July 1 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Wa shington, DC 205590
REF : Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR Part 21 , 14 CFR 45.23 (b) , 14 CFR 61.113 (a) & (b) , 14 CFR 91.7 (a) , 14 CFR 91.9 (b) (2) , 14 CFR 91.103, 14 CFR91.119 , 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) and 14 CFR 417 (a) & (b)

. Dear Sir,
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2 012 (the Reform Act) and 14 CFR Part 11, John Bishop, the operator of Texas Hill Country Photography , is equipped to conduct aerial photography for real estate marketing purpos es for realtors, architects, home builders and wedding venues.
Wehereby apply for an exemption from the list ed Federal Aviation Regulations ("FARs") to a llow commercial operation of our “UAV” (Unmanned Aerial Vehicle), so long as such o perations are co nducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive UA S under controlled conditions in airspace that is 1) below 2 00 feet , 2) not near airports or restricted air space, 3 ) predetermined and 4 ) controlled as to access. Approval of this exem ption would thereby fulfill the Sec retary of Transportation's responsib ilities to " ... establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333 (c) of the Reform Act.

Sincerely, John Bishop Texas Hill Country Photography 206 The Hills Dr

. The Hills, Tx 78738 512

- 997

- 8969**TA BLE OF CONTENTS** 

**I. Contact Information**  **II. UA** **S :**  **DJI Inspire 1 III.**  **Ai rcraft and Equivalent Level of Safety**  **IV. Specific Sections of Title 14 of the Code of Federal Regulations**  **from w hich exemptions are requested**  **V. Summary** 

**I. CONTA CT INFORMA** **TION:**
John Bishop 206 The Hills Dr

. The Hills, Tx 78738 512

- 997

- 8969 Email: John@TexasHillCountryPhotography.com

**II**

**. UA** **S: DJI INSPIRE 1**  ( See specifications in Appendix)
**Model** T600 **Weight (Battery**

**Included)** 6.47 lbs. **Max Speed** 42 kts **Max Flight Time** 18 minutes **Dimension** 18"x18"x12"

**III. A IRCRA**  **FT AND EQUIVA**  **LENT LEVEL OF SA FETY**  The applicant proposes that the exemption requested herein ap ply to civil aircraft that have the characteristics and that operate with the limitations l isted herein. These limitations provide for at least an equivalent or possibly higher level of safety to operations under the current regulatory structure because the propose d operations represent a safety enhancement to the a lready safe filming operations conducted with conventional aircraft.
These limitations and condition s to which Texas Hill Country Photography (John Bishop) agrees to be bound when conducting commercial operations under an FAA issued exemption include: 1. The UAS will weigh less than 10 lbs. (see specifications in appendix) 2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew (Spotter

/Safety Officer).3. Maximum total flight time for each operational flight wil l be 15 minutes. Flights

will always be terminated at 25% battery power reserve to ensure safe return to launch site. (Automatic return to launch site at 25% battery reserve is preprogrammed in the UAS controller application by the manufacturer.) 4. Flights will be operated at an altitude of no more than 2 00 feet AGL, though most operations will be conducted within 50

- 100 feet of the ground. (Flight above 400 feet is restricted in UA S controller application by the manufacturer). 5. Minimum two (2) man crew for each UA S operation will con sist of the Pilot and a Spotter

/Safety Officer

. 6. Texas Hill Country Photography’s aerial team consists of John Bishop (owner), Charles Bishop (father & employee) and a commercial pilot consultant. (David Temp li n , United Airlines )

