Ross	A.	Costanza

Ross	Costanza	Photography	(RCP) 900	High	Point	Circle Chesapeake,	VA	23322 September	27,	2015 U.S.	Department	of	Transportation Docket	Management	System	1200 New	Jersey	Ave.,	SE	Washington	DC	20590 Re:	Exemption	Request	Pursuant	to Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal Aviation	Regulations	from:	14	CFR	21	subpart	H;	14	CFR	45.23(b);	14	CFR	61.113(a);	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 91.151(a);	14	CFR	91.203	(a)	and	(b);	14	CFR	91.405	(a);	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)(1) and	(2);	14	CFR	91.417(a)	and	(b) To	whom	it	may	concern:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14	CFR	Part	11,	Ross A.	Cos tanza,	owner	of	Ross	Costanza	Photography,	also	known	as	RCP,	hereby	applies	for	an exemption	from	the	listed	Federal	Aviation	Regulations	to	allow	commercial	operation	of	a	small UAS,	so	long	as	such	operations	are	conducted	within	and	under	the	condition s	outlined	herein	or	as my	be	established	by	the	FAA	as	required	by	Section	333,	for	all	operators	of	small	Unmanned	Aerial Systems	(UAS)	working	for RCP .	Commercial	operation	small	UAS,	as	described	herein,	which	are equipped	with	cameras	and	sensors,	would	operate	in	the	following	manner: 1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate, architecture,	land	surveying,	engineering	and	other	related	professional	activities. 2.	Aerial	video	and/or	photography	for	public and/or	private	use	including	television,	public events,	and	cinematography. 3.	Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with the	owners	or	local	government	authority. 4.	Aerial	video/photography	or	providing	live video	feed	to	assist	with	search	and	rescue operations	in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	authorities	or government	has	requested	it	by	contract	or	donation.
As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	small	UAS	under controlled	conditions	in	the	NAS	that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	will provide	safety	enhancements	to	the	already	safe	operations	in	the	industry	presently	using conventional	aircraft.	Approval of	this	exemption	would	thereby	enhance	safety	and	fulfill	the Secretary	of	Transportation's	(the	FAA	Administrator's)	responsibilities	to	"	....	establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace	system."

The name,	phone,	email	and	address	of	the	applicant: Name:	Ross	A.	Costanza Phone:	(757)	647

- 4610 Email: costanzaphoto@yahoo.com Address:	900	High	Point	CircleChesapeake,	VA	23322

Regulations	from	which	the	ex emption	is	requested: 14	CFR	Part	21	subpart	H 14	CFR	45.23	(b) 14	CFR	61.113(a) 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	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1 ) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b)
The	small	UAS's	I	will	be	using	are	multi

- rotor	craft	weighing	no	more	than	55lbs.	including	payload. Under	normal	conditions	they	operate	at	speeds	of	no	more	than	45	Mph	or	39	Knots	and	have	the ability	h over	and	move	along	a	vertical	and	horizontal	plane	simultaneously.	They	will	operate	in	line of	sight	only	and	by	the	exempted	persons	only	obeying	all	other	local	and	federal	laws. Given	the	small	size	of	the	small	UAS	and	the	controlled	environment	provided	the	proposed operations	will	adhere	to	the	Reform	Act's	safety	requirements.	The	approval	of	this	application presents	no	national	security	issues.	Regarding	the	level	of	safety surrounding	the	proposed operations	and	the	public	benefit,	reduction	in	environmental	impacts,	including	but	not	limited	to reduced	emissions	and	noise,	the	grant	of	the	requested	exemption	is	in	the	public	interest. Accordingly	the	applicant	requests	that	the	FAA	grant	the	requested	exemption	with	minimum	delay.

**AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY** The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety	because	operations	will further	enhance	the	safety	of	the	person s	and/or	property	using	conventional	aircraft.	These limitations	and	conditions	to	which	the	applicant	agrees	to	adhere	to	when	conducting	commercial operations	under	the	FAA	issued	exemption	as	set	forth	in	the	Flight	Operations	Manual	(FOM) include:
1. The	small	UAS	will	weigh	less	than	55	lbs. 2.	Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer. 3.	Maximum	flight	time	for	each	operational	flight	will	be	30	minutes.	Flights	will	be	terminatedat 25%	battery	power	reserve	or	30	minutes	of	flight	time	whichever	occurs	first.4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(AGL)	and	not

more	than	200	feet	above	an	elevated	platform	from	which	filming	is	planned. 5.	Minimum	crew	for	each	operation will	consist	of	the	small	UAS	Pilot	in	Command	(PIC),	the	Visual Observer	(VO)	when	needed	and	may	include	but	not	limited	to	a	Camera	Operator. 6.	A	briefing	will	be	performed	regarding	the	planned	small	UAS	operations	prior	to	each	day's	flight consisting	of	all	the	days'	production	activities. 7.	The	PIC	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	planned	operation	and ensure	that	only	consenting	persons	will	be	allowed	within	100	feet	of	the	flight	operation,	and	the radius	may	b e	reduced	to	30	feet	based	upon	an	equivalent	level	of	safety	determination,	as	required under	the	FOM.	With	the	advanced	permission	or	direction	of	the	FSDO,	operations	at	closer	range may	be	approved. 8.	The	PIC	and	VO	will	have	been	trained	in	operation of	small	UAS	and	receive	up

- to
- date information	for	the	particular	small	UAS	to	be	operated	and	will	be	able	to	show	upon	request	their competent	ability	to	operate	the	small	UAS	and/or	Camera. 9.	The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	times. 10.	Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	county	or city	jurisdictions,	including	law	enforcement,	fire	or	other	appropriate	governmental	agencies when	needed. 11.	If	the	small	UAS	loses	communications	or	loses	GPS	signal,	the	small	UAS	will	have	the	capability to	return	to	a	pre
- determined	location	within	a	designated	location	and	land	autonomously. 12.	The	small	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicte d	obstacles,	weather, or	emergencies. **14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)** Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural requirements for	the	issuance	of	airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given the	size	and	limited	operating	area	associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an exemption	from	Part	21	Subpart	H	meets	the	requirements	of	an	equ ivalent	level	of	safety	under	Part 11	and	Section	333	of	the	Reform	Act.	The Federal	Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of	the	Reform	Act	both	authorize	the	FAA to	exempt	aircraft	from	the	requirement	for	an	airworthiness	certificate,	upon consideration	of	the size,	weight,	speed,	operational	capability,	and	proximity	to	airports	and	populated	areas	of	the particular	small	UAS.	In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	small	UAS operated	without	an	airworthiness	certi ficate,	in	the	restricted	environment	and	under	the conditions	proposed	will	be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or rotorcraft)	operating	with	an	airworthiness	certificate	without	the	restrictions	and	conditions proposed .	The	small	UAS	to	be	operated		hereunder	is	less	than	55	lbs.	fully	loaded,	carries	neither	a pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operates exclusively	within	a	secured	and	designated	area.	Unlike	other	civil aircraft,	operations	under	this exemption	will	be	tightly	controlled	and	monitored	by	both	the	operator	and	under	the	requirements and	in	compliance	with	local	public	safety	requirements.	These	safety	enhancements	provide	a greater	degree	of	safety	to	the public	and	property	owners	than	conventional	operations	conducted with	airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	application	of	these same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	security	posed by	the	small UAS,	due	to	its	size,	speed	of	operation,	location	of	operation,	lack	of	explosive	materials	or flammable	liquid	fuels,	and	inability	to	carry	a	substantial	external	load. **14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft** The	regulation	requires:	When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration number	is	displayed	on	limited,	restricted	or	light

- sport	category	aircraft	or	experimental	or provisionally	certificated	aircraft,	the	operator	must	also	display	on	that	aircraf t	near	each	entrance to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the words	"limited,"	"restricted,"	"light

- sport,"	"experimental,"	or	"provisional,"	as	applicable.Even	though	the	small	UAS	will have	no	airworthiness	certificate,	an	exemption	may	be	needed	as	the

small	UAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word "Experimental"	can	be	placed.	Given	the	size	of	the	small	UAS,	two

