December 24, 2015

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

Dear Administrator:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I Dale Honning of dalehonning.com a 

real estate photography and videography for hire service would like to apply for an exemption from the 

Federal Aviation Regulations (“FAR’s) to allow operation of my UAS’s for commercial use.

Applicant Information

Applicant: Dale Honning – Owner – Sole Proprietor 

Business Name: dalehonning.com

Business Address: 2185 Crabtree Dr, Greenwood Village, CO 80121

Email: dale@dalehonning.com

Phone: 720-244-7676

Regulations from which exemption is requested:

14 CFR Part 21 Experimental certificates

14 CFR 45.23 (b) Aircraft Registration Number Size

14 CFR 61.113 (a) & (b) Private Pilot Privileges and Command

14 CFR 91.7 Air Worthiness Certificate

14 CFR 91.9 Aircraft Flight Manual & Documentation

14 CFR 91.119 Minimum Safe Altitudes

14 CFR 91.121 Altimeter Settings 

14 CFR 91.151 Fuel Requirements

14 CFR 91.203 (a) & (b) Civil Aircraft – Certifications Required

14 CFR Subpart E (91,401 – 91,417) Maintenance, Preventive Maintenance, Alterations

Proposed intended business use of UAS’s and their operation.

Photography and videography of commercial and residential real estate for sale. Commercially, I would 

be only flying over private property and always with prior authorization of the property owner for the 

purpose of taking photos or video to sell the home. The altitude required would routinely be between 

80 – 150 feet with the horizontal distance being roughly the same. The majority of my flights would be

over residential homes with most being in rural locations. They would take place during the daylight

hours of approximately 10am – 3pm. During that time, there are minimal, and it is more likely than not, 

that there are NO persons in the area. It is rare for me to see someone while on a shoot bringing the 

likelihood of an accident involving a person on the ground to an extremely low level.

How do my services benefit the public? Since 2001 my main clientele has been Realtors. I photograph 

the interior and exterior of their home and property listings. Regarding the exterior views, in the past we 

may have hired an aircraft for aerial views to provide a unique view of their properties. This was costly, 

used excessive fuel and posed a much higher risk factor than today’s technologies afford. By using UAS’s 
to accomplish that same goal, we can now provide those same services at a fraction of the cost, with 

less impact on the environment and with little or no risk to persons on the ground.

My UAS Qualifications

I have 5 years of UAS flight experience. This year alone, I have accumulated over 65 hours of flight time 

during 493 flights without accident or incident flying the UAV’s mentioned below

The types of craft I use.

DJI Phantom 3Pro & DJI Inspire 1. 

I believe both of these crafts meet the requirements stated in the Reform Act for safety and control and 

that they have received like grants in other petitions. Both craft are well known and in popular use.

You can find additional information about these crafts by following the links below.

DJI Phantom 3Pro... http://www.dji.com/product/phantom-3-pro/info#specs

DJI Inspire 1... http://www.dji.com/product/inspire-1/info#specs 

To maximize safety.

My flight polices are always strictly adhered to. These include but are not limited to the following...

1) Have full knowledge of all flight manuals and local restrictions.

2) Only fly in clear weather with a visibility greater than 5 miles.

3) Only fly during daylight hours.

4) Wind speed no greater than 10 mph.

5) Never fly within 5nm of an airport reference point unless a letter of agreement with that 

airports management is obtained or otherwise permitted by a COA issued to me.

6) Always fly below 400 ft. AGL. (as stated above)

7) Flights limited to 10 minutes.

8) Always land craft with 30% battery power remaining.

9) Always maintain communication or GPS signal. If not return to home immediately.

10) Craft ID always prominently displayed. Currently name & phone on all craft. Upon registration, 

for both recreational and commercial use, I will display both numbers.

11) Establish and maintain all flight logs.

12) All craft are maintained and updated to manufactures specifications.

My flight checklist includes but is not limited to the following...

1) Establish flight plan and look for any potential obstacles or hazards along the path.

2) Establish a clear launch and land locations for both normal and emergency situations.

3) Be aware of any maned or un-maned aircraft in the area and be prepared to land in my preestablished location if one should approach.

4) Check that no persons will be in or around the flight path.

5) Notify any persons that MAY enter into or around the flight path to stay back 100 feet.

6) Check all batteries for full charge and condition.

7) Check all propellers for tightness and condition.

8) Check all landing gear and moving parts for proper operation.

9) Check all electrical systems are operational and updated to their latest firmware versions.

10) Check “Return to Home” is set, lock and engaged.

11) Check GPS lock and home point set are activated.

12) Look and Launch – Maintain Awareness

13) Look and Land

14) Post flight all systems and craft check
I would ask for additional relief from having to retain a spotter to assist me on all jobs for the 

following reasons...

1) I am a sole proprietor and a single person business.

2) I would only fly within line of sight. When this cannot be accomplished from an initial launch 

location I would land and reposition myself so that visual contact can be maintained at all times. 

Example: moving from front to rear of home. This keeps the craft always within view and within 

50 – 150 feet away from me.

3) The majority of my flights would be over residential homes with most being in rural locations.

They would take place during the daylight hours of approximately 10am – 3pm. During that 

time, there are minimal, and it is more likely than not, that there are NO persons in the area. It 

is rare for me to see someone while on a shoot bringing the likelihood of an accident involving a 

person on the ground to an extremely low level.

4) The additional cost to hire a spotter would add additional expense to the end user, put me at a 

competitive disadvantage and not improve public safety for the reasons stated in items 1 & 2. 

Thank You for your consideration regarding each of the sections above. Please contact me by the 

methods below if you have additional questions and when your decisions are complete.

Dale Honning

Owner – dalehonning.com

Email – dale@dalehonning.com

Phone – 720-244-7676

Mailing Address – 2185 Crabtree Dr, Greenwood Village, CO 80121