Oct 31, 2015 

Family Memories Photography

13005 Point Richmond Drive NW

Gig Harbor, WA 98332

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), 

Family Memories Photography, the operator, and Sue Burnett owner and pilot Roy Burnett seeks 

an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following 

described Unmanned Aerial System to allow for commercial operations of one DJI “Inspire 1”

four rotor UAS’s (Inspire 1), one DJI Phantom 2 four rotor UAS’s with an attached DJI H3-3D 

Gimbal Mount holding a GoPro Hero 3+ with attached 3 axis gimbal mount for the purpose of 

aerial photography and video for a variety of industries.

THE UNMANNED AIRCRAFT (UA):

The Inspire 1 has a maximum takeoff weight of approximately 7.6 pounds. It has a diagonal 

length of 451mm and a maximum speed of 22 meters per second. DJI Phantom 2 has a 

maximum takeoff weight of approximately 2.9 pounds. It has a diagonal length of 350mm and a 

maximum speed of 15 meters per second.

Inspire 1 and the Phantom 2 both Manufactured by DJI include the following equipment in flight:

1. An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/controller.

2. An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video.

3. An on-board telemetry system using GPS flight that delivers flight data from the onboard flight computer to the on-board radio transmitter including altitude AGL, 

horizontal and vertical speed, compass direction of flight and direction back to its launch 

site.

4. A 5GHz and 2.4GHz for the Inspire 1 and 2.4GHz for the Phantom 2s on-board radio 

transmitter that transmits live HD video from the on-board camera plus all the flight data 

from the telemetry system described above.
THE GROUD STATION-BASED EQUIPMENT AND CREW:

1. A Pilot in Command (PIC) in operational control of flight operation from beginning to end 

who controls the UA while in the air.

2. A 2.4GHz radio transmitter/controller operated by the PIC to control the UA Phantom 2 while 

in flight. A 5GHz and 2.4GHz radio transmitter/controller is used for the Inspire 1.

3. A radio receiver receiving live video and flight data from the on-board camera and computer, 

projecting it all together onto a screen for the PIC to view during flight.

4. A Visual Observer (VO) provides a second pair of eyes to visually track the UA while in 

flight.

Summary

The requested exemption would support an application for a commercial Certificate of

Authorization for Family Memories Photography to provide aerial photography and other 

photography services for real estate agents, real property appraisers, property managers, general 

contractors; utilities and industries (only where safe flight is attainable), Chambers of Commerce,

community events, weddings, marine properties, resorts, wildlife conservation organizations, 

public departments, all other institution requiring filmography (safe flight permitting) and never 

operating over persons not directly involved.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel. It operates at lower altitudes with no people on board, thereby 

reducing current risk levels and enhancing safety and diminishing the likelihood of death or 

serious bodily injury. With a small payload and maximum flight time of only 18 minutes, there is 

little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground based 

imagery for displaying the characteristics of large, complex properties with several buildings and 

large trees. The alternative could be to charter a full-sized helicopter for this purpose, which has 

proven more costly than many potential clients are able to afford. This benefits many buyers and 

sellers of real property and marine property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby 

who might require assistance, including fire fighters, the police, the sheriff, et al., while 

remaining subject to all limitations cited in this application as we do so.

The Family Memories Photography UAs will be operated in the field with both a PIC and a VO 

in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and 

with the following Restrictions:

a) No flight will be made with a UA with gross weight exceeding 55 pounds.

b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at airspeed of 

no more than 50 knots and no further than 3/4 NM from the PIC.

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to

communicate by voice at all times during a flight operation.

d) Operations will be restricted to flights over property with the permission of the property owner.

e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51.

f) All required permits will be obtained from state and local government prior to operation.

g) The Family Memories Photography will not be operated over densely populated areas.
h) The Family Memories Photography will not be operated at air shows.

i) The Family Memories Photography will not be operated over any open-air assembly of people.

j) The Family Memories Photography will not be operated over heavily trafficked roads.

k) The Family Memories Photography will not be operated within 5 NM of an airport or heliport.

l) Operations will be restricted to day only and weather conditions equivalent to VFR.

m) The PIC will brief the VO and property owner about the operation and risk before the first

flight at each new location.

n) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to 

ascertain that the UAs are in a condition safe for flight.

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete a course of maintenance instruction as part of their initial training.

