KeeSnap Photography

CO: Christopher Keeran

(512) 677-7627

P.O. Box 4821 

8027 Bronco Ln.

Lago Vista, TX 78645

Federal Aviation Administration:

On behalf of KeeSnap Photography I would like to submit for an exemption from part 21, subpart H; and 

Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This 

proposed exemption would allow our business to operate an unmanned aircraft system (DJI Inspire 1) in 

Central Texas for the purpose of providing high quality imaging/videos for various commercial, public, 

and residential uses. Our primary market will be Real Estate, construction sites, appraisals, and building 

inspections.

We will operate the UAS DJI Inspire 1 Pro and Phantom 2 to perform these operations. 

Inspire 1 Pro Specification:

Model T600

Weight (Battery Included) 6.5 pounds

Hovering Accuracy (GPS 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

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

Power Spectral Density 9.06mW/MHz
Phantom 2 Specification:

Weight (Battery & Propellers Included) 2.5 Pounds

Hover Accuracy (Ready To Fly) Vertical: 0.8m/Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

Max Flight Speed 15m/s(Not Recommended)

Diagonal Length 350mm

Flight Time 25mins

Take-Off Weight ≤1300g

Operating Temperature -10°C ~ 50°C

Supported Battery DJI Smart Battery

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption, which ensures a 

level of safety at least equal to existing rules:

Training	and	Certifications

- Qualified UA Pilots

o To comply with 14 CFR 61.51(b), KeeSnap Photography provides a pilot training course 

for prospective pilots which consists of a safety course and flight school. This training 

requires the pilots to log 25 hours of flight time on a muti-rotor (Rotocraft) model which is 

used in the field. Pilots must be able to repeatedly display knowledge of all safety 

precautions, pre-flight, takeoff, In the Air, and Landing procedures to operate a UA in the 

field.

Approved	Equipment

- ONLY KeeSnap Photography owned UA's which are registered with the FAA are approved 

for flight and for photography sessions only. A personal UAS is not allowed for business 

use.

Safety

- Ensure you follow the guidelines outlined by the FAA at http://www.faa.gov/uas/

o Events such as the president or other political leaders may cause larger no-fly zones. 

Always check the FAA site prior to scheduling a session.

o Do NOT operate the UA in the vicinity of manned aircraft, regardless of altitude. If a 

manned aircraft is in the vicinity land the UA immediately.

o If the assigned property is in a populated area, such as downtown, ensure the authorities 

have been notified and any requirements are met prior to scheduling the session.

- Create a Flight Path

o Before powering on the UA survey the flight path to ensure there are no obstructions or 

potential dangers to surrounding individuals and/or structures.

o Power lines are difficult to see when operating the UA so take note of all power lines or 

tall structures such as trees or buildings prior to takeoff.

o Ensure all pre-designated flight plans are free of any objects.

o Ensure you are operating the UA with the intent to photograph or video the assigned 

property. Do not operate the UA over private property without permission.

o Always operate within line of sight of the UA. 
- Weather and Nature

o Do not fly the UA before sunrise or after sunset. If you are performing a twilight 

session, operate the UA prior to the official sunset.

o Do not fly the UA in severe weather conditions. This includes rain, snow, fog, hail, heavy 

winds, lightning, tornados, hurricanes or wind speeds exceeding 10m/s. These conditions 

may cause the UA to fly incorrectly causing damage.

o Be aware of any large birds such as hawks, eagles, owls, or any other birds that may be 

territorial. They may attempt to protect their nest and attack the UA causing injury to the 

bird and causing the UA to loose altitude.

o Do not operate the UA in temperatures greater than 110 degrees. Temperatures higher 

than 110 may cause the motors to fail causing improper operation of the UA.

- Do not operate the UA if there is an accident, fire, flood, or a sandstorm in the vicinity.

- Do not operate the UA if you are under the influence of drugs or alcohol or are impaired in 

any way. (Seizures, dizziness, fatigue) 

- Do not operate the UA from a moving vehicle. 

Pre-Flight	Check

- Ensure the remote controller, flight battery and video monitor (or mobile device) is fully charged.

o Battery life must be at full charge (100%) before operating the UA. All KeeSnap 

Photography UA's are set to begin warning the PIC at 30% battery life. At 20% the UA 

will automatically fly back to Home to prevent loss of power while operated. This is the 

default setting from the manufacturer and is not to be changed.

- Turn off Wi-Fi on the mobile device to reduce interference.

- Ensure the propellers are securely mounted onto the motors.

- Ensure there are no errors on the video display and it states it is "Safe to Fly".

- Ensure the flight path is outside the No-Fly Zones outlined by the FAA and conditions are suitable

for flying the UA.

o Refer to “Create a Flight Plan” under Safety to ensure you are ready to operate the UA.

- Choose a "Home" location

o In the event of a signal loss or battery drain lower than 20% the UA will return to "Home". 

This is a designated GPS location chosen prior to launching the UA. Ensure the "Home" 

location is free of any obstacles so the UA can return in the event of a failure without 

incident.

o Choose a secondary landing site in case of an emergency landing scenario.