. 7. Charles Bishop has attended multiple UA S safety and FAA information al classes within the last year including; UA S Direct’s Private Pilot Introductory Ground School (taught by private p ilot George Farris), Drone Introduction: Rules and Regulations at Precision Camera taught by police office an d accomplished drone instructor John Buell (www.dronepilot.io ) and a video training course: DJI Phantom Qu adcopter Drones and Aerial Photography produced by PhotoShopCAFE. John and Charles Bishop will continue to attend new and updated UA S classes as they become available. 8 . The UA S Pilot will be John Bishop, a 30 year old male in good health and a valid Texas driver's license. 9 . The UA S Pilot will serve as Pilot in Command (PIC). 10 . The UA S will onl y operate within central Texas including the counties of Travis, W illiamson, Hays, Blanco, Burnet, Comal, Gillespie, Caldwell and Llano. No flights will occur near regional airports or near populated cities. 11 . The UA S will never enter any MOA or Restricted Airspace, nor shall it violate any TFR as outlined by the FAA. Flying near airports is automatically prevented by the UA S manufacturer which is controlled by preprogrammed GPS location data. 12 . A pre

-flight briefing will be conducted in regard to the plan ned UA S operation prior to each day's flying and recording activitie s. It will be mandatory that all personnel who will be performing duties as "flight crew" be present for this briefing. 13

. The Pilot and Spotter/Safety Officer will have been trained in operation of UA S and received up

-to

- date information on the particular UA S to be operated as required. 14

. The Pilot and Spotter/Safety Officer will at all times be able to communi cate by voice

. 15

. Wr itten and/or oral permission from the relevant property holders will be obtained in advance in all cases

. 16 . If the UAS loses communication or loses its GPS signal, the UA S will have the capability to return to a pre

- determined location and land automatically

. ( This is a DJI Inspire 1 standard capability)

. 17 . The UA S will have the capability to abort a flight in c ase of unpredicted obstacles or emergencies.18

. The Pilot will abide by all Texas Aircraft UA S Operations rules and

regulations

. 19. Visual line of sight (VLOS) will always be maintained between PIC and SO and the UAS during scheduled flight operations. 20

. The PIC shall be trained in the operation of the specific make and model of the UAS being piloted and successfully completed all training required. 21

. The PIC shall have accumulated and logged a minimum of 200 flight cycles and 25 hours of total time on a DJI Inspire 1 UA S

. T o stay fresh with the UAS functionality, t he PIC shall have conducted at least three take

- offs and three landings in the preceding 90 days. Training, proficiency, and experience

- building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time.

a. During training, proficiency, and experien ce - building flights, all persons not essential for flight operations are considered non

- participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR §91.119. b. The UA S Safety Observer (SO) shall meet all training requirements and be responsible for all of his duties as set forth by UA S User and Safety Manual s and in ordinance with the conditions for exemption as set out in this document

. c. The PIC and SO will be design ated before each flight. (John Bishop as PIC and Charles Bishop as SO ) d . Minimum crew for each flight operation will consist of the UAS PIC and SO. e . The PIC and SO shall always be within visual line of sight (VLOS) of each other and in direct verbal com munication at all times. f . Safety Briefings shall be conducted before each day's activities to include, but not limited to: Designated roles of PIC and SO and Risk Management and Mitigation

. **IV . THE SPECIFIC SECTIONS OF TITLE 14 OF THE C**  **ODE OF FEDERA L**  **REGULA TIONS FROM**  **WHICH Texas Hill Country Photography**  **REQUESTS EXEMPTION A** **RE:**

14 CFR Part 21 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR91.119 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)

This exemption application is expressly submitted to fulfill Co ngress' goal in passing Section 333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider whether certain unmanned aircraft systems (UAS), also known as unmanned aerial vehicles (UAV), may operate safely in the national airspace system (NAS) before completion of the rulemakin g required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: • The UAS's size, weight, s peed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. Reform Act §333 (a). Lastly, if the Secretary determine s that such vehicles "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." The Federal Aviation Act expressly grants the FAA the authori ty to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §401 01 of the Act; that includes UAS s , 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 subsectio n (a) or (b) of this section or any sections 44702

- 44716 of this title if the Admin istrator finds the exemption in the public interest. 49 U.S.C. §44704 ; 14 CFR §91.203 (a) (1). Texas Hill Country Photography ’s UA S is a small rotorcraft aircraft, the DJI I nspire 1, weighing less than 10 lbs. including camera payload. Weoperate the rotorcraf t, under normal conditions at a speed of no more than 20 knots, usually 3

