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December 14, 2015

F5 Graphics, Inc.

6245 Indian Trail Drive

Loxahatchee, FL 33470

(561) 795-4826

Email: F5Graphics@att.net

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 2059

Reference: Docket No. FAA-2015-4253

This is an update to our exemption request Docket No. FAA-2015-4253 addressing the issues of:

 The reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which you seek an 

exemption.

 Any additional information, views, or arguments available to support your request.

First, the potential loss of life is diminished because UAS carry no people on board and will be operated 

in specific areas away from mass populations. Second, there is no fuel on board the UAS and thus the 

potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability 

of a UAS allows it to be remotely piloted away from and avoid hazards quickly and safely.

F5 Graphics, Inc. considers safety of utmost importance with every flight. The DJI Phantom 3 

Professional is designed to hover in place via GPS and operate in less than a 16 knot (17 mph) wind. For 

safety, stability and fear of financial loss F5 Graphics, Inc. will not fly in winds exceeding 14 knot (15 

mph). Built in safety systems include a GPS mode that allows DJI Phantom 3 Professional to hover in 

place when radio controls are released. When pilot communication is lost, the UAS is designed to slowly 

descend to point of take-off. The DJI Phantom 3 Professional utilizes battery power rather than 

combustible fuels. F5 Graphics, Inc. utilizes a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is twenty (20) to twenty-five (25) minutes as tested, this 

offers little or no risk to national security. The UAS, powered by batteries, is smaller, lighter and more 

maneuverable than larger aircraft running on combustible fuel with no people on board thereby reducing

current risk levels and enhancing public safety. Due to the small size of the DJI Phantom 3 Professional, 

the material with which the DJI Phantom 3 Professional is built and its specific safety procedures (among 
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others ground detection), the hazard to persons, vessels, vehicles, and structures is not comparable to 

manned aircraft and should be considered in granting the exemption. 

The safety and reliability of the DJI Phantom 3 Professional is supported by the fact that numerous FAA 

exemptions have previously been approved for their use in commercial operations. 

F5 Graphics, Inc.’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is 

important to note that absent the integration of commercial UAS into our national airspace system, fixed 

winged aircraft and helicopters are the primary means of aerial photography and videography. While the 

safety record of such aircrafts are remarkably astounding, there has been incidents involving loss of life 

as well as extensive property damage; it is far safer to operate a battery powered ultra-lightweight UAS. 

The unmanned aspect of aerial technology eliminates the endangerment of human life by allowing low 

and slow flight and permits a safe and cost-effective acquisition of close-up aerial images.

F5 Graphics, Inc. has personally instilled safety protocols and controls to avoid and prevent public 

hazard, as well as interaction with manned aircraft. F5 Graphics, Inc. use of the DJI Phantom 3 

Professional will be subject to the following operating conditions, which are based on the operating 

conditions set forth by the Academy of Model Aeronautics. The main restrictions are summarized 

below:

 Operations to be conducted over private, controlled-access, or public property where 

approved; 

 Permission from the land owner/authority required before commencing any flight;

 Operations over congested areas shall be avoided;

 Operations must not interfere with manned aircraft operations, must yield the right of 

way to manned aircraft, and operators must See & Avoid other aircraft and obstacles at 

all times

 Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and 

daylight hours

 Aircraft operations must remain within Visual Line of Sight (VLOS) and will be 

visually monitored at all times;

 Flight ceiling pre-programed at maximum 400 feet;

 All operations conducted within 5 miles from an airport shall only be initiated after 

verbal coordination with the airport authority, or air traffic control when a control 

tower is present at the airport;

 All operations shall comply with required permissions and permits established by 

territorial, state, county or city jurisdictions; including local law enforcement, fire, or 

other appropriate governmental agencies.

For the reasons stated in our exemption request of July 13, 2015 (Docket No. FAA – 2015-4253), F5 

Graphics, Inc., respectfully request the grant of an exemption to be allowed to operate ultra-light weight, 

remote controlled UAS for the purposes of acquiring aerial photos & videos, both of which will promote 

local economic growth through increased employment and increased tax base. Both performed with 

public safety in mind by utilizing a safe ultra-lightweight UAS as an alternative to manned aircraft 

containing combustible fuel that poses potential public hazard during low and slow flight.
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The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

photography and videography captured through F5 Graphics, Inc. battery operated ultra-lightweight

UAS's. Permitting F5 Graphics, Inc., to immediately fly within national air space furthers economic 

growth. Granting this exemption request substantially furthers the economic impact for the South 

Florida area for companies looking to use aerial photography and videography, both of which serve as a 

stimulus to the community.

Granting F5 Graphics, Inc.’s request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS into the national airspace 

system, but to “...establish requirements for the safe operation of such aircraft systems [UAS] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS for 

photography, videography and aerial data collection purposes. Further F5 Graphics, Inc. will conduct 

operations in compliance with the protocols described herein or as otherwise established by the FAA. 

Respectfully submitted,

F5 Graphics, Inc.

Jozie M. Felicella

Donald J. Felicella