149 N. 120th Street

Wauwatosa, WI 53226 

Phone: 414.727.9505 

Fax: 414.727.9506 

www.wattscom.com 

Video Production  Audio Production  Digital Photography  Website Design

Media Production Studio 

October 26, 2015 

U.S. Department of Transportation, Docket Operation

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Application / Petition for Section 333 Exemption 

To Whom it May Concern: 

The following is a petition presented by Jeff Watts of Watts Communications, Inc. for 

exemption pursuant to Section 333; FAA Modernization and Reform Act of 2012, Public Law 

112-95 FEB. 14, 2012, Section 333. 

I request this exemption to operate our UAV/UAS, DJI Phantom 3 Advanced Quadcopter 

Aircraft, in order to provide services for profit to include aerial photography, aerial 

cinematography, aerial filming and photography for real estate, construction firms, agricultural 

modeling, crop monitoring operations, aerial mapping, special events to include but not limited 

to weddings, private or public parties/events, business advertising, promotional events, 

geological surveying, and environmental studies. 

Over the past year we have been receiving a growing number of requests for drone 

photography or videography by local municipalities, businesses and individuals. By utilizing the 

UAV/UAS we can provide our clients with the point of view they’re looking for at a more 

reasonable price and in a safer method than helicopters or larger aircrafts. This UAS will be 

operated with extreme care and responsibility as we do with all of our production equipment. 

The Phantom 3 Advanced includes many built in safety functions and notifications to ensure 

safety before and during operation. For example, this UAS will not operate in designated no fly 

zones or in poor weather conditions. In addition to the built in safety features (outlined in the 

User PDF document under page 40 – 44 DJI Advanced User Manual ), a pre-flight safety 

inspection will be performed before each use and I will follow all UAS safety guidelines outlined 

by Congress (outlined in the Safety Guidelines and Disclaimer). 

Any and all repairs will be performed only by the manufacturer's authorized repair facilities/ 

providers. Flights will not take place over densely populated areas or private property without 

the owners' permission. The UAS will only be operated within visual line of sight and will not be 

flown within 5 miles of airports or above 400 feet. 
149 N. 120th Street

Wauwatosa, WI 53226 

Phone: 414.727.9505 

Fax: 414.727.9506 

www.wattscom.com 

Video Production  Audio Production  Digital Photography  Website Design

Media Production Studio 

The specific sections of 14 C.F.R from which I am seeking exemption are as follows: 

14 C.F.R. Part 21; CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS 

14 C.F.R. 45.23(b); Display of marks; general. 

14 C.F.R. 61.101(e)(4), & (5); Recreational pilot privileges and limitations. 

14 C.F.R. 61.113(a) & (b); Private pilot privileges and limitations: Pilot in command. 

14 C.F.R. 61.133 (a); Commercial pilot privileges and limitations. 

14 C.F.R. 61.23(a) & (c); Medical certificates: Requirement and duration. 

14 C.F.R 91.7(a); Civil aircraft airworthiness. 

14 C.F.R. 91.9(b)(2); Civil aircraft flight manual, marking, and placard requirements. 

14 C.F.R. 91.109(a); Flight instruction; Simulated instrument flight and certain flight tests. 

14 C.F.R. 91.103; Preflight action. 

14 C.F.R. 91.119; Minimum safe altitudes: General. 

14 C.F.R. 91.121; Altimeter settings. 

14 C.F.R. 91.151(a); Fuel requirements for flight in VFR conditions. 

14 C.F.R. 91.203(a) & (b); Civil aircraft: Certifications required. 

14 C.F.R. 91.405(a); Maintenance required. 

14 C.F.R. 91.407(a)(1); Operation after maintenance, preventive maintenance, rebuilding, or alteration. 

14 C.F.R. 91.409(a)(2); Inspections. 

14 C.F.R. 91.417(a) & (b). Maintenance records. 

Specifications of the DJI Phantom 3 (“P3”) 

• Gross weight: P3=1280g 

• Diagonal Size (including propellers): P3=590mm 

• Maximum Ascent Speed: P3=5m/sec 

• Maximum Descent Speed: P3=3m/sec 

• Vertical Hover Accuracy: P3=+/-10cm 

• Horizontal Hover Accuracy: P3=+/-1m 

• Maximum Speed: P3=16m/sec 

• Battery: 5400mAh 3S 11.1V LiPo 

• Flight Time: 20-25 minutes 

Thank you very much for your time and consideration for this important request. Please let me 

know if there is any additional information required for approval. 

Sincerely, 

Jeff Watts, Owner 

Watts Communications, Inc.

*Enclosures: DJI_Safety_Guidelines_Disclaimer_en.pdf