Taylor Blom

Front Door Photos 

www.frontdoorphotos.net 

4717 W Perry Circle 

Holland, MI 49424 

October 19, 2015 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Petition for exemption request under Section 333 of the FAA 14 C.F.R Part 11

Dear Sir or Madam:

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 

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.

An exemption is being requested because (1) existing regulations will unduly burden

Front Door Photos LLC, (2) Some of the existing regulations are impossible to comply with, (3) 

Petitioner can provide a level of safety that is equal (or greater than in many cases) to those 

provided by existing rules, and (4) the request is in the public interest. The FAA's authority to 

issue exemptions from operating rules, and the Secretary's authority granted by Section 333 of 

P.L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, provide an opportunity to

authorize certain UAS operations in the National Airspace System (NAS) prior to implementation 

of the UAS rule. This incremental step will allow Front Door Photos to safely and legally enter 

into the NAS. 

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 pre-check 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 multi-rotor 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 ground-level 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 pre-flight examinations. 

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

Granting this exemption would benefit the public as a whole. UAS offer a strong

equivalent or greater level of safety while reducing environmental impacts, as they are free from 

the harmful emissions associated with the manned aircraft that are currently used for aerial 

photography and videography. Due to the small size of the UAS and the tightly controlled and 

limited airspace in which the UAS will operate, approval of this application actually reduces the 

risk to the public. Furthermore, the public will be able to legally acquire aerial photography and 

videography in a cost-effective manner to help in advertising commercial, residential and 

agricultural property for sale or development, thus improving the local real estate market and 

economy as a whole. 
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 minimize ecological damage and promote economic growth. 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