CHRISTIAN HORAN PHOTOGRAPHY , INC.

16140 DICKENS STREET

, ENCINO , CA 9 1436 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 (“ U AS ”) for aerial photography and videogra phy with the purpose of creating marketing photo and video media on behalf of hospitality (resort & hotel), real estate, yacht, and travel & tourism clients, he reby 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 phot o 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 crewCHRISTIAN HORAN PHOTOGRAPHY , INC.

16140 DICKENS STREET

, ENCINO , CA 9 1436 415.637.8746 HORANPHOTOGRAPHY.COM 2 and flammabl e 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, r eal estate/ private p roperty owners, and travel & tourism

boards

. These industr ies 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 pr operty 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 bounda ries 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 Ins pire 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. weigh s 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 onlyCHRISTIAN HORAN PHOTOGRAPHY , INC.

16140 DICKENS STREET

, ENCINO , CA 9 1436 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

Ho ran 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

ar eas 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

environmenta l 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 videog raphy.

1. The UAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight o f 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 g uards 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 Pilo t 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.

A ll personnel performing duties within the boundaries of the safety perimeter are required to attend

.CHRISTIAN HORAN PHOTOGRAPHY , INC.

16140 DICKENS STREET

, ENCINO , CA 9 1436 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 f eet 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 rec eived 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 batter y (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 controlle d 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 UA S are soCHRISTIAN HORAN PHOTOGRAPHY , INC.

16140 DICKENS STREET

, ENCINO , CA 9 1436 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: Preflig ht 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 provid ed. 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. reque sts 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 pe ople will not be exposed t o 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 permi ssion 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 aircr aft 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 mai ntain 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, a n 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 9 1436 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 cruis ing 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, U AS 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 in spect 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 payloadCHRISTIAN HORAN PHOTOGRAPHY , INC.

16140 DICKENS STREET

, ENCINO , CA 9 1436 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 imm ediately 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 publica tion 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

alti tudes 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

bat teries 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 associ ated with manned flights.

The operation of UA S conducted will provide an effective level of safety supporting the grant of the exemption requested herein. The UAS operate s at slow speeds, close to the ground, and in a sterile environment. As a result, th ey 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 9 1436 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 k nowledge. 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 adequa te 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

,

Chris tian Horan President, Christian Horan Photography Inc

.