- inch	lettering	will	be	impossible. The	word "Experimental"	will	be	placed	on	the	fuselage	in	compliance	with	§45.29	(f).	The	equivalent level	of safety	will	be	provided	by	having	the	small	UAS	marked	on	its	fuselage	as	required	by	§45.29 (f)	where the	pilot,	observer	and	others	working with	the	small	UAS	will	see	the	identification	of	the small	UAS	as "Experimental." **14	C.F.R.	§	61.113(a):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.** Pursuant	to	14	CFR	61.113	(a),	no	person	who	holds	a	private	pilot	ce rtificate	may	act as	a	pilot	in command	of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	Our	small UAS do	not	carry	any	pilots	or	passengers	nor	property	therefore	I	am	seeking	an	exemption	to	14 CFR 61.113(a).	Although	helpful,	a	pilot's license	will	not	ensure	remote	control	piloting	skills.	The risks attendant	to	the	operation	of	small	UAS	is	far	less	than	the	risk	levels	inherent	in	the commercial activities	outlined	in	14	CFR	61.	I	feel	the	operation	and	limitations	set	forth	in	the	FO M will	equate	tothe	safe	operation	of	the	small	UAS. **14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness.** The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition. As there	will	be	no	airworthiness	certificate issued	for	the	aircraft,	should	this	exemption	be	granted, no FAA	regulatory	standard	will	exist	for	determining	airworthiness.	Given	the	size	of	the	aircraft	for maintenance	and	use	of	safety	checklists	prior	to	each	flight	an	equivalent	level	of	safety will	be provided. **14	C.F.R.	§	91.9	(b)	(2}:	Civil	Aircraft	Flight	Manual	in	the	Aircraft.** Section	91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S.

- registered	civil	aircraft	...	(2)	For	which an Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by §21.5	of	this	chapter,	unless	there	is available	in the	aircraft	a	current	approved	airplane	or	Rotorcraft	Flight	Manual,	approved	manual material, markings,	and	placards,	or	any	combination	thereof.	The	small	UAS,	given	its	size	and configuration	has no	ability	or	place	to	carry	such	a	flight	manual	on	the	aircraft,	not	only	because there	is	no	pilot	on board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the aircraft.	The	equivalent level	of	safety	will	be	maintained	by	keeping	the	fli ght	manual	at	the	ground control	point	where	the pilot	flying	the	small	UAS	will	have	immediate	access	to	it. **14	C.F.R.	§	91.103:	Preflight	Action.** This	regulation	requires	each	pilot	in	command	to	take	certain	actions	bef ore	flight	to	insure	the safety of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an exemption will	be	needed.	The	OPERATOR	will	take	all	actions	including	reviewing	weather,	flight battery requirements,	landing	and	takeoff	distances	and	aircraft performance	data	before	initiation of	flight. **14	C.F.R.	§91.109:	Flight	Instruction.** Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(exc ept	a	manned	free	balloon) that is	being	used	for	flight	instruction	unless	that	aircraft	has fully	functioning	dual	controls.	Small UAS	and remotely	piloted	aircraft,	by	their	design	do	not	have	fully	functional	dual	controls.	Flight control	is accomplished	through	the	use	of	a	control	box	that	communicates	with	the	aircraft	via radio communicatio ns.	The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional dual controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	Theequivalent	level of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in

the	aircraft	and	by	the size	and	speed	of the	aircraft. **14	C.F.R.	§91.119:	Minimum	Safe	Altitudes.** Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	91.119	(d)	allows helicopters	to	be	operated	at less	than	the	minimums	prescribed,	provided	the	person	operating	the helicopter	complies	with	any	route	or	altitudes	prescribed	for	helicopters	by	the	FAA.	As	this exemption is	for	a	small	UAS	that	is	a	helicopter	and	the	exemption	requests	authority	to operate	at altitudes	up	to 400	AGL,	or	not	more	than	200	above	an	elevated	platform	from	which	filming	is planned,	an	exemption may	be	needed	to	allow	such	operations.	As	set	forth	herein,	the	small	UAS will	never	operate	at	higher than	400	AGL	with	the	exception	that	in	circumstances	where	the small UAS	is	used	to	survey	or photograph	a	structure	whose	height	exceeds	400	feet	AGL,	the	small	UAS will	not	be	operated	more than	100'	above	the	highest	point	on	the	structure.	It	will	however	be operated	in	a	re stricted	area	with security	perimeter,	where	buildings	and	people	will	not	be	exposed to	operations	without	their	pre

