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 Reform

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 Unmanned Aircraft System (UAS) with an attached 

Gimbal Mount holding a 4K UHD Camera for the purpose of aerial 

photography and video for Real Estate, Homebuilders, Home 

Inspectors, Commercial Buildings, Golf Courses, and Insurance 

Investigations 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 Act 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) weighing less than 3 pounds and thus offers a lightweight, 

small and compact video platform compared to manned aircraft.

The DJI Phantom 3 is a quad-rotor UAS. The UAS features a 

safety Return to Home function that in the event of a signal loss, 

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

Home 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 Phantom 3 responds to commands while 

automatically handling the most complex aspects of safe, stable 

flight.

2. The DJI Phantom 3 Professional offers significant safety, noise, 

emission, security and environmental benefits not available to 

larger manned aircraft.

3. The DJI Phantom 3 Professional has numerous safety features 

such as failsafe mode, automatic return home feature should 

signal between PIC and UAS be interrupted, GPS based altitude 

and distance locks, Flight Limits function and low battery 

warnings.

4. Operations utilizing the DJI Phantom 3 Professional will provide 

a benefit to the general public and serve the public interest by 
providing the service of aerial photographic 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 Level 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 

need to adhere to the conditions and limitations of the exemption

under Section 333. 

1. The safe operation of the UAS will be the first priority before, 

during and after every operation. It will be taken with the most 

seriousness. Safety is number one and 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% battery capacity.

3. All UAS operations will be conducted at Visual Line Of Sight

(VLOS) below 400 feet AGL.

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

5. No UAS operations shall occur over densely populated areas, 

large assemblies of people, stadiums, 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 3 
miles 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 permissions will be obtained from local 

and state government should they be required.

10. 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.

11. At no time shall the UAS be operated with missing or 

manufacturer unapproved parts, or in any condition that could 

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

ground.

12. 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 present, weather conditions, safety 

procedures at the specific location and approximate duration and 

route of flight. If any are found, no flight will take place.

13. The aircraft will automatically return to point of origin or 

descend in place should signal with the transmitter be lost. 

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

on combustible fuel, has very low decibel level noise emissions 

and has a small payload capacity and short flight time, thus 

significantly reducing current risk levels involved with utilizing 

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

aerial photography images and video at a significantly lower price 

and in the process I will be providing that data at a greater or at 

least equivalent level of safety 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 parameters 

outlined above, the specific exemptions identified above, and

equivalent level of safety provided at a much lower cost to the 

general public will allow the FAA to grant an exemption to 

Portland Drone Videography LLC. for commercial UAS aerial 

photography operations under the Reform Act of 2012.

Thank you for reading and considering this request.

Sincerely,

Robert F. Zimmerman

Portland Drone Videography LLC

DBA: PDV

6825 SW Nyberg St. G204

Tualatin OR 97062

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