James Huenergardt

Reel Inspirations, Inc.

238 Wind River Drive

Chehalis, WA 98532

July 22, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

SE Washington, DC 20590

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 42.27(a), 45.29(3)(c)(d)(e)(f)(g)(h), 61.113(a) & (b), 91.103, 91.119, 91.121, 

91.203, 91.151

Following the format of the FAA Exemption No. 11138 - Regulatory Docket No. FAA-2014-0481 I have included:

1. Phantom 3 Professional Operating Manual link here: http://www.dji.com/product/phantom-3/download

The original PDF is too large to upload to the web site.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, James, a 

professional videographer and photographer as well as a licensed pilot with ratings of Airline Transport Pilot, 

Multiengine Land, Commercial Single Engine Land and Certified Flight Instructor, preparing this exemption request myself, would like to apply for an exemption from the following Code of the Federal Regulations (C.F.R.) 

to be allowed commercial operation of lightweight Unmanned Aircraft Systems (UAS) to obtain aerial images 

and video of real estate properties.

I have over 30 years of experience flying fixed winged aircraft and recently have been flying a DJI Phantom 3 

Professional. The maximum gross weight of the Phantom 3 Professional is approximately 1280 grams, or just 

under 3lbs. This aircraft is equipped with four rotors that are driven by electric motors with a maximum speed 

of approximately 35mph. The Phantom 3 has a return to home feature that enables the UAS to return to the 

launch point should the battery level reach a pre-determined level or a loss of control signal occur. My intent is 

to use the Phantom 3 Professional to augment real estate listings using aerial photography and video; following 

an exemption and approval by the FAA.

My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control) in 

a predetermined area away from general public, airports, heliports and vehicular traffic, under 400 feet AGL, 

after carefully reviewing, inspecting and examining the area of aerial observation. This will enable me to obtain 

images and video in a safe manner to enhance real estate listings. I will abide by all FAA requirements to ensure 

this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe environment that is strictly controlled; and I will conduct extensive preflight inspections and protocols, during which 

safety carries primary importance.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Given the size, weight, speed and limited operating area associate with the aircraft to be utilized, I am asking 

exemption from 12 C.F.R., 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 C.F.R. Part 11 and Section 333 of P.L 112-95 (Section 333)
14 C.F.R. 45.27 (a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3)(c)(d)(e)(f)(h): Size of 

Marks

Furthermore, I request an exemption from §45.23 Marking of the Aircraft because my UAS does not and will 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally, two inch 

lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the 

word “Experimental” or assigned number or name 9based on a request or ruling by the FAA) on its fuselage as 

required by §45.29(f) so that anyone assisting the pilot of the UAS as a spotter will see the markings.

14 C.F.R. 91.103 (b)(1),(b)(2): Preflight Action

If granted an exemption, I agree to additional safety procedure including, but not limited to:

1. Operate my UAS only within visual line of sight (VLOS)

2. Use the UAS’s global positioning system, GPS flight safety feature; it hovers at a selected altitude and 

returns to the point of origin and lands safely if communication is lost from the remote control unit.

3. Conduct all flight operations during the day and under visual meteorological conditions (VMC).

4. Contact respective airports if operation will be within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with 

an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, 

unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA 

issued to the exemption holder. 

5. Always obtain all necessary permission prior to flight operations.

6. Log all flights in my UAS Pilot Log, along with any aircraft maintenance.

7. Always operate the UAS with a second person acting as spotter.

Public Interest 

Aerial videography for real estate marketing is currently available through manned fixed and rotor winged 

aircraft, but for most small businesses, the expense can be cost-prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, I believe my small UAS will pose no threat to the 

public given its small size and lack of combustible fuel when compared to larger manned aircraft. I also believe 

that the operation of my UAS will minimize ecological damage and promote economic growth by providing 

information to companies and persons looking to relocate areas filmed.

Sincerely,

James Huenergardt

President/Director – Reel Inspirations