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September 2nd , 2015

U.S. Department of Transportation Attn: Docket Management System 1200 New Jersey Ave , SE Washington, DC 20590

RE: Exemption Request, under Section 333 of the FAA Modernization and Reform Act, from 14 C

. F

. R

. Part 21; 14 C

. F

. R

. 45.23(b ); 14 C

. F

. R

. 61.113(a) & (b) ; 14 C

. F

. R

. 91.7(a); 14 C

. F

. R

. 91.9(b)(2); 14 C

. F

. R

. 91.103; 14 C

. F

. R

. 91.109; 14 C

. F

. R

. 91.119 ; 14 C

. F

. R

. 91.121; 14 C

. F

. R

. 91.151(a); 14 C

. F

. R

. 91.203(a ) & (b); 14 C

. F

. R

. 91.405(a); 14 C

. F

. R

. 91.407(a)(1); 14 C

. F

. R

. 91.409(a)( 1) & (a)(2); and 14 C

. F

. R

. 91.417(a) & (b).

Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Catherine Bronzo, applies for a summary exemption from the listed Federal Aviati on Regulations (“FARs”) to allow her to operate a light , small Unmanned Aircraft Systems (“ s UAS”) in the airspace regulated by the Federal Aviation Administrati on (“FAA”) for commercial real estate photography, aerial photography and videog raphy
, under the conditions outlined herein or as may be established by the FAA in an exemption gra nted under either Section 333.

The requested exemption would permit the operation of a DJI Phantom 3, a small unmanned and relatively inexpensive s UAS under controlled condi tions in airspace that is 1) limited, 2) predetermined and 3) would provide safety enhancements in the fields in which it will operate, which now depend on aircrafts or humans to navigate through and/or climb on dangerous
structures. Approval of this exemp tion would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the R eform Act.

For the reasons stated below I, Catherine Bronzo, respectfully request the grant of an exemp tion allowing me to operate a light weight, remote controlled s UAS (DJI Phantom 3 Professional) in a safe manner for commercial real estate photography, aerial photography and videography.

**I. The name and address of the applicant is:**

Catherine Bronzo 15 Hunter Drive Hampton, NH 03842 cbronzo@me.com2

**II. The Specific Sections of Title 14 of the Code of Federal Regul**  **ations From Which Catherine Bronzo**  **Requests Exemption are:**

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91. 103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F .R. 91.203(a) & (b) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)( 1 ) & (a)( 2) 14 C.F.R. 91.417(a) & (b)

**III: The Extent of relief**  **Catherine Bronzo seeks and the Reason Sh e Seeks Such Relief:** 

I, Catherine Bronzo, will be the pilot in charg e of my sUAS. The sUAS will not be operated around airports (5 nautical miles+ away) nor in any no fly zones. In addition, my sUAS will maintain a safe distance away from the public to ensure safety. I will not fly over crowds, or areas where safety may be compromised. My sUAS will not be flown in adverse weath er, including rain, wind, snow and fog nor in an y other low visibility weather conditions.

My sUAS will be flown with a fully charged battery, therefore eliminating the risk that comes along with fuel . Flight times will be no longer than fifteen minutes, my sUAS will fly to an altitude no higher than 200 feet above ground level (AGL)
, it will fly no faster than 15mph and it will stay within my line of sight. My sUAS has advanced GPS technology along wi th a fail

- s afe option for auto return home, minimizing certain risks. Additionally my sUAS weighs only 2.9 pounds, yet is packed with safety features to ensure a safe flight.

Safety will be of upmost priority and a pre

- flight inspection will take place wit h each individual flight. I am rather experienced with flying my sUAS and will continue to grow my knowledge by staying up to date with current FAA laws and regulations. I understand that there are more limitations flying commercially with this exemption t han a recreational flyer, and I will adhere to all rules.

**IV: How**  **Catherine Bronzo’s Request Will Benefit the Public As A Whole:** 

sUAS are an efficient and safer alternative to planes and helicopters for aerial photography. sUAS are able to get a unique pe rspective and raise geographical awareness for real estate, events, landscapes, landmarks and more. By eliminating the use for planes/helicopters not only does this save resources and money but it also does not risk the lives of anyone on the se vehicles.3

By being able to capture these aerial views in a safe and efficient manner, consumers will have easier access to these aerial photos and videos . Due to this however, these services are becoming very popular which could be hazardous if the pilot in command do es not have the skills necessary to fly safely. However, I, Catherine Bronzo, do have the skills necessary to fly my sUAS safely and I will adhere to all laws and regulations . Also, due to the small size and extreme maneuverability of my sUAS, I can remotely pilot away fr om and avoid hazards quickly and safely. This creates a safe environment where the public can receive aerial photos and videos while also creating a lower ecological footprint. My DJI Phantom 3 will benefit the public and I will adhere to all FAA and safety protocols to deliver these in

- demand aerials

. **V. Reasons Why Catherine Bronzo’s Exemption Will Not Adversely Affect Safety Or How**  **The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:**

By grant ing I, Catherine Bronzo, this exemption I will create a safer community by contributing to the FAA use of sUAS in a way that promotes awareness and safety. Safety is of my highest priority and I will follow all laws and regulations while also adh ering to r igorous pre

- flight inspections . The use of my sUAS will be within my line of a sight, at an altitude no higher than 200 feet AGL, at s p eed s slower than 15mph and I will only op erate in safe, legal and predetermined areas with good weather conditions. My sa fety protocols will provide a level of safety equal t o or exceeding existing rules.

**VI. A Summary The FAA May Publish in the Federal Register:**

**FAR section Subject**  **Justification**

14 CFR Part 21 Aircraft certification requirements and procedures Des igned for manned aircraft; not suitable for sUAS 14 CFR 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle due to size , also

no cockpit, nor cabin

14 CFR 61.113(a) & (b) Private pilots are limited to

non

- commer cial operations sUAS is incapable of carrying a pilot or passengers, and will be in a controlled area of operation with the pilot having the skills necessary to operate safely without a private pilot certification
14 CFR 91.7(a) Airworthiness requireme nt Designed for manned aircraft; not suitable for sUAS
14 CFR 91.9(b)(2) Requirement for manual to be available in the cockpit No on board pilots or passengers to read manual

14 CFR 91.103 Requires preflight action Preflight actions will differ for s UAS as there is no fuel, runway, etc.

14 CFR 91.109 Requirement for dual controls during flight instruction No onboard pilots or passengers to operate controls

14 CFR 91.119 Minimum altitudes for safe flight Safety requires operation below these alt itudes and will fly 200 AGL4

14 CFR 91.121 Altimeter settings No onboard pilots or passengers to read altimeter 14 CFR 91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR 91.203 (a) & (b) Requirement for registration and airworthiness
cert ificates to be onboard No on board pilots or passengers to read certificates

14 CFR 91.405 (a) Inspection requirements Designed for manned aircraft; not suitable for sUAS 14 CFR 91.407(a) (1) Inspection approval requirements Designed for manned airc raft; not suitable for sUAS 14 CFR 91.409(a)(1 ) & (a)(2) Airworthiness inspection Designed for manned aircraft; not suitable for sUAS

14 CFR 91.417 (a) & (b) Maintenance records requirements Designed for manned aircraft; not suitable for sUAS

In summary, Catherine Bronzo seeks an exemption from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.103; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) & (a)(2); and 14 C.F.R. 91.417(a) & (b) to commercially operate my DJI Phantom 3, a small unmanned aircraft while following FAA regulations and while ensuring safety.

Respectfully Submitted,

Catherine Bronzo 15 Hunter Drive Hampton, NH 03842 cbronzo@me.com5