U.S. Department of Transportation, Docket Operations West

Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Submitted by:

Robert F. Zimmerman Portland Drone Videography LLC

DBA: PDV 6825 SW Nyberg St G204

Tualatin OR 97062
bzimmerman@bhhsnw.com

Dear Sir or Madam,

Accordance to Section 333 of the FAA Modernization and Refor m Act of 2012 (the Reform Act), I, Robert F. Zimmerman, Portland Drone Videography LLC, DBA PDV, hereby apply for an exemption from Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of a DJI Phantom 3

Professional Unmann ed Aircraft System ( UAS ) with an attached

Gimbal Mount holding a 4K UHD Camera for the purpose of a erial photography and video for Real Estate

, H omebuilders, H ome
I nspectors, C ommercial B uildings, G olf C ourses, and I nsurance I nvestigations to enhance their business, listings or marketing.

Regulations from which the exemption is requested:14 CFR 61.23 (a) & (c), 61.101 (e)(4) & (5), 61.113 (a), 61.315

(a), 91.7 (a), 91.119 (c), 91.121, 91.151(a)(1),91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (2), 91.417 (a ) & (b).

As the Reform A ct allows the FAA to “establish requirements for the safe operation of such aircraft systems in the NAS” , I, Robert F. Zimmerman, use of the DJI Phantom 3 Professional UAS will provide the following benefits and enhance or provide an equivalent level of safety.

1. The DJI Phantom 3 Professional Unmanned Aircraft System ( UAS ) weigh ing less than 3 pounds and thus offers a lightweight,

smal l and compact video platform compared to manned aircraft. The DJI Phantom 3 is a quad

- rotor UAS

. The UAS f eatures a safety Return to Home function that in the event of a signal loss,

the UAS w ill return to a preset position and land. The Return to

Hom e feature can also be triggered manually. The remote
connects to your phone or tablet, and a 720p HD view of everything your camera sees as you fly is displayed live. From takeoff to landing, the Phant om 3 responds to commands while automatically handling the most complex aspects of safe, stable flight.

2. The DJI Phantom 3 Professional of fers significa nt safety, noise,
emission, sec urity and environmental benefits not available to larger manned aircraft.

3. The DJI Phantom 3 Professional has numerous safety fea tures

such as f ailsafe mode, automatic r e turn home feature should signal between PIC and UAS be inte rrupted, GPS based altitude

and distance locks, Flight Limits function and low battery warnings.

4. Operations utilizing the DJI Phantom 3 Professional will provid e

a benefit to the general public a nd serve the public interest byproviding the serv ice of aerial p hotographic images and video to

numerous businesses and individuals for considerably less than

the previously only available option of utilizing manned aircraft at

an equivalent level of safety.

The Aircraft, Operations and an Equivalent Le vel of Safety

1. I currently hold a commercial pilot license with an instrument rating. I also have a background in ATC having worked at a ARTCC and TWR. I believe my background gives me a better understanding of the FAA, ATC system and the NAS and the

n eed to adhere to the conditions and limitations of the exemption

under Section 333.

1. The safe operation of the UAS wil l be the first priority before, during and after every operation. It will be taken with the most seriousness. Safety is number one an d that is why I wish to
request this exemption.

2

. The DJI Phantom 3 Professional UAS will utilize

GPS/GLONASS location, auto return home and will never be operated at below 20% batter y capacity

.

3 . All UAS operations will be conducted at Visual Line Of Sight (VLOS) below 400 feet AGL.

4 . No UAS operations will be con ducted within 5 NM of an airport.

5 . No UAS operations shall occu r over densely populated areas, large assemblies of people, stadiu ms, government buildings,

power lines, or major roads.

6

. All operations will be conducted during daylight hours and in

VFR /VMC conditions at all times

. Visibility to be not less than 3miles and not less than 500 ft below and 2,000 ft horizontal from a

cloud.

7 . All UAS operations will have a Visual Observer (VO) present and all operations will be within line of sight (LOS) of the VO.

8 . The UAS will yield to all manned aircraft at all times.

9 . All required permits and pe rmissions will be obtained from local and state government should they be required.

1 0 . A pre

- flight inspection by the PIC will be performed prior to each flight to assure that the UAS is safe for flight. A post

- flight inspection will also be performed as an added level of safety.

1 1 . At no time shall the UAS be operated with missing or manufacturer unapproved parts, or i n any condition that could

pose a hazard to any other aircraft or structure or person on the ground.

1 2 . Prior to all UAS operations a pre

- flight meeting or observation

will be held to determine the parameters of flight in a given location, any hazards pres ent, weather conditions, safety procedures at the specific locati on and approximate duration and route of flight. If any are found, no flight will take place.

13. The aircraft will automatically retur n to point of orig in or

descend in place should signal with the transmitter be lost.

14. The UAS is unmanned, operates at low altitud es, does not run

on combustible fuel, has very low decibel level noise emissions

and has a small payload capacity and short flight ti me, th us significantly reducing current risk levels involved with utili zing

manned aircraft for aerial photography.I will provide a public benefit in allowing more people to acce ss

aerial photography images and video at a significantly lower price and in the process I will be providi ng that data at a greater or at least equivalent level of safet y as compared to similar manned operations. It is the applicant’s belief that the small size of the DJI

Phantom 3 Professional UAS , the basic operating parame ters outlined above, the specific exemptions identified above

, and equival ent level of safety provided at a much lower cost to the general pub lic will allow the FAA to grant an exemption to Portland Drone Videography LLC . for commercial UAS aerial photogra phy operations under the Reform Act of 2012.

Thank you for read ing and considering this request.

Sincerely,

Robert F. Zimmerman Portland Drone Videography LLC

DBA: PDV

6825 S W Nyberg St

. G204

Tualatin OR 97062

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