August 21, 2015

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"), Christian Green (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 photography and video of homes, properties, public land, and vacant areas 

around Central Texas. 

Applicant:

Christian Green

1700 S 2nd St, Apt 3

Waco, TX 76706

christian@grnwrksmedia.com

Attachments:

3DR Solo Smart Drone – User Manual (Exhibit “A”) 

3DR Solo Smart Drone – Specs (Exhibit “B”) 

Requested Regulation Exemptions:

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 (al

14 CFR 91.407 (a] (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Extent of Relief and Reasoning:

14 CFR Part 21 subpart H

The operation of UAS carries neither pilot, passenger, nor explosive materials or flammable

liquids. Given the size, weight, speed and limited operating area utilized by an UAS, I request an 

exemption. In the restricted environment and under the conditions proposed, operation of the 

UAS 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 the required minimums.

14 CFR 91.7 (a)

The UAS will not have an airworthiness certificate. In the event the exemption is granted, an FAA 

regulatory standard determining airworthiness will not exist. Given the size of the aircraft for 
maintenance and use of a safety checklist prior to every flight, an equivalent, if not higher, 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 a flight manual. An equivalent, if 

not higher, level of safety will be maintained by keeping the flight manual (please reference “3DR 

Solo Smart Drone – User Manual” attachment) at the ground control point where the pilot will 

have immediate access to it at all times before, during, and after each flight.

14 CFR 91.103

Since FAA approved flight manuals will not be provided for the UAS, an exemption will be 

needed. Normal operating and safety procedures are, including, but not limited to: reviewing 

weather, flight battery requirement, landing and takeoff distances, Please see attached Exhibit “A” 

for a comprehensive list of safety procedures. An equivalent, if not higher, level of safety will be 

achieved by observing applicable flight protocol that properly matches the UAS.

14 CFR 91.109

The UAS does not have fully functional dual controls. Flight control is achieved through the use of 

a remote control that communicates with the aircraft via radio communications. An equivalent, if 

not higher, level of safety will be provided because neither a pilot nor passengers will be carried 

in the UAS. The maximum speed (55mph) and weight (3.3lbs) of the UAS also provides for a 

higher level of safety in comparison to a larger, manned aircraft. 

14 CFR 91.113 (a) and (b)

I can achieve an equivalent, if not higher, level of safety as achieved by current regulations 

because the UAS does not carry a pilot or passengers. A pilot’s license is an integral part of 

operating a large aircraft carrying numerous passengers for extended distances. As an UAS is 

operated by remote control at ground level, the operator does not require the same expertise as a 

licensed pilot. An UAS does not travel at the same altitudes, speed, or distance as the aircraft 

requiring a pilot. 

14 CFR 91.121

An UAS has a GPS altitude read out rather than a barometric altimeter. An exemption may be

needed. An equivalent, if not higher, level of safety will be achieved by the operator receiving and 

analyzing live flight data, as well as monitoring and confirming current altitudes. The operator will 

also review the altitude of the launch site. The GPS report provides sufficient statistics to ensure 

a safe environment and flight process. 

14 CFR 91.203 (a) and (b)

Similar to 14 CFR91.9 (b) (2), given the size and configuration, the UAS has no ability to carry 

certificate and registration documents on the aircraft. An equivalent, if not higher, 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 the pilot has immediate access to them before, during, and after each 

flight.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

The above referenced sections only apply to aircrafts with an airworthiness certificate. As an UAS 

does not require an airworthiness certificate, these sections are inapplicable. As a safety 

precaution, operator will perform pre-flight inspections and ensure the UAS is in proper working

condition before initiating each flight.

Applicant is seeking relief from the FARs referenced above in order to conduct aerial photography

and video of homes, properties, public land, and vacant areas around Central Texas taken at 

altitudes of less than 400 feet AGL, at speeds of less than 35 mph, and with a maximum flight 

time not to exceed 15 minutes. The drone to be used has a maximum weight of 4 pounds, which 
is well below the 15-pound limit for "small unmanned aircraft" found in Section 331 (6) ("The 

Reform Act"). In order to obtain the highest quality photographs and videos, the UAS will be 

operated at speeds far below its maximum speed of 55 mph. Due to the UAS being battery 

powered, there are no combustible fuels onboard. Maximum flight time for this particular UAS is 

20-25 minutes based on payload. As an additional safeguard, flights will be terminated with no 

less than 25% battery life remaining. When given the size, weight, speed, and limited operating 

area utilized by an UAS, these exceptions are reasonable. The operator maintains an equivalent, 

if not higher, level of safety.

Safety:

The safety precautions to be observed before, during, and after every flight are attached as 

Exhibit “A.”

Additionally:

1) When operating my UAS, safety of others, as well as myself, is paramount. I routinely conduct 

extensive pre-flight inspections and follow all safety protocols to ensure the highest levels of 

safety for each flight.

2) I will not operate my UAS within 25 miles of an airport unless prior contact to Air Traffic Control 

or the airport manager has been made.

3) I will land my UAS prior to the manufacturer’s recommended minimum level of battery power.

This serves as an additional safety precaution.

4) I will pilot my UAS by line of sight through the use of a remote control, while always keeping 

within direct eyesight from the ground launch point. 

5) My UAS uses GPS and includes a flight safety feature whereby it automatically returns to a 

pre-programmed position, and then slowly lands if communication with the remote control pilot is 

lost at any point during the flight.

6) I actively gather and analyze flight data and other sources of information to constantly update 

and enhance my safety protocols. 

7) I always make sure to obtain all necessary permissions prior to operating my UAS. 

8) I have pre-determined safety procedures set in place to abort flights in the event of safety 

breaches or potential danger to others or myself.

Public Interest:

The use of an UAS in the real estate industry provides both buyers and sellers an elevated level 

of service. A higher level of marketing and advertising can be achieved by creating content 

through the use of an UAS. Appealing to more buyers, in return, can result in the quicker sale of a 

particular home. Furthermore, faster closings on homes can also help accelerate the surrounding 

economy as a whole. By using an UAS, I would be able to depict a whole property, even several 

acres, in a single photo or short video. Not only does this benefit the specific home seller or buyer 

but it also benefits the surrounding general public. The UAS is more efficient than the traditional 

use of larger aerial vehicles, such as planes or helicopters. The UAS allows the consumers the 

same product, but eliminates the potential for noise and inconvenience for adjacent owners.

Through the use of UAS, I can now provide a higher level of service while also being conservative 

with fuel, time, emissions, noise, and other resources. In conclusion, when considering the size, 

weight, speed, and absence of any combustible fuels, my UAS poses far less of a safety concern 

for the general public when compared to the alternative of a manned aircraft.
Thank you for your consideration,

Christian Green

Owner, GRNWRKS Media