CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 1

CHRISTIAN HORAN PHOTOGRAPHY, INC.

EIN #: 46-2162131

16140 Dickens Street, Encino CA 91436

T: 415.637.8746 E: christianhoran@mac.com W: horanphotography.com

November 24, 2015 

U.S. Dept. of Transportation, Docket Operations 

1200 New Jersey Avenue, SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Re: Christian Horan Photography Inc. - Petition for Exemption to Operate 

Unmanned Aircraft Systems Pursuant to Section 333 of the FAA 

Reform Act, and Part 11 of the Federal Aviation Regulations from: 14 

CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (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, Christian Horan Photography Inc. an operator of an

Unmanned Aircraft System (“UAS”) for aerial photography and videography with the 

purpose of creating marketing photo and video media on behalf of hospitality (resort & 

hotel), real estate, yacht, and travel & tourism clients, hereby applies for an exemption 

from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UAS.

Attached additionally are the UAS manufacturer’s user manual, release notes, disclaimer, 

and safety guidelines. 

High definition photo and video from variable low level angles using the UAS specified 

below are very much desired, and effective than ground-based imagery. And further, is 

safer than utilizing a manned aircraft of significantly greater proportions, carrying crew 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 2

and flammable fuel. The benefits of reduced cost, reduced noise interference and 

improved quality of presentation from the UAS will be greatly beneficial to many 

hospitality professionals, real estate/private property owners, and travel & tourism 

boards. These industries will benefit from this low cost solution by increasing awareness 

of their offerings, and traffic to their locations. Thereby attracting more revenue to 

business and property, and increasing taxable opportunities. Under virtually all 

circumstances, all of the only property or structures near the sites are owned and 

operated by the same entity. Any complaint from a third party member of the public 

complaining of even a hint of invasion of privacy, founded in fact or not, and even within 

the private boundaries of the specific land parcel owner, and with the camera lens facing 

inward and focused only onto an owners parcel, will instantly be honored, resulting in 

immediate termination of aerial operations. 

Petitioner will operate the following UAS: DJI Inspire 1

Name and address of the applicant: 

Christian Horan Photography Inc. 

Attn: Christian Horan

Phone: 415-420-0866

Email: christianhoran@mac.com

Address: 16140 Dickens Street, Encino CA 91436

Regulations from which the exemption is requested: 

14 CFR 61.113(a) and (b) 

14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151(a) 14 CFR 91.405(a) 14 CFR 

407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) and (b) 

Petitioner will operate the following UAS: 

DJI Inspire 1 

The UAS operated by Christian Horan Photography Inc. weighs less than 55 pounds, 

including the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more 

than 50 knots, can hover, and simultaneously move vertically and horizontally. Christian 

Horan Photography Inc. will only operate its UAS in line of sight and will operate only 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 3

within the sterile area. Such operations will insure that the UAS will “not create a hazard 

to users of the national airspace system or the public.” Given the small size of Christian 

Horan Photography Inc.’s UAS and the restricted sterile environment within which they 

will operate, Christian Horan Photography Inc.’s UAS operations adhere to the Reform 

Act’s safety requirements. Additionally, due to the size of the UASs and the limited 

areas in which they will operate, approval of this application presents no national 

security issues. Based on the substantial level of safety surrounding the proposed 

operations, and the significant public benefit (enhanced safety), reduction in 

environmental impacts (reduced emissions and noise), the grant of the requested 

exemption is in the public interest. Accordingly, Christian Horan Photography Inc. 

respectfully requests that the FAA grant the requested exemption without delay. 

Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Christian Horan Photography Inc. provide for at 

least an equivalent or higher level of safety than when using conventional passenger 

carrying aircraft for photography and videography. 

1. The UAS will weigh less than 55 pounds. 

2. Flights will be operated within line of sight of a UAS, pilot and/or observer. 

3. Maximum flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 20 minute 

limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. UAS will be fitted with propeller guards to enhance the safety of surrounding 

personnel. 

6. Minimum crew for each operation will consist of the UAS Pilot, the Visual 

Observer, and the Camera Operator. 

7. A UAS pilot will be registered with FAA and pass an approved FAA Aeronautical 

knowledge exam when it becomes available. 

8. A UAS Pilot will be Pilot in Command (PIC). 

9. The UAS will only operate within a confined “Sterile Area.” Requiring the 

 establishment of a “Security Perimeter” for the flight operations area. 

10. A briefing will be conducted for planned UAS operations prior to each day’s flight. 

All personnel performing duties within the boundaries of the safety perimeter are 

required to attend. 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 4

11. The operator will obtain consent of all persons involved in the 

photography/recording and ensure that only consenting persons will be allowed 

within 10 feet of the flight operation, in accordance with equivalent level of 

safety determination with the advanced permission of the project manager, 

operations at closer range can be approved. 

12. The Pilot and observer must be trained in UAS operations and have received 

current information on the particular UAS to be operated. 

13. The Observer and pilot will at all times be able to communicate by voice, radio 

and/or text. 

14. Written and/or oral permission from the relevant property holders will be 

obtained. 

15. All required permissions and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

16. If the UAS loses communications or loses its GPS signal, the UAS will have

“failsafe” capabilities to return to a pre-determined location within the Security 

Perimeter and land. 

17. The UAS is equipped with alarm triggers to notify PIC of stage one battery 

decrease, making the PIC aware of near 25% reserve. 

18. Failsafe for low battery (25%) will also trigger a return to secure destination 

procedure. 

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

or emergencies. 

