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** 25m ins **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 provi des 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 mu st 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 appr** **oved for flight and for photography sessio**  **ns only. A personal UA** **S 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 o r 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 ma nned 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 U A.- **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 beg in 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 locati on 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 em ergency 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 withi n 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 A ir**  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 Wh ile 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, powere d 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 o perated at lower altitudes in certain conditions. We will not operate our UAS above the alt itude 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 equi valent 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 in applicable 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 w hen a low battery is detected. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enou gh 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 lon g 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 t hreat 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 aircraft s 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 du ring 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 sa fe 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 Stati on 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 c ritical 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. inop erable 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 t he 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 l ogged, 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 a nd 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 operat ions 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 bel ow 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 o r be recovered in accordance with the operating d ocuments. 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 th e 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 operatin g. These documents will be made a vailable 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 no nparticipating 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 s afety assessment of the risk of operating closer to those objects and determined that it does n ot 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 a s 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 t ransportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov