August 21 , 2015

**RE: Exemption Request Section 333 of the F AA**  **Reform A ct and Part 11 of the Federal**  **Av iation 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 hom es, properties , public land, and vacant areas around Central Texas

. **Ap plicant:**  Christian Green 1700 S 2 nd St, Apt 3 Waco, TX 76706 christian@grnwrksmedia.com **At tachments**  **:** 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, no r 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 dim ensions 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 forma intenance 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 ma intained by keeping the flight manual (please reference “3DR Solo Smart Drone

– User Manual” attachment) at the ground control poi nt where the pilot will have immediate access to it at all tim es 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 a re, 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 p rovides 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 b y current regulations because the UAS does not carry a pilot or pass engers. 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 mo nitoring and confirming current altitudes. The operator will also review the altitude of the launch site

. The GPS report provides suffi cient statistics to ensure a safe environment and flight process. 14 CFR 91.203 (a) and (b) Sim ilar 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 ensu re 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 hom es, properties, public land, and vacant areas around Central Texas taken at altitudes of less than 400 feet AGL , at speeds of less than 3 5 mp h, and with a maximum flight tim e not to exceed 15 minutes

. The drone to be used has a maximum weight of 4 pounds, whichis well below the 15

- pound lim it for "sm all unmanne d aircraft" found in S ection 331 (6) ( "The

Reform Act" ) . In order to obtain the highest quality photograph s and videos, the UAS will be operated at speeds far below its maximum speed of 55 mp h. Due to the UAS being battery powered , there are no combustible fuels onboard. Maximum flight time for this particular UAS is 20

-25 mi nutes based on payload. As an additional safeguard, flights will be terminated with no less th a n 25% battery life remaining

. Wh en g iven the size, weight, speed, and limited operating area utilized by an UAS, these exception s are reasonable

. T he 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.” **Ad ditionally:**  1) Wh en operating m y UAS, safety of others , as well as m ys elf, is paramount. I routinely conduct extensive pre

-flight inspections and follow all safety protocol s to ensure the highest levels of safety for each flight. 2) I will not operate my UAS within 2 5 miles of an airport unless prior contact to Air Traffic Control or the airport ma nager has been made. 3) I will land m y UAS prior to the ma nufacturer’s recommended minimum level of battery power. This serves as an additional safety precaution. 4) I will pilot m y UAS by line of sight through the use of a rem ote 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 a ll necessary permissions prior to operating m y UAS

. 8 ) I have pre-determined safety procedures set in place to abort flights in the event of safety breaches or poten tial danger to others or m ys elf

. **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 econom y as a whole. By using an UAS , I would be able to depict a whole prope rty, 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 sam e 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 fu el, 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 ma nned ai rcraft.Thank you for your consideration,

Christian Green Owner , GRNWRKS Media