Overshot Photography 

Attn: Jordan Meyer 

905 OAve 

La Grande, OR 97850 

541-786-9844 

Dept. of Transportation 

Docket Operations West Building Ground Floor 

Room w12140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Exemption Request under Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation 

Regulations 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 

C.F.R. Part 11, Overshot Photography (SP) seeks an exemption from Federal Aviation Regulations 

("F ARs") detailed below for the following described Unmanned Aerial System called in this application 

the DJI Phantom 2 Vision+, which includes an Unmanned Aircraft System (UAS) and ground stationbased equipment and crew 

THE UNMANNED AIRCRAFT SYSTEM (UAS): 

• A lightweight (2.7lb gross weight with all onboard equipment), battery operated 4motor rotorcraft: that 

takes off and lands vertically, manufactured by DJI, Model Phantom Vision Plus 2, to carry the following 

equipment in flight; 

• An onboard flight computer with GPS navigation and location ability that receives signals for flight 

controls from a groundbased transmitter/controller; 

• An onboard camera capable of capturing imagery in the form of full color, high definition still photos 

and video; 

• An onboard telemetry system that delivers flight data from the onboard flight computer to the onboard 

radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and 

direction back to its launch site; 

• A 600mW, 5.8GHz onboard radio transmitter that transmits live video from the onboard camera plus all 

the flight data from the telemetry system described above; 

THE GROUND STATIONBASED PART OF THE SYSTEM: 

• A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who 

controls the UA while in the air; 

• A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight; 

• A radio receiver receiving live video and flight data from the onboard camera and computer projects it 

all together onto a screen for the PIC to view during flight; 

• A Visual Observer (VO) who provides a second pair of eyes to visually track the UA while in flight. 

The requested exemption would support an application for a commercial Certificate of Authorization to 

use the above described UAS to support aerial photography and video primarily of real property, 
specifically individual properties of at least two acres in size (equivalent to a square 295 feet/side). The 

UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on 

combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current 

risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With 

a small payload and maximum flight time of only 20 minutes, this is offers little or no risk to national 

security. Low level oblique photos and video from several angles are far more effective than groundbased 

imagery for displaying the characteristics of large, complex properties with several buildings and large 

trees. Helicopters can be used, but they are more expensive to and not able to fly as low. The benefits of 

reduced cost and improved quality of presentation from the UA will be valuable to and benefit many 

buyers and sellers of real property. 

Additionally, we request that we be allowed to use our system to benefit first responders nearby who 

might require assistance, including fire fighters, the police, the sheriff, FEMA, et al., while remaining 

subject to all limitations cited in this application as we do so. 

The UAS will be operated in the field with both a PIC and aVO in accordance with FAA Policy N 

8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: 

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no 

more than 25 knots and no further than 3/4 NM from the PIC; ' 

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by 

voice at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property 

owner; 

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours 

logged as a UA pilot with a similar UA type; 

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The UAS will not be operated over densely populated areas; 

(h) The UAS will not be operated at air shows; 

(i) The UAS will not be operated over any open air assembly of people; 

(j) The UAS will not be operated over heavily trafficked roads; 

(k) The UAS will not be operated within 5 NM of an airport or heliport; 

(1) The UAS will not be operated over properties smaller than two acres in size; 

(m) Operations will be restricted to day only and weather conditions equivalent to VFR; 

(n) The PIC will brief the VO and property owner about the operation and risk before the first flight at 

each new location; 

(o) No flight may be made without a preflight Inspection by the PIC before each operation to ascertain 

that the UA is in a condition safe for flight (see Appendix A). 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and \vill complete 

a course of maintenance instruction as part of their initial training. 

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified 

flight crew and strict operation under the guidelines established in 8900.227, and under all of the 

Restrictions (a) through (o) listed above, the FAA can have full confidence that the operation will have an 

equivalent or greater level of safety than manned aircraft performing the same mission. 
The name and contact information of the applicant is. 

Overshot Photography 

Attn: Jordan Meyer 

Phone: 541-786-9844 

Email: Jordan.Mever@overshotphoto.com 

The regulations from which the exemption is requested are listed below. Beside each regulation number is 

the page of the attached Addendum upon which each may be found together with our proposed equivalent 

level of safety for each regulation: 

• 14 CFR Part 21.. ............................... Addendum Page 1 

• 14 CFR 91.203 ................................. Addendum Page 1 

• 14 CFR45.23, 45.29 .......................... Addendum Page 2 

• 14 CFR 91.9 .................................... Addendum Page 2 

• 14 CFR 61.113, 61.133 ....................... Addendum Page 3 

• 14 CFR 91.109, 91.119, 91.121.. ............ Addendum Page 3-4 

• 14 CFR 91.151.. ............................... Addendum Page 4 

• 14 CFRSubpartE (91.401 91.417) ...... Addendum Page 4 

• FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) ... Addendum Page 5 

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. Please contact us at any time if you require additional information or clarification. We look 

forward to working with your office. 

Sincerely, 

ou-r 

Jordan Meyer 

Owner - Overshot Photography 

The Following are included. 

