Chad Traywick, Real Estate Photo & Videographer Jackson, MS / Tyler, TX 

Section 333 Exemption Petition FAA-2007-0001

January, 1st 2016

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Appendix A –Phantom 3 Professional User Manual

Appendix B – Mississippi & Texas area maps

Dear Sir or Madam,

I, Chad Traywick, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, to request that I, Chad Traywick, an owner and operator of 

small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so 

that I, Chad Traywick, may operate my small ultra-light weight unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein 

I, Chad Traywick, am a Real-estate Photographer & Videographer within the State of Mississippi & Texas; 

experienced in flying hobby helicopters and Airplanes for 25 years for recreational purposes. I have 

added a hobby grade quad-copter1 UAS to my inventory with intent for aerial videography and

cinematography to enhance academic community awareness for those individuals and companies 

unfamiliar with the geographical layout of the land of Mississippi and Texas, and augment real estate 

listing videos; following exemption and approval by the FAA. There by enhancing their academic 

research experience for the Mississippi & Texas area.

I have flown small RC electric helicopters & Airplanes for over ten (25) years without incident. 

Committed to safety with each flight my, Chad Traywick, exemption request would permit operation of 

ultra-light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in 

tightly controlled and limited airspace predetermined in areas away from general public, airports, 

heliports and vehicular traffic for community videos, and within property boundaries for individual 

homeowner & land real estate listing videos/photos. Currently, similar lightweight, remote controlled 

UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to 

prevent catastrophe. I, Chad Traywick, will continue to strictly comply with safety and maintenance 

procedures included in all applicable UAS manufacturer’s instructions and operating manuals to avoid 

and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further 

safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as I, 
Chad Traywick, record flight data and other information gained through permitted flight operations to 

share with the FAA through any required FAA reports to assist with future protocol and safety 

regulation.

Granting my, Chad Traywick’s, request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace 

system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real 

estate/Realtor purposes. Further I, Chad Traywick, will conduct my operations in compliance with the 

protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Chad Traywick, respectfully request the grant of an exemption allowing 

me to operate ultra-light weight, remote controlled UAS’s for academic community awareness to 

benefit/stimulate attraction to the Idaho area and to enhance real estate listing videos for homeowners 

who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local 

economic growth through increased employment and increased tax base. Both with public safety in 

mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public 

hazard.

I. Contact Information:

Chad Traywick, Real Estate Photo & Videographer 

104 Faith Way 

Brandon, MS 39042

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Chad Traywick 

Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The Extent of relief Chad Traywick seeks and the Reason He Seeks Such Relief:
I, Chad Traywick, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FARs operating to prevent me, Chad Traywick, contemplated 

commercial cinematic, academic and other flight operations within the national airspace system. The 

Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public’s interest to do so. My, Chad Traywick’s, ultra-light weight 

UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the 

integration of my ultra-light weight UAS is expressly contemplated by the Reform Act. I would like to 

operate my ultra-light weight UAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. Thereby, providing direct experience and valuable information 

for formal regulation that can be administered uniformly to all real estate related UAS aerial video and 

photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate 

safely in our national airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAS's; whether the UAS will be operated near airports or heavily populated areas; 

and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflects 

in favor of an exemption for me, Chad Traywick. My UAS utilizes four (4) counter-rotating propellers for 

balance, control and stability. My UAS is equipped with GPS and auto return safety technology. 

Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with 

gimbal.

I, Chad Traywick, consider safety as foremost with each flight. My small unmanned aircraft is designed 

to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear 

of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS 

mode that allows my UAS to hover in place or return to home when radio controls are released. With 

three modes to choose from, I utilize the Loiter Mode for aerial videography/photography. This is the 

safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost 

UAS is designed slowly descend to point of takeoff. I do not operate my UAS near airports, Hospitals nor 

Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-

100) yards depending on location, conditions and weather. I am constantly on alert for any manned 

aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and 

safest ground point should a manned aircraft approach my location or I suspect manned aircraft may 

approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only 

within my line of sight of me, as the remote control pilot, utilizing battery power rather than 

combustible fuels, flights generally last between three (3) to seven (7) minutes, with an altitude under 

one hundred fifty (150) feet. 

I, Chad Traywick, utilize a fresh fully charged battery with each flight as a safety precaution; full flight 

time limit for each battery is fifteen (15) to twenty-five (25) minutes as tested. I do not operate my UAS 

at or below manufacture recommend minimum charge levels for operation; preferring to remain well 

within a safe operating range to insure adequate communication between radio control and UAS to 

eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise 

to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause 

a crash that could create hazard to the public/property/manned aircraft, and have no desire to lose an 
investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for 

future commercial use to gain familiarization with the characteristics of this specific UAS's performance 

under different temperature and weather conditions. I also practice computerized simulated flights to 

maintain adequate skills and response reflex time all for the sake of safety.

I, Chad Traywick, am extremely cautious in operating of my UAS/ultra-light weight unmanned aircraft 

and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 

(b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone 

when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the 

national airspace system. Chad Traywick’s UAS, used in hobby flight, has a demonstrable safety record 

and does not pose any threat to the general public or national security.

