May 28, 2015

Exemption No. 11704

Regulatory Docket No. FAA–2015–0770

Mr. Andrew J. Pond

Owner

Dock House Digital, LLC

1548 Maple Grove Drive

Johns Island, SC 29455

Dear Mr. Pond:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on March 26, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Dock House Digital, LLC (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial photography and videography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, a comment 

opposing the petition was submitted to the public docket. In granting this exemption, the 

FAA has determined that the proposed operations can safely be conducted under the 

conditions and limitations of this exemption. As with exemptions issued to Aeryon Labs, 

Astraeus Aerial, Clayco, Inc., and VDOS Global, LLC, failure to comply with the document’s 
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conditions and limitations is grounds for immediate suspension or rescission of the 

exemption.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI T600.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21 and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Dock House Digital, LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 
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91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Dock House Digital, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI T600 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
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documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
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government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
Andrew	J.	Pond

Dock	House	Digital,	LLC

1548	Maple	Grove	Dr.

Johns	Island,	SC	29455

Phone:	(843)	743-3555

E-mail:	drew@dockhousedigital.com

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”) and 14 C.F.R. Part 11, Dock House Digital, LLC (“DHD”) seeks an 

exemption from Federal Aviation Regulations (“FARs”) detailed below for the following 

described Unmanned Aerial System called in this application the DHD System, which 

includes an Unmanned Aircraft (UA) and ground station-based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

• €A lightweight (6.4 lb gross weight with all on-board equipment and no 

payload), battery operated fixed-wing UA in the form of a quadcopter that takes 

off and lands vertically, manufactured by DJI, Model T600, with a maximum 

speed of 50mph and dimensions of 17in. x 17in x 12in. modified by the applicant 

to carry the following equipment in flight; 

• €An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

• €An on-board camera capable of capturing imagery in the form of full color, 

high definition still photos and video; 

• €An on-board telemetry system that delivers flight data from the on-board 

flight computer to the on-board radio transmitter including altitude AGL, 

horizontal and vertical speed, compass direction of flight and direction back to its 

launch site; 

• €A 600mW, 5.8GHz on-board radio transmitter that transmits live video from 

the on-board camera plus all the flight data from the telemetry system described 

above; THE GROUND STATION-BASED 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 on-board camera 

and computer projects it all together onto a screen for the PIC to view during 
flight; 

• €A Visual Observer (VO) is a person 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 DHD System to support aerial photography and video primarily of real 

property, specifically individual properties of no more than two acres in size. We 

are a video production company who uses these aerial images solely to enhance 

our end product, giving our clients a view of their property, which cannot be 

established from any ground-based equipment. We do not seek any type of 

additional compensation from our clients to use this technology. This technology 

is used solely for professional-quality video production purposes. Our use of the 

UA is very minimal as we simply elevate the UA (to no more than 100 ft.), get a 

360 degree shot of the property, and then land the UA; a process of no more than 

8 minutes. The UA, for our purposes, is only used vertically, and never travels 

horizontally, minimizing any danger or threat to an individual.

The UA, 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 18 minutes, this offers little to no risk to national security as the 

maximum altitude intended for our use is less than 100 ft. Our use of the UA will never 

be closer than 30 miles to the nearest airport.

Low-level oblique photos and video from several angles are far more effective than 

ground- based imagery for displaying the characteristics of large, complex properties 

with several buildings and large trees. The applicant in the past has chartered 2-seat fullsized helicopters for this purpose, which has proven more costly than our business has 

been able to afford. The benefits of reduced cost and improved quality of presentation 

from the UA will be valuable to our business as a whole.

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, et al., 

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

The DHD System will be operated in the field with both a PIC and a VO 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 DHD System will not be operated over densely populated areas; 

. (h) The DHD System will not be operated at air shows; 

. (i) The DHD System will not be operated over any open-air assembly of people; 

. (j) The DHD System will not be operated over heavily trafficked roads; 

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

. (l) The DHD System 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 Pre-Flight 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 will 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 are:

Dock House Digital, LLC Attn: Andrew J. Pond Ph: 843-743-3555
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 CFR 45.23, 

45.29..........................Addendum Page 2 - 14 CFR 91.9....................................Addendum 

Page 2 - 14 CFR 61.113, 61.133.......................Addendum Page 2 - 14 CFR 91.109, 

91.119, 91.121..............Addendum Page 3 - 14 CFR 

91.151.................................Addendum Page 4 - 14 CFR Subpart E (91.401 - 91.417) 

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

...Addendum Page 4

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,

_______________________________________________________

Andrew	J.	Pond,	Owner	– Dock	House	Digital,	LLC