- Ensure all media is inserted and ready for recording

- Post magnetic sign on vehicle stating “Attention Aerial Photography in Progress – Please stay 

clear”

- Contact respective airports if operations will be within 5 miles to advise them of the estimated 

flight time, flight duration, elevation of flight and other required information

- Always obtain all required permissions prior to operation

Flight	Procedures

- Takeoff

o Follow all pre-flight checks

o Ensure any individuals watching are clear of the flight path and are aware of the UA.

o Ensure all pets are restrained and clear of the flight path

- In the Air

o All KeeSnap Photography UA’s are programed to stop at an altitude of 400 feet. All flight 

plans are documented and may be reviewed by management for improper operations.

o While in the air always have the controller in your hands and your fingers on the sticks. 

Even in GPS mode ensure the controller is always in your hands.

o Be aware of your flight path and any obstacles you may encounter.

o Be aware of your flight time and time to return home.
o Larger properties require longer flight times. Ensure the UA can return to “Home” safely 

by watching the return to home indicator.

o If in the event of failure and you must land prematurely, locate a safe place to land away 

from structures and individuals. Leave the controller and mobile device, or video monitor, 

powered on until the UA is retrieved.

- Landing

o Always ensure the “Home” GPS location is clear from individuals and obstacles.

o Hover above the “Home” GPS location and select the “Return to Home” button.

o If equipped, use the automatic landing process and allow the UA to automatically land 

while keeping your hands on the controller in case you must manually land the UA.

o Once landed stop the rotation of the rotors, as per the shutdown procedures, power off 

the UA and then the controller to prepare for traveling.

Specific	Exemptions	Requested

Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption 

from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and (b) (Certifications 

required), subject to certain conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is 

difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the 

word “Experimental” on its fuselage as required by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an 

airworthiness certificate, since there is currently no certificate applicable to our operation, this 

regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as 

a safety precaution we will perform a preflight inspection of the UAS before each flight as outlined in the 

attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, 

however since there are no pilots or passengers on board the aircraft and given its size, this regulation is 

inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight 

manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil 

aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We will not 

operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in 

safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or 

below those in relation to minimum safe altitudes.” Given the size, weight, maneuverability, and speed 

of the UAS, an equivalent or higher level of safety will be achieved. 
We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes 

electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 

100% electric and two low battery alerts are issued - per the operating documents, the UAV will be 

landed at the first alert. Also, the UAS has an automated function which results in immediate landing 

when a low battery is detected. The PIC will not begin a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first point of intended landing and, assuming 

normal cruising speed, land the UA with 30% battery power remaining.

Public	Interest

Aerial videography for geographical awareness and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. By granting this exemption we would be able to provide this service at a much 

lower cost. Further, our small UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to larger manned aircraft. Additionally, the operation of our UAS will 

minimize ecological damage and promote economic growth by providing information to companies

looking to relocate or build in the metro areas we service.

Summary

We will comply with all of the following conditions and limitations should this grant of exemption

be provided:

1. Operations will be limited to the following aircrafts described in the operating documents which 

is a quad-rotor aircraft weighing less than 3 pounds: DJI PHANTOM 2 UAS or the DJI Inspire 1

UAS weighing less than 7 pounds.

2. The UA will not be flown at an indicated airspeed exceeding 30 knots.

3. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents. All altitudes reported to ATC 

must be in feet AGL.

4. The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all 

times. 

5. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of 

sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all 

times. The PIC will be designated before the flight and will not transfer his or her designation for 

the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed 

in the operating documents.

6. The operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. Any revisions to the operating documents will be presented to the 

Administrator upon request.

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be 

operated until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station will be included in the preflight inspection. 

All maintenance and alterations will be properly documented in the aircraft records.
8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, will undergo a functional test flight. The PIC who 

conducts the functional test flight will make an entry in the aircraft records.

9. The pre-flight inspection section in the operating documents will account for all discrepancies,

i.e. inoperable components, items, or equipment, not already covered in the relevant sections of 

the operating documents.

10. We will follow the UAS manufacturer’s maintenance, replacement, inspection, and life limit 

requirements.

11. We will carry out maintenance, inspections, and record keeping requirements, in accordance

with the operating documents. Maintenance, inspection, and alterations will be noted in the 

aircraft records, including total flight hours, description of work accomplished, and the signature 

of the authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

14. Prior to operations conducted for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours logged as a UAS pilot with a multi-rotor UAS.

15. Prior to operations conducted for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and 

model of the UAS to be used in operations. The PIC will accomplish 3 take-offs and landings in 

the preceding 90 days.

16. The PIC will not operate the UAS for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos, unless the PIC has demonstrated and logged in a manner 

consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent 

with the operating documents, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

17. UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will 

be conducted under visual meteorological conditions (VMC).

18. The UA will not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart.

19. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC.

20. If a UA loses communications or loses its GPS signal, it will return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents.

21. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents.

22. The PIC will not begin a flight unless (considering weather conditions) there is enough power to 

fly at normal cruising speed to the designated landing point and land the UA with 30% battery 

power remaining.

23. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.
24. The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents will be made 

available to the Administrator or any law enforcement official upon request.

25. The UA will remain clear and yield the right of way to all manned aircraft operations and 

activities at all times. If any manned aircraft is in the vicinity the UA will be landed immediately.

26. The UAS will not be operated by the PIC from any moving device or vehicle.

27. The UA will not be operated over congested or densely populated areas.

28. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. We will ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating

persons leave such protection and are within 500 feet of the UA, flight operations must

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a).

29. All operations will be conducted over private or controlled-access property with permission

from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted.

30. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov