Photography

CO: Christopher Keeran

(512) 677-7627

P.O. Box 4821 

8027 Bronco Ln.

Lago Vista, TX 78645

Federal Aviation Administration:

On behalf of KeeSnap Photography I would like to submit for an exemption from part 21, subpart H; and 

Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This 

proposed exemption would allow our business to operate an unmanned aircraft system (DJI Inspire 1) in 

Central Texas for the purpose of providing high quality imaging/videos for various commercial, public, 

and residential uses. Our primary market will be Real Estate, construction sites, appraisals, and building 

inspections.

We will operate the UAS DJI Inspire 1 Pro and Phantom 2 to perform these operations. 

Inspire 1 Pro Specification:

Model T600

Weight (Battery Included) 6.5 pounds

Hovering Accuracy (GPS Mode) Vertical: 0.5 m / Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s - Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Power Spectral Density 9.06mW/MHz
Phantom 2 Specification:

Weight (Battery & Propellers Included) 2.5 Pounds

Hover Accuracy (Ready To Fly) Vertical: 0.8m/Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

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

Max Flight Speed 15m/s(Not Recommended)

Diagonal Length 350mm

Flight Time 25mins

Take-Off Weight ≤1300g

Operating Temperature -10°C ~ 50°C

Supported Battery DJI Smart Battery

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption, which ensures a 

level of safety at least equal to existing rules:

- Operate UAS below 400 feet and within a radius distance of 1000 feet from the controller to aid 

in direct line of sight visual observation.

- Obtain permission from the owner/operator of any properties and structures within 300 feet of 

the assigned property.

- Operate the UAS less than 20 minutes per flight. Multiple flights might be required due to the 

size of the property. 

- Battery life must be at full charge (100%) before operating the UA. All KeeSnap Photography 

UA's are set to begin warning the PIC at 30% battery life. At 20% the UA will automatically fly 

back to Home to prevent loss of power while operated. This is the default setting from the 

manufacturer. 

- Operate UAS during daylight hours only within visual line of sight (VLOS);

- Utilize the automatic landing procedures to ensure a proper safe landing.

- Conduct all operations under the flight safety protocols 

o Post a magnetic sign on the vehicle stating, “Attention Aerial Photography in Progress

Please stay clear”

- Contact respective airports if operations will be within 5 miles to advise them of his estimated

flight time, flight duration, elevation of flight and other pertinent information;

- Always obtain all necessary permissions prior to operation;

- Have procedures in place to abort flights in the event of safety breaches or potential danger;

- Only operate in safe environments that are strictly controlled, are away from power lines, 

elevated lights, airports and densely populated areas (defined by areas depicted in “yellow” on 

VFR charts and through obtaining information regarding congested areas from the local Flight 

Standards District Office (FSDO);
- Conduct extensive preflight inspections and protocols, during which safety carries primary

importance (reference PHANTOM Flying Flow Chart and User Manual).

UAS	Pilot	in	Command	(PIC)

Josh Kneifel, our Chief Pilot, holds a FAA Commercial Pilot license, first-class medical certificate, multiengine instrument rating, is a former Certified Flight Instructor and has substantial flight time in 

numerous types of aircraft. Given his flight background and experience, he has the knowledge required 

to ensure the high level of safety required by current regulations. Any other pilots who would conduct 

flights will hold a minimum of a FAA Private Pilot License and third-class medical.

Regarding UAS operational training, we have flown numerous practice flights in remote areas as 

hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of 

the UAS’ performance under different temperature and weather conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner consistent

with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least

10 hours logged as a UAS pilot with a multi-rotor UAS. The PIC will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and

model of UAS to be used for operations. In addition to the hour requirements, the PIC

will accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes)

prior to any flight.

Specific	Exemptions	Requested

Given the size, weight, speed, and limited operating area associated with the UA, we

feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §

91.203(a) and (b) (Certifications required), subject to certain conditions and limitations,

is warranted and meets the requirements for an equivalent level of safety under 14 CFR

part 11 and Section 333 of P.L. 112-95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller

than the minimal lettering requirement. Regardless of this, we can mark the UAS in the

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

by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft

without an airworthiness certificate, since there is currently no certificate applicable to

our operation, this regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a)

and (b) Maintenance inspections since they only apply to aircraft with an airworthiness

certificate. However, as a safety precaution we will perform a preflight inspection of the

UAS before each flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in
the aircraft, however since there are no pilots or passengers on board the aircraft and

given its size, this regulation is inapplicable. We believe an equivalent level of safety

will be achieved by maintaining a safety/flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation

of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain

conditions. We will not operate our UAS above the altitude of 300 feet above ground

level (AGL) and will also only operate in safe areas away from the public and traffic,

thus “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 the UAS, an

equivalent or higher level of safety will be achieved. 

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the

UAS utilizes electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions.

The UAV is 100% electric and two low battery alerts are issued - per the operating

documents, the UAV will be landed at the first alert. Also, our flights will last only

5-10 minutes each, and the UAS has an automated function which results in immediate

landing when a low battery is detected. The PIC will not begin a flight unless (considering

wind and forecast weather conditions) there is enough power to fly to the first point

of intended landing and, assuming normal cruising speed, land the UA with 30% battery

power remaining.

Public	Interest

Aerial videography for geographical awareness and for real estate marketing has been

around for a long time through manned fixed wing aircraft and helicopters, but for small

business owners, its expense has been cost-prohibitive. By granting this exemption we

would be able to provide this service at a much lower cost. Further, our small UAS will

pose no threat to the public given its small size and lack of combustible fuel when compared

to larger manned aircraft. Additionally, the operation of our UAS will minimize ecological

damage and promote economic growth by providing information to companies

looking to relocate or build in the metro areas we service.

Summary

We will comply with all of the following conditions and limitations should this grant of exemption

be provided:

1) Operations will be limited to the following aircraft described in the operating documents

which is a quad-rotor aircraft weighing less than 3 pounds: PHANTOM 2 Unmanned

Aircraft System.

2) The UA will not be flown at an indicated airspeed exceeding 30 knots.

3) The UA will be operated at an altitude of no more than 300 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents. All altitudes

reported to ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command
(PIC) at all times. 

5) All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate

verbally at all times. The PIC will be designated before the flight and will not

transfer his or her designation for the duration of the flight. The PIC will ensure that the

VO can perform the functions prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and made available

to the Administrator upon request. Any revisions to the operating documents will

be presented to the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the

UAS will not be operated until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight. The Ground Control Station will be included

in the preflight inspection. All maintenance and alterations will be properly documented

in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics,

e.g. replacement of a flight critical component, will undergo a functional test flight.

The PIC who conducts the functional test flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all discrepancies,

i.e. inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

10) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance

with the operating documents. Maintenance, inspection, and alterations will be

noted in the aircraft records, including total flight hours, description of work accomplished,

and the signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate

and at least a current third-class medical certificate. The PIC will also meet the

flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is

rated on his or her pilot certificate. 

15) Prior to operations conducted for the purpose of aerial videography/cinematography

and augmenting real estate listing videos (or similar operations), the PIC will have accumulated

and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25

hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS

pilot with a multi-rotor UAS.

16) Prior to operations conducted for the purpose of aerial videography/cinematography

and augmenting real estate listing videos (or similar operations), the PIC will have accumulated

and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5

hours as UAS pilot operating the make and model of the UAS to be used in operations.

The PIC will accomplish 3 take-offs and landings in the preceding 90 days (for currency

purposes).

17) The PIC will not operate the UAS for the purpose of aerial videography/cinematography

and augmenting real estate listing videos (or similar operations), unless the PIC

has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability
to safely operate the UAS in a manner consistent with the operating documents, including

evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All

operations will be conducted under visual meteorological conditions (VMC).

19) The UA will not operate within 5 nautical miles of an airport reference point as denoted

on a current FAA-published aeronautical chart.

20) The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

21) If a UA loses communications or loses its GPS signal, it will return to a predetermined

location within the planned operating area and land or be recovered in accordance

with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather conditions)

there is enough power to fly at normal cruising speed to the intended landing

point and land the UA with 30% battery power remaining.

24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization

(COA) prior to conducting any operations, and also request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to

the operation.

25) Before conducting operations, the radio frequency spectrum used for operation and

control of the UA will comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC

at the Ground Control Station of the UAS any time the UAS is operating. These documents

will be made available to the Administrator or any law enforcement official upon

request.

27) The UA will remain clear and yield the right of way to all manned aviation operations

and activities at all times.

28) The UAS will not be operated by the PIC from any moving device or vehicle.

29) The UA will not be operated over congested or densely populated areas.

30) Flight operations will be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. We will ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating

persons leave such protection and are within 500 feet of the UA, flight operations must

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has granted permission and the PIC has

made a safety assessment of the risk of operating closer to those objects and determined

that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not

present an undue hazard to those persons per § 91.119(a).

31) All operations will be conducted over private or controlled-access property with permission

from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be
conducted.

32) Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to

the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov