carries neither pilot nor passenger and carries no explosive materials 

or flammable liquids. Given the size, weight, speed, and limited operating area associated with 

the aircraft to be utilized, I request exception. In the restricted environment and under the 

conditions proposed operation will be at least as safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without said restrictions. 

14 CFR 45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market 

certain words or phrases. Lettering would be very difficult to place on such a small aircraft and 

dimensions would need to be smaller than required minimum. Understanding the importance of 

lettering I will mark my UAS with the largest possible letters by placing the word "Experimental" 

or assigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent 

level of safety will be provided by having the UAS marked on its fuselage as required.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check list prior to each flight an equivalent level of safety will be 

provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. 

There is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level 

of safety will be maintained by keeping the flight manual at ground control point where the pilot 

wil) have immediate access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be 

needed. Normal procedures including but not limited to; reviewing weather, flight battery 
requirement, landing and takeoff distances, along will all of those found in attachment "DJI Pilot 

Training". An equivalent level of safety will be provided by preflight protoco) to properly match 

the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is 

achieved through the use of a control box that communicates with the aircraft via radio 

communications. The equivalent level of safety provided because neither a pilot nor passenger 

will be carried in the aircraft, and by the speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

I can achieve an equivalent level of safety as achieved by current regulations because my UAS 

does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control 

piloting skills.

14 CFR 91.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I 

believe an exemption may be needed. An equivalent level of safety is achieve by the operator 

receiving live flight data monitoring and confirming current altitude along with altitude of launch 

site shown on GPS altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry 

certificate and registration documents on the aircraft. There is no room, capacity, or pilot on 

board to adequately such documents. An equivalent level of safety wili be achieved by keeping 

these documents, to the extent they are applicable to the UAS, at the ground control point 

where pilot has immediate access to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these section only apply to aircraft with an airworthiness certificate, theses sections do 

not apply to this applicant. As a safety precaution, operator will perform preflight inspections and 

ensure UAS is in working condition before initiating each flight.

Catherine Maum is seeking relief from all FARs above preventing appiicant from conducting 

aerial photography and video of real estate taken at levels less than 400ft, at a speed less than 

33.5 mph, and with a maximum flight time of 25 minutes,. The drone to be used is a D1I 

Phantom 2 Plus. At 2.74 pounds the weight of the UAS meets the definition of "small unmanned 

aircraft" found in section 331 "The Reform Act". In order to obtain high quality photography and 

video the UAS will be used at speeds much less than it's top speed of 33.5 mph. Due to the 

UAS being battery powered there are no combustible fuels onboard. Maximum flight time for 

this particular UAS is 25 minutes battery life, flights to be terminated with 25% battery life 

remaining. Given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized I find this exception to be reasonable with an equivalent, or greater, level of safety 

to be reached by the operator.
Safety

*Please see attachment "DJI Pilot Training" for safety precautions I use for every flight. Aside 

from these practices I was given a hands on training course when I purchased my UAS.

Additionally:

1) I do not operate within 10 miles of an airport.

2) I land my UAS prior to manufacturer recommended minimum level of battery power.

3) I pilot my UAS through remote control by line of sight

4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position 

and then slowly lands if communication with the remote control pilot is lost. I do not pilot my 

UAS outside of GPS lock under any circumstances.

5) I actively analyze flight data and other sources of information to constantly update and 

enhance safety protocols 

6) I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance

7) I always obtain all necessary permissions prior to operation; and,

8) I have procedures in place to abort flights in the event of safety breaches or potential danger.

The use of an UAS in the real estate industry provides both buyers and sellers a higher level of 

service. For a buyer a higher level of marketing and advertising is achieved, appealing to more 

buyers, resulting in a quicker sale of their home. Quicker home sales also helps accelerate the 

economy as a whole. Buyers experience the benefit of encompassing a whole property, 

sometimes several acres, in one photo or a short video. Not only does this benefit the specific 

home seller or home buyer, but it benefits the general public because it is much more efficient 

than traditional ways of using a plane or helicopter to achieve the same result. We can now 

provide this level of service while being conservative with fuel, time, emissions, noise, and other 

resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will 

poses much less of a safety concern for the general public when compared to larger manned 

aircraft.

Thank you for your consideration.

Catherine Maum