July 1, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, 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 2012 (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 purposes for realtors, architects, home builders and wedding venues. 

We hereby apply for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of our “UAV” (Unmanned Aerial Vehicle),

so long as such operations are conducted 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 UAS under controlled 

conditions in airspace that is 1) below 200 feet, 2) not near airports or restricted 

air space, 3) predetermined and 4) controlled as to access. Approval of this 

exemption would thereby fulfill the Secretary of Transportation'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.

Sincerely,

John Bishop

Texas Hill Country Photography

206 The Hills Dr.

The Hills, Tx 78738

512-997-8969
TABLE OF CONTENTS

I. Contact Information

II. UAS: DJI Inspire 1

III. Aircraft and Equivalent Level of Safety 

IV. Specific Sections of Title 14 of the Code of Federal Regulations 

from which exemptions are requested

V. Summary

I. CONTACT INFORMATION:

John Bishop

206 The Hills Dr.

The Hills, Tx 78738

512-997-8969

Email: John@TexasHillCountryPhotography.com

II. UAS: 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. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or possibly higher level of

safety to operations under the current regulatory structure because the proposed 

operations represent a safety enhancement to the already safe filming operations 

conducted with conventional aircraft. 

These limitations and conditions 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 will 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 200 feet AGL, though 

most operations will be conducted within 50 -100 feet of the ground. (Flight 

above 400 feet is restricted in UAS controller application by the manufacturer). 

5. Minimum two (2) man crew for each UAS operation will consist 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 

Templin, United Airlines).

7. Charles Bishop has attended multiple UAS safety and FAA informational

classes within the last year including; UAS Direct’s Private Pilot Introductory 

Ground School (taught by private pilot George Farris), Drone Introduction: Rules 

and Regulations at Precision Camera taught by police office and accomplished 

drone instructor John Buell (www.dronepilot.io) and a video training course: DJI 

Phantom Quadcopter Drones and Aerial Photography produced by 

PhotoShopCAFE. John and Charles Bishop will continue to attend new and 

updated UAS classes as they become available. 

8. The UAS Pilot will be John Bishop, a 30 year old male in good health and a 

valid Texas driver's license. 

9. The UAS Pilot will serve as Pilot in Command (PIC). 

10. The UAS will only operate within central Texas including the counties of 

Travis, Williamson, Hays, Blanco, Burnet, Comal, Gillespie, Caldwell and Llano. 

No flights will occur near regional airports or near populated cities. 

11. The UAS 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 UAS manufacturer which is controlled by preprogrammed GPS location 

data. 

12. A pre-flight briefing will be conducted in regard to the planned UAS operation 

prior to each day's flying and recording activities. 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 

UAS and received up-to-date information on the particular UAS to be operated as 

required. 

14. The Pilot and Spotter/Safety Officer will at all times be able to communicate 

by voice. 

15. Written 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 UAS will have 

the capability to return to a pre-determined location and land automatically. (This 

is a DJI Inspire 1 standard capability). 

17. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 
18. The Pilot will abide by all Texas Aircraft UAS 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 UAS. To stay fresh with the UAS

functionality, the 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 experience-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 UAS Safety Observer (SO) shall meet all training requirements and be 

responsible for all of his duties as set forth by UAS User and Safety Manuals and 

in ordinance with the conditions for exemption as set out in this document.

c. The PIC and SO will be designated 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 communication 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 CODE OF FEDERAL 

REGULATIONS FROM WHICH Texas Hill Country Photography REQUESTS 

EXEMPTION ARE:

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 Congress' 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 rulemaking 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, speed, 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 determines 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 authority 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 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 

U.S.C. §44704; 14 CFR §91.203 (a) (1).

Texas Hill Country Photography’s UAS is a small rotorcraft aircraft, the DJI 

Inspire 1, weighing less than 10 lbs. including camera payload. We operate the

rotorcraft, under normal conditions at a speed of no more than 20 knots, usually 

3-5 knots, and have the capability to hover and move in the vertical and 

horizontal plane simultaneously. We will 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 Manuals (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 UASs to commence immediately. Also due to the size of the UAS

and the areas in which the relevant UAS will operate, approval of the application 

presents no national security issue. Given the clear direction in Section 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, and 
significant public benefit, including enhanced safety, reduction in environmental 

impact, including reduced emissions associated with allowing UAS 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 FAA 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: Airworthiness Certificates 14 CFR §91.203 (a) 

(1)

Subpart H, entitled Airworthiness Certificates, 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 the Applicant, 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 U.S.C. §44701 (f)) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the requirement 

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 

(fixed-wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. The UAS to be operated hereunder is less 

than 10 lbs. fully loaded, carries neither a pilot nor passenger, carries neither 

explosive materials nor flammable 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. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by 

the UAV, 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 Aircraft
The regulation requires: When 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," "restricted", "light sport", "experimental," or "provisional," as applicable.

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 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 UAS as "Experimental." The FAA has issued 

the following exemptions to this regulation to Exemptions Nos. 10700, 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 UAS 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 Country 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 UAS 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 Manuals 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 operations 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 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 and Maintenance 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 Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person 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 

check 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 Action

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 initiation 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 Altitudes

Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated 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 UAS, 

Texas Hill Country Photography (John Bishop) requests authority to operate at 

altitudes up to but not exceeding 200 feet AGL; an exemption may be needed to 

allow such operations. As set forth herein, the UAS will never operate higher than

200 ft. AGL. (Altitude will be limited to less than 200 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 equivalent level of safety will be achieved given the size, weight, 

speed of the UAS 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 participants 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 UAS will ensure separation 

between these small UAS operations and the operations of conventional aircraft 

that must comply with Section 91.119.
14 CPR § 91.121: Altimeter 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 UAS will 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 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 UAS provides approximately 20 minutes of powered 

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 UAV. Additionally, limiting UAS 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 UAS to its 

planned landing zone from anywhere in its limited operating area. The UAS is 

setup to automatically return to the launch site when the battery reaches 25% 

capacity. This is more than adequate to ensure the UAS safely returns to the 

launch site within 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): Carrying Civil Aircraft 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 current airworthiness certificate...

(b) No person may operate a civil aircraft unless 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 UAS 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 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, 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 the 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 

Manual for the UAS (http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_e

n.pdf ). An equivalent level of safety will be achieved because these small UASs

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 UAS

can land immediately and will be operating at no higher than 400 ft. AGL. As 

provided in the Maintenance and User Manuals, the PIC (operator) will ensure 

that the UAS 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 marketing 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.

Airborne Image Capture

With regard to airborne filming, John Bishop will adhere to all FAA regulations. 

Further John Bishop’s airborne team operates under the principals of; Safety 

First, Quality Assurance, Accountability, Reporting and Training. 

When 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 UAS 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 lbs +, 

carrying large amounts of Jet A fuel. Such aircraft must fly to and from 

photographing location. In contrast, a UAS weighing fewer than 10 lbs. and

powered by batteries eliminates virtually all of the risk given the substantially

reduced mass and lack of combustible fuel carried on board. The UAS is typically 

transported to the location via auto or cargo van in a medium sized case and is 

never flown to operational site. 

The UAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft. The operation of small UAS, 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 

wing aircraft operating 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.

The 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 am07:00pm (19:00).
V. Summary

We hereby apply for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of our “UAS” (Unmanned Aircraft), so 

long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.

This would enable commercial operation of applicant’s UAS 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 UAS 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
Appendix

(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

Weight (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 (limited to maximum of 400 ft)

Max Wind 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

Dimensions 438x451x301 mm

Gimbal

Model ZENMUSE X3

Output Power (With Camera) 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 Sony 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 Formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types 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 Type LiPo 6S High voltage battery

Energy 99.9 Wh

Net Weight 570 g

Operating Temperature Range -10° to 40° C
Storage 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 Type LiPo 6S

Energy 129.96 Wh

Net Weight 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, iPad 4;* 

Samsung Note 3, SamsungS5, Sony Z3 

EXPERIA