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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 Aviation Regulations (“FARs”) to allow her to operate a light, small Unmanned Aircraft 

Systems (“sUAS”) in the airspace regulated by the Federal Aviation Administration (“FAA”) for 

commercial real estate photography, aerial photography and videography, under the conditions 

outlined herein or as may be established by the FAA in an exemption granted under either 

Section 333.

The requested exemption would permit the operation of a DJI Phantom 3, a small unmanned and 

relatively inexpensive sUAS under controlled conditions 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 exemption 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 

Reform Act.

For the reasons stated below I, Catherine Bronzo, respectfully request the grant of an exemption 

allowing me to operate a light weight, remote controlled sUAS (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.com
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II. The Specific Sections of Title 14 of the Code of Federal Regulations 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 She Seeks Such Relief: 

I, Catherine Bronzo, will be the pilot in charge 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 weather, 

including rain, wind, snow and fog nor in any 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 with a fail-safe 

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 with 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 than 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 perspective 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 these vehicles. 
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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 does 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 from 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 granting 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 adhering to rigorous 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 speeds slower than 15mph and I will only operate in safe, legal and 

predetermined areas with good weather conditions. My safety protocols will provide a level of 

safety equal to 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

Designed 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-commercial 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 requirement Designed for manned aircraft; not suitable for 

sUAS 

14 CFR 91.9(b)(2) Requirement for manual to 

be available in the cockpit 

No onboard pilots or passengers to read 

manual 

14 CFR 91.103 Requires preflight action Preflight actions will differ for sUAS 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 

altitudes and will fly 200 AGL
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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 

certificates to be onboard 

No onboard 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 aircraft; 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.com
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