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 r eal e state 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 C FR 91.109

14 C FR 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 en vironment 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

wil l 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 requ ired.

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 adequa tely 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 t hroug h the use of a control box that communicates with the aircraft via radio communications. The equivalentlevel 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

Th e 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 a long 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 acce ss 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,

o perator 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 ma ximum 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 n o 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

ut ilized 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 wi th 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 si ght.



### 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

constantl y 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 fight s 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 ma rketing 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 acr es, 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 sameresult. We c an 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