14 C.F.R. § 61.113(a) and (b): Private Pilot

Privileges and Limitations: 

Pilot in Command Sections 61.113 (a) and (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 

the PIC operating the aircraft to have a private pilot’s license rather than a commercial 

pilot’s license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is 

remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety 

exceeds that provided by a single individual holding a commercial pilot’s certificate 

operating a conventional aircraft. The risks associated with the use of a UAS are so 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 5

diminished from the level of risk associated with commercial operations contemplated 

by Part 61 allowing UAS use by a private pilot as the PIC exceeds the present level of 

safety sought by 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 

91.103 requires each pilot to preflight an aircraft before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is 

requested. However, an equivalent level of safety will be provided. The PIC will take all 

actions, including reviewing weather, flight battery requirements, landing and takeoff 

distances, and aircraft performance data before commencement of flight. 14 C.F.R. 

§91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for 

operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when 

necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: ..... (c) Over other than congested areas. An altitude of 400 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 400 feet to any person, vessel, vehicle, or structure.” 

Because Christian Horan Photography Inc. requests authority to operate at altitudes 

only up to 400 AGL an exemption is needed to allow such operations. The UAS will never 

operate higher than 400 AGL. It will, however, be operated in a restricted area within a 

security perimeter, 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, and speed of the UAS, as well as the location where it is operated. No 

flight will be taken without the permission of property owners or local officials. Because 

of the advance notice to the property owners and participants in the 

photography/recording activity, all affected individuals will be informed of the planned 

flight operations. Compared to flight operations for manned aircraft and the lack of 

flammable fuel, any risk associated with the proposed UAS operations is far less than 

conventional aircraft operating at or below 400 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between a UAS and conventional aircraft. 

14 C.F.R. §91.121 Altimeter Settings 

Section 91.121 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 a UAS may not have a 

barometric altimeter, but instead a GPS altitude data, an exemption is needed. An 

equivalent level of safety will be achieved by the operator, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 6

14 C.F.R. §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....” 

The battery powering Christian Horan Photography Inc.’s UAS provides approximately 

25 minutes of powered flight. To meet the 20-minute reserve requirement in 14 CFR 

§91.151, UAS flights will be limited to approximately 10 minutes in length. Given the 

limitations on the UAS’s proposed flight area and its proposed operations within a 

predetermined location, a longer time frame for flight in daylight VFR conditions is 

reasonable. Furthermore, operating the UAS in a tightly controlled area where only 

people, property owners, or official representatives who have signed waivers will be 

allowed, less than 20 minutes of reserve fuel does not engender the type of risk that 

§91.151(a) was intended to address. 

Christian Horan Photography Inc. believes that safety can be achieved by limiting flights 

to 10 minutes or 25% of battery power, whichever occurs first. This restriction would be 

more than adequate to return the UAS to its pre-determined landing zone from 

anywhere in its limited operating area. 

Christian Horan Photography Inc. is not seeking an exemption for nighttime UAS 

operations.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (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 sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Christian Horan Photography Inc.’s 

operations. Maintenance will be accomplished by the operator. An equivalent level of 

safety will be achieved because the UAS are limited in size, will carry a small payload 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 7

and operate only in restricted areas for limited periods of time. If mechanical issues 

arise, the UAS can land immediately and will be operating from no higher than 400 feet 

AGL. The operator will ensure that the UAS is in working order prior to flight, perform 

any required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the UAS and best suited to maintain it in an 

airworthy condition. 

Summary for Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Christian Horan Photography Inc. seeks an exemption from the following rules: 14 C.F.R. 

§§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanned vehicle (55 

pounds or less) for aerial photography and videography with the purpose of creating 

marketing photo and video media on behalf of hospitality (resort & hotel), real estate, 

yacht, and travel & tourism clients.

As established by the UAS exemptions already granted by the FAA, allowing commercial 

operations of UASs in the hospitality and real estate industries enhance safety by 

reducing risk. Conventional film operations, using turbine aircraft, operate at low 

altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, 

and which carry large amounts of Jet A fuel. Such aircraft must also fly to and from the 

film location. In contrast, a UAS weighing fewer than 55 pounds and powered by 

batteries eliminates virtually all of that risk given the small size and lack of combustible 

fuel. The UAS is carried, and not flown, to a film set. In this regard, the UAS carries no 

passengers or crew and, therefore, will not expose them to the risks associated with 

manned flights. 

The operation of UAS conducted will provide an effective level of safety supporting the 

grant of the exemption requested herein. The UAS operates at slow speeds, close to the 

ground, and in a sterile environment. As a result, they are far safer than conventional 

operations conducted with turbine helicopters carrying fuel and flying near the ground 

and people. 
CHRISTIAN HORAN PHOTOGRAPHY, INC.

16140 DICKENS STREET, ENCINO, CA 91436 415.637.8746 HORANPHOTOGRAPHY.COM 8

Privacy 

All flights will occur over private or controlled access areas with the property owner’s 

prior consent and knowledge. Filming will be only of people who have given their 

consent in writing or otherwise have agreed to be in the area where 

photography/recording/filming will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security) provide more than adequate 

justification to grant Christian Horan Photography Inc.’s requested exemption, allowing 

for Christian Horan Photography Inc.’s UAS commercial operations for aerial 

photography and videography with the purpose of creating marketing photo and video 

media on behalf of hospitality (resort & hotel), real estate, yacht, and travel & tourism 

clients.

If you have any questions or need any additional information, please contact Christian 

Horan at 415-420-0866 or at christianhoran@mac.com. 

Kind regards,

Christian Horan

President, Christian Horan Photography Inc.