Taylor Blom

Front Door Photos

www.frontdoorphotos.net

4717 W Perry Circle

Holland, MI 49424

July 3, 2015

US Department of Transportation

Brenda Robeson

Program Analyst

Airmen and Airspace Rules Division

RE: Public Docket No. FAA­2015­0659, Request for exemption under Section 333 of the

FAA 14 C.F.R Part 11 (providing additional information)

Front Door Photos requests an exemption from the Federal Aviation Regulations stated in 14

C.F.R Part 11 to commercially operate a DJI Inspire 1 and DJI Phantom 2 for real estate

photography/videography purposes, both commercial and residential, inside the United States.

Specifically, Front Door Photos requests an exemption from the following rules:

14 C.F.R. Part 21, Subpart H & 14 C.F.R. §91.203(a) and (b) which requires all civil aircraft to

have an airworthiness certificate. Front Door Photos requests an exemption from this rule in

accordance with the size, speed, operational safety features of the UAVs as well as its proximity

to airports and populated areas. Front Door Photos will maintain an equivalent level of safety

and pre­check all UAVs before flight to ensure airworthiness.

14 C.F.R. §45.23(b) which requires all aircrafts to display a registration number at least 3’’ high

and the word ‘Experimental’ at least 2” high near the cabin entrance. Front Door Photos

requests an exemption to this rule due to the impossibility of implementing such large lettering

and numbering. Instead, we will place identification numbers 1” high on the side of each UAV

which should be a suitable substitute and provide an equivalent level of safety.

14 C.F.R. §61.23(a) which requires all operators hold a Medical Certificate. Front Door Photos

requests an exemption to this rule due to the size, speed of the UAS as well as its proximity to

people. Instead all UAS] operators will hold a valid Driver's License to achieve an equivalent

level of safety.

14 C.F.R. §61.113(a) which requires all UAS operators to hold a Commercial Pilot Certificate.

Front Door Photos requests an exemption to this rule so the above mentioned UAS can be

operated by a person holding a Private Pilot’s License. The risks associated with the operation

of the DJI multi­rotor aircraft (given the size, speed, operational capabilities, proximity to people

and lack of combustible fuel) are so much less than the level of risk associated with fixed wing

and rotorcraft operations, both private and commercial, as contemplated by Part 61, that
allowing operations of these UAS, as set forth above, meets or exceeds the present level of

safety provided under 14 C.F.R. §61.113(a).

14 C.F.R. §91.7(a) & 14 C.F.R. §91.9(b) which requires all aircrafts to have airworthiness status

as well as a current, approved flight manual in the aircraft. As previously stated, Front Door

Photos will provide safety checks as outlined in the DJI user manual before every flight to

maintain an equivalent level of safety in regards to its airworthiness. Also, since the UAS cannot

possibly contain an approved flight manual during flight, the DJI user manual will be accessible

to all Front Door Photos pilots before, during and after UAS flights to maintain an equivalent

level of safety at all times.

14 C.F.R. §91.109(a) which states that no person can operate an aircraft for training for flight

instruction unless it has dual operating controls. The UAS in this exemption are remotely piloted

aircraft, and, by design, not equipped with fully functional dual controls. Flight control is

accomplished through the use of a controller that connects with the aircraft remotely. A pilot

skilled in remote piloting will provide an equivalent level of safety as an exemption to this rule.

14 C.F.R. §91.119 which states the minimum safe flying altitude in sparsely populated areas is

500 feet. Since the UAS will fly no more than 400 ft. in the air at all times, Front Door Photos

requests an exemption to this rule on the basis of UAS safe flying practices which will

undoubtedly provide an equivalent level of safety in regards to this particular rule.

14 C.F.R. §91.121 which states that an altimeter shall be used to maintain cruising altitudes

within 100 miles of a nautical aircraft. Since the UAS will never fly above 400 feet, navigating

with an altimeter will not be necessary. The advanced controls of the UAS will provide an

equivalent level of safety in regards to this rule.

14 C.F.R. §91.151(a) which states that that no person can fly an aircraft under day­VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. Since the UAS is battery­powered, this requirement is not

applicable. Battery checks before flight and low­battery warnings during flight will provide an

equivalent level of safety in regards to this rule.

14 C.F.R. Subpart E (§91.401 ­ §91.417) which requires the operator to be responsible in

maintaining the aircraft’s airworthiness before, during and after flight. The operator is also

responsible for returning the aircraft for service in an airworthy state. Front Door Photos will

examine all UAS prior to and following all flights ensuring an equivalent level of safety to this

rule.

In addition to the previously mentioned safety measures for all exemptions, Front Door Photos

will adhere to the following restrictions for all UAS flights:

­ All flights will be conducted under 50mph and never further away than a 1⁄2 mile

­ Safe landing/takeoff procedures will be followed at all times
­ All flights will be executed by a pilot and a ground­level observer to maintain the highest

level of safety

­ All flights will be monitored by direct line of sight and the UAS will be visible at all times

­ No flights will be conducted within 5 miles of any airport

­ The UAS will be operated over private property only with the permission of the owner(s)

­ The UAS will not be operated over populated areas at any time

­ Flight operations will only occur during normal daylight hours. Nighttime flights will not be

permitted

­ The pilot and observer will maintain open lines of communication during all flights

­ All UAS will fly with a maximum weight of 10 lbs.

­ The highest level of caution and safe flying will be adhered to at all times.

­ The DJI Inspire 1 and Phantom 2 will undergo safety checks and pre­flight examinations.

(The exact specs of these aircrafts have already been supplied to the docket)

In conclusion, Front Door Photos requests an exemption under Section 333 to enable safe

commercial UAS operations for real estate photography/videography, both commercial and

residential, which will improve the overall health of the real estate market for realtors, home

buyers, and sellers. By approving these exemptions, the FAA will create benefits to the areas

mentioned that is ultimately in the public interest. Thank you.

Taylor Blom

Owner/President

Front Door Photos

Endclosure