May 28, 2015 

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave.,

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 

2012 (the "Reform Act"), Christopher Teren (the "applicant"), operator of an 

Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal 

Aviation Regulations ("FARs") to allow for commercial operation for aerial 

imaging and video production, for use in the real estate industry.

Applicant 

Christopher Teren

400 False Bay Drive 

Friday Harbor, WA 98250

Attachments 

DJI Pilot Training Manual

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2) 

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

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 why

14 CFR Part 21 subpart H

The UAS 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 aircraft 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 this UAS it does 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. Understanding the importance of lettering I 

will mark my UAS with the largest possible letters by placing the word 

"Experimental" or assigned number or name, based on request/ruling of 

FAA, on UAS fuselage. The equivalent level of safety will be provided by 

having the UAS marked on its fuselage as required. 

14 CFR 91.7 (a)

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 aircraft 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 has no ability to carry a flight 

manual on the aircraft. There is no room, capacity, or pilot on board to 

adequately carry flight manual. A 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 "DJI Pilot Training". An equivalent 

level of safety will be provided by preflight protocol to properly match the 

machine. 

14 CFR 91.109

UAS 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)

I can achieve an equivalent level of safety as achieved by current regulations 

because my UAS does not carry pilot nor passenger. While helpful, a pilots' 

license will not ensure remote control piloting skills. 

14 CFR 91.121

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

altitude read out. I believe 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 

has no ability to carry certificate and registration documents on the aircraft. 

There is no room, capacity, or pilot on board to adequately manage such 

documents. An equivalent level of safety will be achieved by keeping these 

documents, to the extent they are applicable to the UAS, 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, 

theses sections do not apply to this applicant. As a safety precaution, 

operator will perform preflight inspections and ensure UAS is in working 

condition before initiating each flight. 

Christopher Teren 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 33.5 mph, and with a maximum flight 

time of 25 minutes. The drones to be used are a DJI Phantom 1, DJI 

Phantom 2, and DJI Phantom 3. All are under 4 pounds of weight, and thus 

meet 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 their top speed of 33.5 mph. Due to 

the UAS being battery powered there are no combustible fuels onboard. 

Maximum flight time for these particular UASs is 25 minutes battery life, 

flights to 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, or greater, 

level of safety to be reached by the operator. 
Saftey

*Please see attachment "DJI Pilot Training" for safety precautions I use for 

every flight. Further, I am a Private Pilot with approximately 500 hours of 

PIC time, operating in the National Airspace System for many years both in 

remote rural locations, and very congested areas (I am based in Friday 

Harbor, WA so frequently fly into KBFI in Seattle). 

Additionally:

1) I do not operate within 5 miles of an airport unless prior contact to Air 

Traffic Control or the airport manager has been made.

2) I land my UAS prior to manufacturer recommended minimum level of 

battery power.

3) I pilot my UAS through remote control by line of sight.

4) My UAS uses GPS and a flight safety feature whereby it returns to a 

preprogrammed position and then slowly lands if communication with the 

remote control pilot is lost.

5) I actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols.

6) I conduct extensive pre-flight inspections and protocol, during which 

safety carries primary importance.

7) I always obtain all necessary permissions prior to operation.

8) I have procedures in place to abort fights in the event of safety breaches 

or potential danger.

Public Interest

The use of an UAS for artistic and commercial photography, and in the real 

estate industry, provides both buyers and sellers a higher level of service. 

For a buyer 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. Not only does this benefit the specific home seller or 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 will poses much 

less of a safety concern for the general public when compared to larger 

manned aircraft. 

Thank you for your consideration. 

Christopher Teren