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Travis Knoop 

Travis Knoop Photography, LLC 

4200 W. Eaglerock Dr. 

Wenatchee, WA 98801 

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September 26, 2015 -~ 

Cell: 509.860.4321 

Email: travisknoop@gmail.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act}, 

Travis Knoop Photography, LLC, and owner Travis Knoop hereby apply for an exemption from 

Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of small 

unmanned aerial systems for the primary purpose of aerial photography and video. 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 9.1.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14CFR91.121 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) and (b) 

Extent of relief I seek and reasoning behind the request: 

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14 CFR Part 21 subpart H 

The UAS's to be operated carries neither pilot nor passenger and carries no explosive 

materials or flammable liquids. Given the size, weight, speed, and limited operating area 

associated with the aircrafts to be utilized, I request exception. In the restricted 

environment and under the conditions proposed operation will be at least as safe, or 

safer, than a conventional aircraft operating with an airworthiness certificate without 

said restrictions. 

14 CFR 45.23 (b) 

Due to the size of these UAS's they do not have a cockpit, cabin, or pilot station on which to 

market certain words or phrases. Lettering would be very difficult to place on such a 

small aircraft and dimensions would need to be smaller than required minimum. 

14 CFR 91.7 (al 

As there will be no airworthiness certificate for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the 

size of the aircrafts for maintenance and use of safety check list prior to each flight an 

equivalent level of safety will be provided. 

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS's have no ability to carry a flight manual on the 

aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. 

An equivalent level of safety will be maintained by keeping the flight manual at ground 

control point where the pilot will have immediate access to it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft an exemption will 

be needed. Normal procedures including but not limited to; reviewing weather, flight 

battery requirement, landing and takeoff distances, along will all of those found in 

attachment "OJ I Pilot Training". An equivalent level of safety will be provided by 

preflight protocol to properly match the machine. 

14 CFR 91.109 

UAS's and remotely piloted aircraft do not have fully functional dual controls. Flight 

control is achieved through the use of a control box that communicates with the aircraft 

via radio communications. The equivalent level of safety provided because neither a 

pilot nor passenger will be carried in the aircraft, and by the speed and size of the 

aircraft. 

14 CFR 91.113 (a) and (b) 

Travis Knoop Photography, LLC can achieve an equivalent level of safety as achieved by 

current regulations because my UAS's do not carry pilot nor passenger. While helpful, a pilot's 

license will not ensure remote control piloting skills. 
14CFR91.121 

The UAS's may not have a barometric altimeter, but instead does have a GPS altitude 

read out; an exemption may be needed. An equivalent level of safety is achieve 

by the operator receiving live flight data monitoring and confirming current altitude 

along with altitude of launch site shown on GPS altitude indicator. 

14 CFR 91.203 (a) and (b) 

Similar to 14 CFR 91.9 (b) (2), given the size and configuration, the UAS's have no ability to 

carry certificate and registration documents on the aircraft. There is no room, capacity,or pilot on 

board to adequately such documents. An equivalent level of safety will be 

achieved by keeping these documents, to the extent they are applicable to the UAS's, at 

the ground control point where pilot has immediate access to them. 

14 CFR 91.405 (a). 14 CFR 91.407 (a) (1). 14 CFR 91.409 (a) (2). 14 CFR 91.417 (a) and (b) 

Given these section only apply to aircraft with an airworthiness certificate, these 

sections do not apply to this applicant. As a safety precaution, operator will perform 

preflight inspections and ensure the UAS's are in working condition before initiating each flight. 

Travis Knoop Photography, LLC is seeking relief from all FARs above preventing applicant from 

conducting aerial photography and video of real estate taken at levels less than 400ft, at 

a speed less than 40 mph, and with a maximum flight time of 25 minutes. The UAS's 

to be used is a OJI Phantom 2 and a DJI Inspire 1. At 3.08 pounds (OJ I Phantom 2 and 

gimbal/camera) and 6.6 pounds (OJ I Inspire 1) the weight of the UAS meets the definition of 

"small unmanned aircraft" found in section 331. 

"The Reform Act". In order to obtain high quality photography and video the UAS will be 

used at speeds much less than its top speed of 33.5 (Phantom 2) and 49 (Inspire 1) mph. Due 

to the UAS being battery powered there are no combustible fuels on board. Maximum flight time 

for these particular UAS's varies between 18 and 25 minutes battery life, and flights will be 

terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating 

area associated with the aircraft to be utilized I find this exception to be reasonable with an 

equivalent, orgreater, level of safety to be reached by the operator. 

