Petitioning for Exemption under Section 333

Type of application – Still Photography

UAS – DJI Phantom 2

Camera – GoPro

Primary	use	of	UAS	would	be	lower	altitude	flight	for	images	during	weddings	and	

real	estate	images.	The	DJI	Phantom	2	UAS	is	designed	to	be	lightweight	and	can	

carry	a	smaller	camera	such	as	the	GoPro	Hero.	The	GoPro	is	limited	to	its	wideangle lens	so	flying	too	high	would	create	images	that	are	not	usable	in	my	opinion	

so	anything	over	150ft	to	200ft	would	be	too	high.	

Safety	is	very	important	to	my	business.	The	UAS	is	equipped	with	lights	for	

visibility.	Night	flying	would	not	be	performed.	Weight	of	the	UAS	is	1000g	(2.2lbs)	

according	to	the	manufacturer.	The	GoPro	camera	is	around	8.1	oz. at	its	heaviest.	

When	on	photo-shoots	I	have	a	2nd Photographer	and/or	Assistant	that	would	be	

able	to	assist	in	spotting	and	be	another	set	of	eyes	on	the	ground.		The	UAS	is	also	

equipped	with	guards	over	the	props	and	uses	a	plastic	prop	that	is	self-tightening.		

It	uses	a	GPS	on	board	to	ensure	it	doesn’t	fly	away.	I	am	also	aware	of	the	No	Fly	

Zones	in	my	area.	Also	would	be	aware	of	the	zones	if	traveling.		To	ensure	the	safest	

flight,	the	UAS	will	never	leave	the	ground	without	a	pre-flight	check	which	will	

include:	Battery	Check	(must	be	full	charge),	prop	check,	Bolt	check	of	the	gimbal	

that	secures	GoPro,	GoPro	secure	to	gimbal,	safety	lights	functional,	transmitter	

battery	charge.	Myself	and/or	assistant	will	plan	shots	before	take	off	to	ensure	

minimum	time	in	the	air	and	maximum	efficiency	since	flight	time	is	25	minutes	

with	UAS.		Flight	plan	is	also	needed	to	determine	any	obstacles	or	crowds	that	need

to	be	avoided.	Weather	will	also	be	checked	and	assured	flight	will	not	be	affected.

PIC	does	not	have	an	airman	certification.	UAS	training	with	this	UAS	is	learning as	

you	go.	As	a	hobbyist	PIC	has	used	the	UAS	and	ones	smaller	and	same	controls	for	a	

year.	DJI	Phantom	2	is	made	to	be	a	beginning	level	UAS	and	is	equipped	with	many	

options	to	make	flight	easily	learnable.		I	do	plan	on	trying	to	further	my	knowledge	

even	further	to	obtain	a	license	or	certification	for	UAS	if	applicable.	

Primary	Uses	Explained:

Wedding	Photography:	Mainly	used	for	exterior	venue	shots	if	the	

area	allows	a	safe	flight.	This	image	would	be	taken	early	on	in	the	day	when	

guests	aren’t	present.	The	occasional	outdoor	wedding	as	well	as	the	group	

shot	could	be	taken	with	the	drone	but	would	not	exceed	50ft	– 100ft.	

Real	Estate:	Exterior	photography	of	real	estate	property	for	clients.		

There	 would	be	5-10	images	taken	during	a	real	estate	photo	shoot.	All	

images	will	be	planned	out	before	flight	to	ensure	efficiency.		Realtor	would	
be	present	as	well	as	told	to	notify	direct	neighbors	that	a	UAS	will	be	

present	for	a	short	amount	of	time	range.

Operating	speeds	would	not	be	high.		Still	photography	requires	the	UAS	to	be	still	

and	stationary	while	still images	are	taken.	Height	will	be	limited	as	well	because	of	

the	wide-angle nature	of	the	Camera’s	lens.		Too	close	and	the	image	is	distorted	and	

too	far	away	you	won’t	see	anything	so	the	sweet	spot	of	any	shots	taken	with	this	

UAS/Camera	would	be	25ft-60ft	with	some	real	estate	reaching	the	higher	of	that	

range	but	no	more	than	100ft.	

Airports	in	the	area	are	all	out	of	range	from	where	I	would	be	photographing	and	if	

travelling	would	be	sure	to	be	at	least	5-6	miles	away	from	the	No	Fly	Zone.		

PIC	Information:	

Company:	MJOY	PHOTOGRAPHY

Owner:	Mitch	Highman

Phone:	701.730.0422

Email:	mitch@mjoyphotography.com

Website:	www.mjoyphotography.com