- 5 knots, and ha ve the capability to hover and move in the vertical and horizontal plane simultaneously. Wewill manually operate only in Visual Line of Sight and will operate only within the operating parameters as described in the DJI Inspire 1 Operating and Safely M anual s ( see appendix) Adherence to these manuals will insure that the UAS will "not create a hazard to the national airspace system or the public." Given the small size and weight of the UAS involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UA S s to commence immediate ly. Also d ue to the size of the UA S and the areas in which the relevant UA S will opera te, approval of the application presents no national security issue. Given the clear direction in S ection 333 of the Reform Act, the authority contained in the Federal Aviation Act , as amended; the strong equivalent level of safety, surrounding the proposed operations, andsignificant public benefit, including enhanced safety, reduction in environmental

impa ct, including reduced emissions associated with allowing UA S for real estate marketing operations, (as opposed to full scale aircraft), the granting of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FA A grant the requested exemption without delay for the following sections of Title 14 of the Code of Federal Regulations:

**14 CFR Part 21, Subpart H: A irw**  **orthiness Certificates 14 CFR §91.203 (a) (1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issua nce 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 the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent leve l of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from t he requirement capability and proximity to airports and populated areas of the particular UAS

. In all cases, an analysis of these criteria demonstrates that the UA S 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 (fixed

-win g or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UA S to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot nor passenger, carri es neither explosive materials nor fl ammable liquid fuels, and operates exclusively within a limited radius area as set out in the preflight briefing . Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the PIC , pursuant to safety requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional aircraft. These safety enhancements, which already apply to civil aircraft operated in connection with video production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. La stly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UA V , due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. **14 CFR §45.23 (B): Marking of the A ircraft** The regulation requires: Wh en marks include only the Roman capital letter "N"

and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restri cted", "light sport " , "experimental," or "provisional," as applicable. Even though the UA S 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 UAV, two inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAV marked on its fuselage as required by §45.29 (f) where the Pilot, Spotter/Safety Officer and others working with the UAV will see the identification of the UA S as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10 700, 8738, 10167 and 10167A. **14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations** 

- Pilot in Command (PIC) Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UA S will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring our PIC to have a commercial pilot (David Templin, United Airlines) , as a flight consultant within Texas Hill Count ry Photography

. Our commercial pilot works closely with us to ensure we understand and operate within the appropriate FAA guidelines as outlined in this document. Unlike a conventional aircraft that carries the pilot and passengers, the UA S is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the UAS User and Safely Manual s and as per our consulting commercial pilot . The level of safety provided by these procedures meets that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with commercial operations contemplated by Part 61 when drafted, that allowing o perations of the UAS as requested with a commercial pilot on staff exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b). **14 CFR §91.7 (a): Civil A ircraft A**  **irw orthiness**  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 requi rements contained in the User and M aintenance Manuals and use of safety checks prior to each flight , an equivalent level of safety will be provided. **14 CFR §91.9 (b) (2): Civil A ircraft Flight Manual in the A** **ircraft** Section 91.9 (b) (2) provides: No perso n may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by§21.5 of this chapter, unless there is available in the aircraft a current approved

Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS , given its 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 Operating Manual at the ground control point where the pilot is flying the UAS will have immediate access to it. In addition , a flight ch eck list is followed for each and every flight ensuring the Operating Manual directions are followed. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167,10167A 10602, 32827, and 10700 **14 CFR §91.103: Preflight A ction**  This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the Operating Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initi ation of flight. In addition, a flight check list is followed for each and every flight ensuring the Operating Manual directions are followed. **14 CPR § 91.119: Minimum Safe A ltitudes**  Section 91. 119 establish es safe altitudes for operation of civil aircraft . Section 91.119 (d) allows helicopters to be ope rated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UA S , Texas H ill Country Photography (John Bishop) requests authority to operate at altitudes up to but not exceeding 2 00 fee t AGL; an exemption may be needed to allow such operations. As set forth herein, the UA S will never operate higher than 2 00 ft. AGL. (Altitude will be limited to less than 2 00 feet by settings in the flight controller application ) It will however be operated in a controlled area where buildings and people will not be exposed to operations without their pre