IV. How Chad Traywick’s Request Will Benefit the Public as a Whole:

Aerial videography for geographical awareness and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters. For small budget real estate companies and 

average homeowners the expense of such aerial videography is cost prohibitive. Only large companies 

and high end Realtors or luxury homeowners can afford to absorb such expense, depriving non -luxury 

homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat 

to the public through potential catastrophic crash that the community has experienced in the past, each 

resulting in loss of life, each with combustible fuel that exploded and burned on impact. Police 

helicopters have made emergency hard landings within city limits. My, Chad Traywick’s, UAS pose no 

such threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's 

into the national airspace system, hence the passing of the Reform Act. Granting my, Chad Traywick’s, 

exemption request furthers the public interest through academic/visual awareness of the geographical 

benefits in and around the Idaho area. My ultra-light weight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of my ultra-light weight UAS crashing is far 

less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can 

cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through my battery operated ultra-light weight UAS's. Permitting me, Chad 

Traywick, to immediately fly within national air space furthers economic growth. Granting my exemption 

request substantially furthers the economic impact for the community for companies looking to relocate 

or build in the Idaho area as well as Individuals looking to relocate for career advancement through 

academic and geographical awareness, both of which serve as a stimulus to the community.

V. Reasons Why Chad Traywick’s Exemption Will Not Adversely Affect Safety or How the

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:
My, Chad Traywick’s, exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated permitting me, Chad Traywick, to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow me to contribute to the innovation and implementation of new 

and novel, as of yet undiscovered safety protocols for Realtors that can be embraced by the NAR6 , 

AAR7 , and TAR8 for development in cooperation with the FAA. In addition I, Chad Traywick, submit the 

following representations of enhancements to current aerial videography and photography for real 

estate:

1. My UAS weighs less than 5 pounds complete.

2. I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by 

the FAA Modernization and Reform Act of 2012);

3. My UAS only operate for 20-25 minutes per flight; I land my UAS prior to manufacturer 

recommended minimum level of battery power; I pilot my UAS through remote control 

only by line of sight;

4. My UAS has GPS a flight safety feature whereby it hovers 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 only operate in reasonably safe environment that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; I conduct extensive 

pre-flight inspections and protocol, during which safety carries primary importance;

7. I always obtain all necessary permissions prior to operation; and, I have procedures in 

place to abort flights in the event of safety breaches or potential danger.

My, Chad Traywick’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is 

important to note that absent the integration of commercial UAS into our national airspace system, 

helicopters are the primary means of aerial video and photography for community awareness and real 

estate. While the safety record of such helicopters is remarkably astounding, there has been local 

incident involving loss of life as well as extensive property damage; it is far safer to operate a battery 

powered ultra-light weight UAS.

1. The potential loss of life is diminished because UAS's carry no people on board and I 

only operate my UAS in specific areas away from mass populations.

2. There is no fuel on board a UAS and thus the potential for fire or explosions is greatly

diminished.

3. The small size and extreme maneuverability of my UAS allow me to remotely pilot away 

from and avoid hazards quickly and safely.

Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS 

need not be so close to the objects they are focused on through the technology and use of post editing 

software allowing pan and zoom.
Accordingly, my UAS has been experimentally operated for familiarization/competency and will 

continue to operate at and above current safety levels.

VI. A Summary the FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed 

operational area of my, Chad Traywick’s, UAS permits exemption from Part 21 because my UAS meets 

(and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to

exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My, Chad Traywick’s, 

current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined.

10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565,9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global 

positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. 

They are inapplicable for the same reasons described above. The equivalent level of safety will be 

achieved by maintaining any such required certifications and registrations by me, Chad Traywick.

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications.

My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small 

aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in 

the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the 

markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 

10167, 10167A and 10700.
C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non -commercial operations. I, 

Chad Traywick, can achieve an equivalent level of safety as achieved by current Regulations because my 

UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote 

control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels 

inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Chad Traywick, 

to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 

200 AGL; safely below the standard of 400 AGL. I, Chad Traywick, will however operate my UAS in safe 

areas away from public and traffic, providing a level of safety at least equivalent to or below those in 

relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an 

equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above- cited Regulations require, amongst other things, aircraft owners and operators to “have 

[the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will 

not, therefore, apply to my, Chad Traywick’s, UAS. However, as a safety precaution I inspect my UAS 

before and after each flight.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness 

Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). 

The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my 

Chad Traywick’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act 

(49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My UAS meets or 

exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, 

this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As 

there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved.
In summary, Chad Traywick seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a);

14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R.

§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14

C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§

91.417 (a) & (b) to commercially operate my, Chad Traywick’s, small unmanned vehicle/lightweight 

unmanned aircraft vehicle in community awareness and real estate operations, and to develop 

economic platforms for real estate inspections to enhance the experience of those seeking to relocate. 

Currently, area awareness and real estate aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel, posing potential risk to the public. Granting my, Chad 

Traywick’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS 

craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than 

conventional real estate video and photographic aircraft with much less flight time. Further, I operate at 

lower altitudes and in controlled airspace eliminating potential public risk flying to and from established 

air fields. I, Chad Traywick, have been informally analyzing flight information and will compile safety 

protocols and the implementation of a flight operations manual for real estate usage that exceeds 

currently accepted means and methods for safe flight. Formal collection of information shared with the 

FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my, Chad Traywick’s, UAS and 

therefore the likelihood of death or serious bodily injury is significantly diminished. My, Chad Traywick’s, 

operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas 

will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Chad 

Traywick, respectfully request that the FAA grant my exemption request and am willing to cooperate in 

sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Chad Traywick, Real Estate Photo & Videographer Brandon, MS / Tyler, TX 

104 Faith Way

Brandon, MS 39042