We submit that the combination of the UA's light weight, flight performance and ability, qualified 

flight crew and strict operation procedures under the guidelines established in 8900.227, and 

under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that 

the operation we undertake will have an equivalent or greater level of safety than manned aircraft 

performing the same mission.

The name and contact information of the applicant is:

Family Memories Photography: Roy Burnett

Phone: 253-304-1013

Email: roynsueb@comcast.net

Exemptions/Rule Making

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 45.29

14 CFR 61.23

14 CFR 61.113(a) & (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) & (b)

14 CFR 91.405(a)

14 CFR 407(a)(1)

14 CFR 409(a)(2)

14 CFR 417(a) & (b)

14 CFR Subpart E (91.401-91.417)

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory 

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including UASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. The Administrator may grant an exemption from a requirement of a regulation 
prescribed under subsection (a) or (b) of this section or any sections §44702-44716 of this title if 

the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UASs may operate 

in the national airspace system without creating a hazard to the user, the public, or a threat to 

national security. In making this determination, the Secretary must consider:

1.		The UASs size, weight, speed and operational capability;

2.		Whether the UAS operates within the visual line of sight of the operator;

3.		Whether the UAS operates outside of highly populated areas and away from close proximity to 

airports.

Reform Act 333 (a). If the Secretary determines that a UAS "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system." Id. 333 (c).

The DJI Inspire 1 is a multi-rotor aircraft weighing 7.6 pounds, including payload. It has the 

ability to operate under normal conditions at a speed of no more than 45 knots and has the 

capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will 

operate only in the pilot's or visual observer's visual line of sight at all times. Such operations will 

insure that the UAS will "not create a hazard to users of the national airspace system or the 

public." Reform Act Section 333(b). The operators’ manual will be at the control site with the 

PIC and VO.

The DJI Phantom 2 is a Multi-rotor aircraft weighting 2.9 pounds, including payload. It has and 

ability to operate under normal conditions at a speed of nor more than 35 Knots and the

capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will 

operate only in the pilot's or visual observer's visual line of sight at all times. Such operations will 

insure that the UAS will "not create a hazard to users of the national airspace system or the 

public." Reform Act Section 333(b). The operators’ manual will be at the control site with the 

PIC and VO.

Given the small size of the UAS involved and the restricted environment within which UAs will 

operate, our application falls squarely within the zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also due to the small size of the UASs and the low altitudes in 

which our UAS will operate, approval of the application presents no national security issue.

The Inspire 1 can be operated entirely by a touch-screen, map-based interface. This means the 

operator only needs to command the system where to go, and the system does all the flying for 

the operator. The Inspire 1 can be operated in both semi and fully autonomous flight modes, with 

the operator simply clicking on a map to create a preplanned flight path for a flight. In addition, 

the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot 

enter areas deemed unsafe or unnecessary to fly over.

The UAS has built-in intelligent fault handling which allows the Inspire 1 to detect a system fault 

while in the air and automatically fly back to its takeoff location and land. Faults that can be 

detected include: loss of communication; loss of GPS lock; and low battery levels.

The DJI Phantom 2 UAS is a small and safe sub 3 pound plastic and composite aircraft utilizing 

four propellers driven by a 5200mAh, 11.1V, LiPo smart battery with an average flight time of 

17-18 minutes. The remote control/transmitter operates at 2.4 GHz. The aircraft’s software can be 

calibrated to limit both AGL and distance from the transmitter. The aircraft will automatically 
return to point of origin or descend in place should signal with the transmitter be lost. The UAS is

unmanned, operates at low altitudes, does not run on combustible fuel, has very low decibel level 

noise emissions and has a small payload capacity and short flight time, thus significantly reducing 

current risk levels involved with utilizing manned aircraft for aerial photography.

All flight operations are global positioning system (GPS) controlled, making the systems easy to 

navigate. At any point if the operator is not explicitly commanding the system to move, the 

system automatically holds its GPS position. Also a flight termination link - to prevent a "fly 

away" or other potentially dangerous situation - is available to the operator.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the 

aircraft to be utilized by Family Memories Photography. An exemption from Part 21 Subpart H 

meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 USC §44701(f) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability and proximity to airports and 

populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that 

the UAS operated without an airworthiness certificate, in the restricted environment and under the 

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

an airworthiness certificate without the restrictions and conditions proposed.