- obtained consent. The equival ent level of safety will be achieved given the size, weight, speed of the UA S as well as location where it is operated. No flight will be taken without the permission of the property owner. Because of the advance notice to the property owner and participa nts in the photographic activity, all affected individuals will be aware of the planned flight operations as set forth in the photography shoot schedule

. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 10 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 ft. AGL. In addition, the low

- altitude operations of the UA S will ensu re separation between these small UA S operations and the operations of conventional aircraft that must comply with Section 91.119.**14 CPR § 91.121 : A** **ltimeter Settings**

This regulation requires each person operating an 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 UA S will not have a barometric altimeter, but instead a GPS altitude read out, an exem ption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Operating Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 CPR §91.151 (a): Fuel Requirements for Flight in VFR Conditions**  Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 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 (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the UA S provides approximately 20 minutes of powere d flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be impossible. Given the limitations on the UAS 's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is not possible

. Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS , in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UA

V . Additionally, limiting UA S flights would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 15 minutes or 25% of reserve battery power whichever happens first. This restriction would be more than adequate to enable return of the UA S to its planned landing zone from anywhere in its limited operating area. The UA S is setup to automatically return to the launch site when the battery reaches 25% capacity. This is more than adequate to ensure the UA S safely returns to the launch site wi thin the predetermined restricted flight area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 57 45, 1 0673, and 10808.**14 CFR §91.203 (a) and (b): Carry ing Civil A**  **ircraft Certification and**

**Registration** The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and cu rrent airworthiness certificate

... (b) No person may operate a civil aircraft u nless the airworthiness certificate required by paragraph (b) of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UA S fully loaded weighs no more than 10 lbs. and is operated without an onboard Pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UA S

. 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 , and should they be issued. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 CFR §91.405 (a); 407 (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 ... ," and others shall inspect or maintain t he aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator; pursuant to the Maintenance M anual for the UA S ( http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_e n.pdf ) . An equivalent level of safety will be achieved because these small UA S s are very limited in size and will carry a small camera and operate only in restricted areas for limited periods of time. If mechanical issues arise , the UA S can land immediately and will be operating at no higher than 400 ft. AGL. As provided in the Maintenance and User Manual s , the PIC (operator) will ensure that the UA S is in working order prior to initiating flight, and perform required maintenance. 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. Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: D 14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & ( b);91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate

commercially a small unmanned vehicle for real estate m arketing purposes

. **Privacy** All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Image capture of people will rarely take place, but in the event they are, they will have consented prior to being filmed or otherwise have agreed to be in the area where data collection will take place.
**Ai rborne Image Capture** 
Wi th regard to airborne filming, John Bishop will adhere to a ll FAA regulations. Further John Bishop’s airborne team operate s under the principals of; Safety First, Quality Assurance, Accountability, Reporting and Training.
Wh en approved by the FAA it is John Bishop’s mandate to treat all UAS operations with the exact same level of professionalism and seriousness as that of conventional aircraft. Approval of exemptions allowing commercial operations of UA S in the real estate industry will enhance safety by reducing risk. Conventional filming operations, using turbine or piston powered aircraft present the risks associated with vehicles that weigh in the neighborhood of 2,000 l bs +, carrying large amounts of Jet A fuel. Such aircraft must fly to and from photographing location. In contrast, a UA S weighing fewer than 10 lbs. and powered by batteries eliminates virtually all of the risk given the substantial ly reduced mass and lack of combustible fuel carried on board. The UA S is typically transported to the location via auto or cargo van in a medium sized case and is never flown to operational site

. The UA S will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft. The operation of small UA S , weighting less than 10 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with piston helicopters or fixed win g aircraft opera ting in relatively close proximity to the ground and people. The primary market of interest for John Bishop utilizing UAV is to support the marketing of real estate property , architects, home builders and wedding venues