The UAS's 

Both UAS's utilize internal inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS) to maintain its geospatial orientation and 

position. They are controlled primarily through an FCC certified radio control (RC) unit. Real 

time video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from . 

PIC, camera imagery, and control camera angle. They have failsafe modes of operation for 

either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and 

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to 

approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry and 
external lighting cues before reaching a low battery state. An automatic termination of flight and 

landing will be initiated when the battery reaches a predetermined low state. It is anticipated that 

flights will usually last less than 15 minutes. More information is available in Attachment 1 and 2. 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference's 1-3 Conditions and Limitations section 

and believes that the procedures specified therein are reasonable and will be utilized in order to 

manage and mitigate risk and ensure public safety. A preflight checklist will be developed and 

employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will 

be maintained by performance of routine inspections before each flight, maintaining flight and 

maintenance logs to record time on failure prone components. These documents will be made 

available to the FAA and SOT to assist in future implementation of safety standards and 

regulations. The petitioner will only operate the UAS over designated properties with the owner's 

consent. Flight plans will be predetermined to limit the UAS'ss flight time and limit safety 

concerns. The petitioner will take into account distance from persons and potential flight 

obstacles prior to operating the UAS. UAS operation will always be within VLOS of the PIC and 

the observer. 

Public Interest 

The use of an UAS in the real estate industry provides both buyers and sellers a higher 

level of service. For a seller a higher level of marketing and advertising is achieved, 

appealing to more buyers, resulting in a quicker sale of their home. Quicker home sales 

also helps accelerate the economy as a whole. 

Buyers experience the benefit of encompassing a whole property, sometimes several 

acres, in one photo or a short video. Aerial photography provides the opportunity to view the 

topography, setting and orientation of a particular property. Not only does this benefit the 

specific home selleror home buyer, but it benefits the general public because it is much more 

efficient than traditional ways of using a plane or helicopter to achieve the same result. We can 

now provide this level of service while being conservative with fuel, time, emissions, noise, 

and other resources. Considering size, weight, speed, and absence of combustible fuels, 

my UAS's will pose much less of a safety concern for the general public when compared 

to larger manned aircraft. 

~~sideration. 

Travis Knoop, owner ~ Travis Knoop Photography, LLC 

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Attachment 1: DJI Phantom 2 System Specs 

Aircraft: 

Weight (Battery & Propellers included) - 1 OOOg 

Hover Accuracy (Ready to Fly) - Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity- 200°/S 

Max Tilt Angle - 35° 

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

Max Flight Speed - 15m/s 

Diagonal Length - 350 mm 

Flight Time - 25mins 

Take-off Weight- :s1300g 

Operating Temperature- -10°C- 50°C 

Supported Battery - OJ I Smart Battery 

2.4GHz Remote Control: 

Operating Frequency - 2.4GHz I 

SM Communication Distance (open area)- 1000m 

Receiver Sensitivity (1%PER)- -97dBm 

Working CurrenWoltage - 120 mA@3. ?V 

Built-in LiPo Battery Working Current/Capacity- 3.7V, 2000mAh 

Full user manual available at: http://www.dji.com/productlphantom-2/download 
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Attachment 2: DJI Inspire 1 System Stats 

Aircraft: 

Weight (Battery & Propellers included) - 2935g 

Hover Accuracy (Ready to Fly) - Vertical: 0.5m; Horizontal: 2.5m 

Max Yaw Angular Velocity- 150°/s 

Max Tilt Angle- 35° 

Max Ascent I Descent Speed - Ascent: 5m/s; Descent: 4m/s 

Max Flight Speed - 22m/s 

Diagonal Length - 559 to 581 mm 

Flight Time - 18 mins 

Operating Temperature- -10°C- 40°C 

Supported Battery- DJI Intelligent Flight Battery 4500 -5700 mAh 

2.4GHz Remote Control: 

Operating Frequency- 5.725-5.825 or 2.400-2.483 GHz 

SM Communication Distance (open area)- 2km 

Receiver Sensitivity (1%PER)- 10dBn@900m, 13dBn@5.8G, 20dBm@2.4G 

Built-in LiPo Battery Working Current/Capacity- 6000mAh LiPo 2S 

Full user manual available at: http://www.dji.com/productlinspire-1/download