14 CFR 45.23(b) & 14 CFR 45.29: Marking of the aircraft; Display of Marks; Size of Marks

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport 

category aircraft to be marked with letters between 2 inches and 6 inches high "limited", 

"restricted" "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit 

or pilot station. Even though the UAS will have no airworthiness certificate, an exemption may 

be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the 

word "Experimental" can be placed. Given the size of the UAS, 2 inch lettering will be 

impossible. Robbins Land Surveying, Inc. Family Memories Photography will mark the UAS 

with the organization's name and address. 

14 CFR 61.23: Medical certificates; Requirement and duration

Regulations provide that a person:

(1) Must hold a first-class medical certificate:

a) When exercising the pilot-in-command privileges of an airline transport pilot 

certificate;

b) When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that requires 

three or more pilots; or

c) When serving as a required pilot flight crewmember in an operation conducted under 

part 121 of this chapter if the pilot has reached his or her 60th birthday.

(2) Must hold at least a second class medical certificate when exercising:

a) Second-in-command privileges of an airline transport pilot certificate in part 121 of 

this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or
b) Privileges of a commercial pilot certificate

Given the size of the UAS, their structure, the limited flight area and the safety features integrated 

into the autopilot (among others the flight termination system), Family Memories Photography 

believes that an Equivalent Level of Safety can be reached if the pilot-in-command has a valid 

driver's license.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the pilot operating the aircraft to have completed UAS 

manufacturers flight training before flying a UAS. Unlike a conventional aircraft that carries the 

pilot and passengers, the UAS is remotely controlled with no living thing or cargo on board. The 

area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the User Guide. The risks associated with the operation of the small

UAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the UAS as requested exceeds 

the present level of safety achieved by 14 CFR 61.113(a) and (b).

14 CFR 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the User Guide for maintenance 

and use of safety checklists prior to each flight an equivalent level of safety will be provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The UAS, given there size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the User Manual at the ground 

control point where the pilot flying the UAS will have immediate access to it.

14 CFR 91.103: Preflight action

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery requirements, 

checking takeoff and landing distances, and all other actions in the User Guide and safety 

checklists. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. By design, UASs and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The equivalent level of safety is provided by the fact that 
neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via 

radio signals from the controller and by the size and speed of the aircraft

14 CFR 91.119: Minimum safe altitudes

Section 91.119 states persons may operate a helicopter 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. The sUAS meets this 

criteria as a helicopter and requests the ability to operate at altitudes up to 400’ AGL. Only in 

accordance with pre-obtained consent will the sUAS operate while also maintaining an altitude 

less than 400’ AGL. For comparison with traditional aircraft and rotorcraft the sUAS weighs less 

than 8lbs, while also preventing potential risks associated with flammable fuel. Lastly the 400’ 

AGL ceiling limits any ability for the sUAS to interfere with conventional aircraft operating at or 

above 500’AGL.

The equivalent level of safety will be achieved given the size, weight and speed of the UAS as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because advance notice to the property owner and any on-site 

personnel, as well as the precautions outlined below, all affected individuals will be aware of the 

planned flight operations. Flight operations will be conducted at least 200 feet from all nonparticipating persons (persons other than the pilot in command (PIC) or visual observer (VO), 

vessels, vehicles and structures, unless:

1. Barriers or structures are present that sufficiently protect non-participating persons 

from debris in the event of an accident. The PIC will ensure that non-participating 

persons remain under such protection. If a situation arises where non-participating 

persons leave such protection and are within 200 feet of the UAS, flight operations 

will cease immediately and/or;

2. The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and;

3. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 

14 CFR 91.119(a).

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be 

conducted at lease 5 miles from an airport and at least 3 miles from any city or densely populated 

area. The PIC or VO will provide notification to the local Flight Standards District Office and 

airport controller of all operations within 5 miles of an airport. The FAA will have advance notice 

of all operations through the filing of notices-to-airmen.

Compared to flight operations with aircraft or rotor craft weighing far more than the UAS 

proposed herein and carrying flammable fuel, any risk associated with our operations if far less 

than those presently presented with helicopters and other conventional aircraft operating at or 

below 500 feet AGL. In addition, the low-altitude operations of the UAS will ensure separation 

between these UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the aircraft to maintain cruising altitude by 

reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate 
altimeter setting available before departure." As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151 states no person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. 

The sUAS battery powered operational flight time is not able to incorporate a 20 minute reserve 

window following successful first point of intended landing due to current battery capacity 

limitations. In order to provide adequate reserve power for return landing the sUAS will abide by 

a 12 minute flight time or 20% of remaining battery power, whichever happens first.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot station and is operated without an on-board pilot. 

Therefore, there is no ability or place to carry certification and registration documents or to 

display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS.

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter 

etc" and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Family Memories Photography. Maintenance will be performed by the 

operator pursuant to the Maintenance Manual and the User Guide. An equivalent level of safety 

will be achieved because these UASs are very limited in size and will carry a small payload and 

operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS 

can land immediately and be put out of service until proper maintenance and then tested. As 

provided in the User Guide, the operator will ensure that the UAS is in working order prior to

initiating flight, perform required maintenance and keep a log of any maintenance performed on 

the UA. Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for precision aerial surveys 

enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater 

risk because the craft are much larger, have combustible fuel, and carry an on-board human pilot. 

In contrast, a UAS weighing 8 pounds and powered by batteries eliminates virtually all of that 

risk given the reduced mass and lack of combustible fuel carried on board. The UAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights. Conducting aerial surveys with the DJI Inspire 1, or the Phantom 2 instead of 
manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial survey flight operations. By using battery power and 

electric motors, both the Inspire 1 and the Phantom 2 produce no air pollution and is a viable, 

environmentally conscious alternative to the cabin class, six cylinder internal combustion twin 

engine aircraft that are typically utilized for aerial surveys, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The Inspire 1, and the Phantom 2 while reducing the 

carbon footprint of aerial surveys, also reduce noise pollution as the UASs are propelled by 

battery powered electric motors rather than an internal combustion engine.

EQUIVALENT LEVEL OF SAFETY

Family Memories Photography proposes that the exemption requested herein apply to civil 

aircraft that have the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations under the 

current regulatory structure because the proposed operations represent a safety enhancement to 

the already safe protocols followed by aerial survey operations conducted with helicopters and 

other conventional aircraft.

Family Memories Photography will be bound by the following limitations when conducting its

UASs operations under an FAA issued exemption:

1. The UAS will weigh less than 9 pounds and 3 pounds respectively.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operations flight will be 20 minutes. Flights will be 

terminated at 20% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flight operations will be conduced 5 miles from an airport and at least 3 miles from any 

city or densely populated area, which are depicted in yellow on VFR sectional charts.

6. Flight operations within 5 miles of an airport require notification and approval from the 

local Flight Standards District Office and airport controller.

7. Flight operations will occur during daylight hours and under visual meteorological 

conditions only.

8. The FAA will have advance notice of all operations through the filing of notices-toairmen.

9. Minimum crew for each operation will consist of the UAS pilot and visual 

observer/camera operator.

10. The pilot and visual observer are trained in the operation of the UAS.

11. The pilot and visual observer will at all times be able to communicate by voice and/or 

text.

12. Written and/or oral permission from the relevant property holders will be obtained.

13. Flight operations will be conducted at least 200 feet from all non-participating persons, 

vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect non-participating 

persons from debris in the event of an accident. The pilot will ensure that nonparticipating persons remain under such protection. If a situation arises where 

non-participating persons leave such protection and are within 200 feet of the 

UAS, flight operations will cease immediately and/or

b. The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and
c. Operations near the pilot or visual observer do not present an undue hazard to 

the pilot or visual observer.

14. If the UAS loses communication or loses its GPS signal, both UASs have the capability 

to return to the takeoff point location and land.

15. The PIC will have the capability to abort flight in case of unpredicted obstacles or 

emergencies.

PRIVACY

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Images taken will be of individuals who have also consented to being 

filmed or otherwise have agreed to be in the area where aerial photography will take place.

FEDERAL REGISTER SUMMARY

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security - provide more than adequate justification for the grant of 

the requested exemptions allowing Family Memories Photography to conduct contracted 

commercial sUAS operations using the DJI Inspire 1 and Phantom 2 for a wide range of 

industries and applications.

Sincerely,

Roy & Sue Burnett

Owner/President

Family Memories Photography

13005 Point Richmond Drive NW

Gig Harbor, Washington 98332

253-304-1013