Addendum containing Exemption Requests and Equivalent Level of Safety 

Appendix A - Preflight Inspection & Emergency Procedures 

Appendix B - Owner's Manual for UAS 
/• 

Addendum 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Overshot Photography requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the UAS: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the UAS under either or both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new 

aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, sales 

demonstrations, and customer crew training, we would expect that an experimental certificate would 

permit our commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the UA's light weight, being constructed primarily of carbon 

fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the 

previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides 
that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." At a maximum gross weight of2.7 pounds, the UA is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate 

for tllis aircraft by the FAA will be in possession of the crew at the ground control station and available 

for inspection upon request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the 

following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23, 

which follows immediately after the proposed placard description below: 

EXPERIMENTAL 

Manufacturer: DJI Innovations, Inc. 55 South A Street Suite 110 Pensacola, FL 32502 

Model: Phantom Vision 2 Plus 

If found please contact: (541)786-9844 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UA does not have 

an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration 

number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the 

word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO 

and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the 

aircraft's registration information at the ground station. Finally, we wi.ll display at the ground station a 

high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 

inches high or greater. Since the aircraft wi.ll operate within 3/4 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is 

in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is 

available to the aircrew while operating the aircraft. We request an exemption to this requirement since 

the aircraft is not only too small to carry documentation, the documentation would not be available to the 

crew during flight operations. To obtain an equivalent level of safety and meet the intent of91.9, we 

propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight. 
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial 

pilot privileges and limitations. 

The regulation provides that no person that holds a private pilot certificate may act as pilot in command of 

an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of 

an aircraft in connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for compensation or 

hire. Our proposed operations require that the PIC must either 

1. Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours of flight 

experience in this type of UA, or 

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in 

which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA 

Private Pilot ·written examination." 

Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent 

category and class in order to apply for a commercial pilot's license, we propose to generate an equivalent 

level of safety by requiring our pilots to complete a minimum of 100 logged hours ofUAS flight time. 

Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph 

(b) even though the intent of this application is to conduct a business. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." The UAS ground-based control station consists of 

a small handheld radio transmitter and while it does not offer a second set of "controls", both the student 

and instructor can, and will, operate the single set of controls simultaneously. With both student and 

instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 

and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 

feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 

feet AGL, we cannot comply with this requirement. In order to provide an equivalent level of safety we 

will only fly over private property with a size of at least two acres with the permission of the owner of the 

property flown over. The aircraft will not be operated over congested areas or over any open air assembly 

of persons. The property owner will be briefed on the expected route of flight and the associated risks to 

persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power 
unit fails, an emergency landing \vithout undue hazard to persons or property on the surface. Therefore we 

maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The UA will always fly below 400 feet AGL and will not need to 

maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the UA onboard computer to 

the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

We feel the intention oftl1is paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The UAS is battery operated and the maximum duration of flight from a single battery charge is 

18 minutes with a 20% reserve. Since the aircraft will never fly more than % NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement 

ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation 

with the word "energy". 

14 CFR Subpart E (91.401 91.417) Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that 

tl1e aircraft be "approved for return to service by a person authorized under 43. 7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." As provided in the PreFlight Checklist in 

Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 

addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC 

is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating 

software and firmware for tl1e onboard computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed in accordance 

with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure 

an equivalent level of safety. 
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FAA 8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(l) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA secondclass medical certificate 

issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 2. 7 

pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO 

are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically 

incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and 

land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical 

requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We 

propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a 

valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see 

and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle. 

APPENDIX A- FLIGHT MANUAL FLIGHT RESTRICTIONS 

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

(b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed of no 

more than 25 knots and no further than 3/4 NM from the PIC; 

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate 

verbally at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property 

owner; 

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 

( 1 ), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least 

ten hours logged as a UA pilot with a similar UA type; 

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The UAS will not be operated over densely populated areas; 

(h) The UAS will not be operated at air shows; 

(i) The UAS will not be operated over any open air assembly of people; 

(j) The UAS will not be operated over heavily trafficked roads; 

(k) The UAS will not be operated within 5 NM of an airport or heliport; 

(I) The UAS will not be operated over properties smaller than two acres in size; 

(m) Operations will be restricted to day only and weather conditions equivalent to VFR; 
(n) The PIC will brief the VO and property owner about the operation and risk before the first flight at 

each new location; 

(o) No flight may be made without a successful PreFlight Inspection by the PIC before each operation to 

ascertain that the VA is in a condition safe for flight. 

PREFLIGHT CHECKLIST 

(1) Use voltmeter to determine that UA battery is fully charged in order to prevent unexpected premature 

descent; 

(2) Check all wiring connections are tight; 

(3) Check all propellers are undamaged and no cracks exist in any structural members of the VA; 

(4) Turn on radio controller, check for adequate voltage, set it to com1ect to the VA, move all control 

switches to forward or dmw position and throttle control stick full back position; 

(5) Connect VA main battery, check for radio contact with UA's radio receiver; 

( 6) At a location different from previous flight, reset GPS and compass to current location; 

(7) Tum on transmitter, gimbal and camera. 

TO REGAIN CONTROL AFTER LOST RADIO CONTACT 

1. Failsafe= ON 

2. Throttle= 50% 

3. Mode=ATTI 

4. Failsafe= OFF 

5. Mode=GPS 

If radio contact is not restored, the VA will automatically continue at 60 ft above its last elevation before 

losing contact toward its takeoff point, then descend and land there autonomously