. T he airborne image capture process will be accomplished exclusively in day time VFR environments. To capture the highest quality of resolution all of the airborne data collections will take place during daylight hours, typically between 07:00 am 07:00pm (19:00 )

.**V. Summary**

Wehereby apply for an exemption from the list ed Federal Aviation Regulations ("FARs") to a llow commercial operation of our “UA S ” (Unmanned Aircraft ), so long as such o perations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required by Section 333. This would enable commercial operation of applicant’s UA S in the real estate industry resulting in accelerated commercial development in central Texas. This would be done with fewer safely, environmental or national security issues than conventional piston powered helicopters or fixed wing aircraft currently being used for this purpose

. John Bishop is eagerly standing by to support the FAA and UA S community in its quest to establish proper regulations and protocols for the safe introduction of unmanned aircraft into the national airspace.

Sincerely, John Bishop Texas Hill Country Photography 206 The Hills Dr

. The Hills, Tx 78738 512

- 997

- 8969**Ap pendix** 

(UAS ): DJI Inspire 1 User Manual, Maintenance Manual and Safely Manual are available from DJI at: http://www.dji.com/product/inspire

- 1/download
These manuals are in Texas Hill Country Photography’s flight team’s possession and are utilized in conducting all aerial photography sessions. **Specifications**
Aircraft
Model T600 We ight (Battery Included) 2935 g Hovering Accuracy (P Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude 4500 m (lim ited to maximum of 400 ft) Max Wi nd Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range

- 10° to 40° C Diagonal Distance 559 to 581 mm Dim ensions 438x451x301 mm
Gimbal
Model ZENMUSE X3 Output Power (W ith Cam era) Static: 9 W ; In Motion: 11 W Operating Current Station: 750 mA; Motion: 900 mA Angular Vibration Range ±0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30° Pan: ±320° Mechanical Range Pitch:

- 125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°
Camera
Name X3 Model FC350 Total Pixels 12.76M Effective Pixels 12.4M Image Max Size 4000x3000 ISO Range 100

- 3200 (video) 100

- 1600 (photo) Electronic Shutter Speed 8 s to 1/8000 s FOV (Field Of View) 94° CMOS Son y EXMOR 1/2.3”Lens 20mm (35mm format equivalent) f/2.8 focus at ) 9 Elements in 9 groups Anti

- distortion Still Photography Modes Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate Of Video Storage 60 Mbps Supported File Forma ts FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported SD Card T yp es Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required. Operating Temperature Range 0° to 40° C
Remote Controller
Name C1 Operating Frequency 922.7MHz~927.7 MHz (Japan Only) 5.725~5.825 GHz;2.400~2.483 GHz Transmitting Distance 2 km (Outdoor And Unobstructed) EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, Mini

- HDMI Power Supply Built

- in battery Charging DJI charger Dual User Capability Host

- and

- Slave connection
Mobile Device Holder Tablet or Smart Phone Output Power 9 W Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0

- 40° C Battery 6000 mAh LiPo 2S Charger
Model A14

- 100P1A Voltage 26.3 V Rated Power 100 W Battery (Standard)
Name Intelligent Flight Battery Model TB47 Capacity 4500 mAh Voltage 22.2 V Battery T ype LiPo 6S High voltage battery Energy 99.9 W h Net W eight 570 g Operating Temperature Range

- 10° to 40° CStorage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W

Battery (Optional)
Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery T ype LiPo 6S Energy 129.96 W h Net W eight 670 g Operating Temperature Range

- 10 to 40° C Storage Temperature Range Less than 3 months:

- 20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range 5

- 500 cm Operating Environment Brightly lit (lux > 15) patterned surfaces Operating Range 0

- 250 cm DJI Pilot App Mobile Device System Requirements iOS version 7.1 or later; Android version 4.1.2 or later Supported Mobile Devices iPhone 6 Plus, iPhone 6, iPhone 5S, iPad Air 2, iPad Mini 3, iPad Air, iPad Mini 2, i Pad 4;* Sam sung Note 3, Samsung S5, Sony Z3 EXPERIA