August 3, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue 

Washington, DC 20590 

RE: Exemption Request Under 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 ) 

Kimberly Steen (the "applicant"), operator of an Unmanned Aircraft System 

("UAS") requests and exemption from the Federal Aviation Regulations to allow 

for commercial operation for aerial photography and cinematography of real 

estate properties and events (weddings, sports, portrait sessions, and parties). 

Applicant: 

Kimberly Steen 

2639 W Old Topside Rd. 

Louisville, TN 37777 

Aircraft Type & Specifications: 

Make: DJ I 

Model: Phantom 3 Advanced 

Weight: 2.82 Ibs. 

Diagonal Size: 23.22 in. 

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) 

14CFR91.103 

14 CFR 91.109 

14 CFR 91.119 © 

14 CFR 91.121 

14 CFR 91.203 (a) and (b) 

14 C F R 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, and reason 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. I request exemption because of the 

size, weight, speed, and limited operating area associated with the aircraft to be 

utilized. 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 the 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 ietters 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. 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 with all of those found in attachment "Safety Guidelines." 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 functionai dual controls. 

Flight control is achieved through the use of a control box that communicates 

with the aircraft via radio communications. The equivalent fevel of safety 

provided because neither a pifot 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 pilot's 

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 achieved 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 such documents. An equivalent 

level of safety will be achieved by keeping these documents, to the extent they 

are applicabfe to the UAS, at the ground control point where pilot has immediate 

access to them. 

14 C FR 91.405 (a), 14 C FR 91.407 (a) (1), 14 C FR 91.409 (a) (2), 14 C FR 

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. 

Kimberly Steen is seeking relief from all FARs above preventing applicant from 

conducting aerial photography and video of real estate properties and events, 

taken at levels less than 200ft, at a speed less than 50 mph, and with a 

maximum flight time of 25 minutes. The drone to be used is a DJI Phantom 3 

Advanced. At 2.82 pounds, 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 it's 

top speed of 50 mph for better picture quality. Due to the UAS being battery 

powered there are no combustible fuels onboard. Maximum flight time for this 

particular UAS 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. 

Safety 

*Please see attachment "Safety Guidelines" for safety precautions I use for every 

flight. 

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) 1 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 iands if communication with the 

remote control pilot is lost 

5) 1 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) 1 always obtain all necessary permissions prior to operation; and, 

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

or potential danger. 

9) All flights will occur over private or controlled access areas with the 

property owner's prior consent and knowledge. Filming will be only of 

people who have given their consent or otherwise have agreed to be 

in the area where filming will take place. 

Public Interest 

The use of an UAS in real estate and marketing provide businesses with a 

much lower cost solution to highlight aspects of their businesses and 

communities. Aerial photography and videography can enable homes to 

sell quicker and thus help the economy. The use of an UAS in 

photographing events, such as portrait sessions, sports, weddings, and 

parties (from a safe distance away from people and never above them), 

provides a higher level of service for clients while being conservative with 

tuel, time, emissions, noise, and other resources and safer than other 

means to capture a photo or video from a higher perspective. Considering 

size, weight, speed, and absence of combustible fuels, my UAS wili pose 

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

larger manned aircraft. 

Thank you for your consideration. 

Kimberly S een