- obtained consent.	The	equivalent	level	of	safety	will	be	achieved given	the	size,	weight,	speed	of	the small	UAS	as	well	as	the	location	where	it	is	operated.	No	flight will	be	taken	without	the	permission	of the	property	owner	or	local	officials.	Because	of	the	advance notice	to	the	property	owner	and participants	in	the	filming	activity,	all	affected	individuals	will	be aware	of the	planne d	flight	operations. Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighti ng	far	more	than	the	maximum	55 bs. proposed	herein	and	the	lack	of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less than those	presently	presented with	conventional	aircraft	operating	at	or	below	500	AGL.	In addition,	the low

- altitude	operations	of	the	small	UAS	will	ensure	separation	between	these	small

UAS	operations and	the	operations	of	conventional	aircraft	that	must	comply	with	Section	91.119

. **14	C.F.R.	§91.121	Altimeter	Settings.** This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	altitude	by	reference to an	altimeter	that	is	set	"	...	to	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter setting available	before	departure."	As	the	small	UAS	may	not	have	a	barometric	altimeter,	but instead	a	GPS altitude	read	out,	an	exemption	may	be	needed.	An	equivalent	level	of	safety	will	be achieved	by	the operator,	pursuant	to	the	safety	check	list	and	live	f light	data	monitoring,	confirming the	altitude	of	the launch	site	shown	on	the	GPS	altitude	indicator	before	flight. **14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions** Section	91.151	(a)	prohibits	an	individual	from	beginning	"a	flight in	a n	airplane	under	VFR conditions unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to the	first	point	of intended	landing,	and,	assuming	normal	cruising	speed

- (1)	During	the	day,	to	fly after	that	for	at	least 30	mi nutes;	or	{2}	At	night,	to	fly	after	that	for	at	least	45	minutes."	The	battery powering	the	small	UAS provides	approximately	30	minutes	of	powered	flight.	To	meet	the 30

- minute reserve	requirement	in	14 CFR	§91.151,	small	UAS	flights	would	be	limited	to	a pproximately 10	minutes	in	length.	Given	the limitations	on	the	small	UAS's	proposed	flight	area	and	the	location	of its	proposed	operations	within	a P re - determined	area,	a	longer	time	frame	for	flight	in	daylight	or	twilight	VFR	conditions	is reasonable. Applicant	believes	that	an	exemption	from	14	CFR	§91.151{a)	falls	within	the	scope	of prior	exemptions. Operating	the	small	UAS,	in	a	tightly	controlled	area	where	only	people	and property	owners	or	official representatives	who	have	signed	waivers	will	be allowed,	with	less	than 30	minutes	of	reserve	fuel,	does not	engender	the	type	of	risks	that	Section	91.151{a)	was	intended to	alleviate	given	the	size	and	speed of	the	small	UAS.	Additionally,	limiting	small	UAS	flights	to	10 minutes	would	greatly	reduce the	utilityfor	which	the	exemption	will	be	granted.	Applicant	believes	that	an	eq uivalent	level	of	safety	can	be

achieved	by	limiting	flights	to	30	minutes	or	25%	of	battery	power

- whichever	happens	first.	This restriction	would	be	more	than	adequate	to	r eturn	the	small	UAS	to	its	planned	landing	zone	from anywhere	in	its	limited	operating	area.

**14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration** The	regulation	provides	in	pertinent	part: (a)	Except	as	provided	in§ 91.715,	no	person	may	operate	a	civil	a ircraft	unless	it	has	within it the	following: (1)	An	appropriate	and	current	airworthiness	certificate	.... (b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	required	by paragraph	(a)	o fthis	section	or	a	special	flight	authorization	issued	under	§91.715	is displayed	atthe	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.
The	small	UAS	fully	loaded	weighs	no	more	than	55	lbs.	and	is	operated	without	an	on	board	pil ot.	As such,	there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or	to	display	them on the	small	UAS. An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the ground	control	point where	the	pilot	flying	th e	small	UAS	will	have	immediate	access	to	them;	to	the extent	they	are applicable	to	the	small	UAS. **14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections**

. These	regulations	require	that	an	aircraft	operator	or	owner	"shal l have	that	aircraft	inspected	as prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections,	except	as	provided	in paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter	...	," and others	shall inspect	or	maintain	the	aircraft	in	compliance	with	Part	43.	Given	that	these	section and Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate,	these	sections	will	not	apply	to the applicant. The	operator	pursuant	to	the	flight	manual	and	operating	handbook	will	accomplish maintenance .	An	equivalent	level	of	safety	will	be	achieved	because	these	small	UASs	are	very limited in	size	and	will	carry	a	small	payload	and	operate	only	in	restricted	areas	for	limited	periods	of time.	If	mechanical	issu es	arise	the	small	UAS	can	land	immediately	and	will	be	operating	from	no higher than	400	feet	AGL.	The	operator	will	ensure	that	the	small	UAS	is	in	working	order	prior	to initiating flight,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance performed. Moreover,	the operator	is	the	person	most	familiar	with	the	aircraft	and	best	suited	to	maintain	the aircraft	in	an airworthy	condition	to	provide	the	equivalent	level	of	safety. An	equivalent	level	of	safety	will	be	achieved	because	maintenanc e	and	i nspections	will	be performed	in accordance	with	the	small	UAS	Manufacturer's	Manual,	as	referenced	in	the	Aircraft Operations	Manual (AOM}.	As	provided	in	the	FOM,	the	operator	will	ensure	that	the	small	UAS	is	in working	order	prior	to initiating	flight	and	perform	required	maintenance	needed.**Small	UAS	Information**

Small	UAS's	to	be	used	are	as	follows	but	not	limited	to	providing	t hey	are	within	the	scope	of	the exemption	granted	by	the	FAA:
1.	DJI	Phantom	3 Professional Weight	(Battery	&	Propellers	Included)

- 2.8211bs. Hover	Accuracy

- Vertical:+/

- .33ft	(when	Vision	Positioning	is	active)	or	+/

- 1.64ft Horizontal:	+/

- 4.9	ft Max	Yaw	Angular	Velocity

- 200°/s Max	Tilt	Angel

- 35° Max	Ascent	Speed

- 16	ft/s Max	Descent	Speed

- 9	ft/s Max	Flight	Speed

- 36m	ph DJI	Phantom	3	Battery o	DJI	4480mAH	LiPo	Battery DJI	Phantom	3	Gimbal Controllable	Range

- Pitch

- 90	degrees	to	+30	degrees Stabilization

- 3

- axis	(pitch,	roll,	yaw) DJI	Phantom	3	Camera o	Operating	Temperature	Range

- 32°F

- 1 04°F o	Sensor	Size

- 1/2.3	in. o	Effective	Pixels

- 14M o	Resolution

- 4384x3288 o	HD	Video	Recording •	UHD:	4096x2160p	24/25,	3840x2160p	24/25/30 •	FHD:	1920x1080p	24/25/30/48/50/60 •	HD:	1280x720p	24/25/30/48/50/60 o	Recording	Field	of	View

- 110°/85° DJI Phantom	3	Transmitter o	Operating	Frequency

- 2.400GHz

- 2.483GHz o	Communication	Distance	(unobstructed)

- FCC	Compliance:	2400	ft o	Receiver	Sensitivity	(1%PER)

- 101dbm	+/

- 2dbm o	Transmitter	Power

- FCC	Compliance:	20dbm CE:	16dbm
DJI	Phantom	3	Professional	Firmware	also	makes	it	impossible	to	operate	within	a	5	mile

- radius	of an	airport,	further	increasing	the	safety	of	the	National	Airspace	and	the	general	public. Thank	you	for	your	consideration	of	these	exemptions. Regards,



### Ross	Costanza Owner/ Operator Ross	Costanza	Photography

### RCP