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Petition for Exemption
- Section 333 October 8, 2015 Docket Operations, M.-30 U.S. Department ofTransportation 1200 New

### Jersey Avenue, SE. 

### Room W12

..140, West Building Ground Floor Washington, OC 20590-0001 To Whom It May Concern: 

### Jeff Littlejohn Imagine NWNisuallmpressions 9284 Double Ditch Road · · · Lynden,VVA.98264



### "

I, Jeff Littlejohn, hereby submitthis petition for exemption under Section 333; FAA Moderni:z:ation and Reform Act of2012, Public Law 112-95 FEB. 14, 2012, Section 

### 333. 

### I reCjuest this 

### exemption 

### in order

### to operate 

### my small Unmanned Aircraft System 

### (UAS), DJI Phantom 2 Professional Quadcopter Aircraft, in orderto provide feefor-services to include: aerial photography, aerial cinematography, aerial filming and photography for real estate, construction firms, agricultural modeling, crop monitoring operations, environmental monitoringfmapping, news reporting, special events 

### to include 

### but not 

### limited

## to weddings, 

### private or public 

### parties/events, business 

### advertising, promotional 

### events, geological surveying, and environmental studies. I serve as the Executive Directorof Imagine NWI. We are a State ofWashington 

### non-profit corporation thatspecializes 

### In community 

### developmenttraining, coaching 

### and consultation. 

### We have added "Visual Impressions" as a project within Imagine NW! through which ourvideography and photography functions. Operating 

### a UAS 

### as described above 

### will provide our non-profit with greater financial sustainability, and, 

### will greatly assist our greaterWhatcom County 

### communitywith such seNices 

### prior non-existent The 

### ability to provide these services to other local businesses, non-profits. churches. 

### community organizations, and individuals in my 

### community will benefit them by opening up opportunities they otheiWise did not have before. Traditional methods ofaerial photography/videography are simply not viable options for the average consumer as they are costly and involve greater risks to everyone

1OCT-10-2015 04:23 FROM:NEW WAY MIN 3603189840 T0:12024932251

involved; i.e. the use of largeraircraft carrying humans and flammable fuel. 

### By utilizing UAS the same results can be achieved with much safer conditions. I hold a current FAA Private Pilot Certificate [issued 12/22/2003}. I have a current Washington State Driver License. I have over 300 operational hours flying the Phantom 2. Operational Limitations and Specifications 

### • The UAS weighs less than 

### 31bs. (including Phantom 

### 2**w/~** 

### battery, Zenmuse H3-3d gimbal, and GoPro Hero

### 4 camera). • The 

### UAS remain within 

### VLOS ofthe operator. • At all times the small unmanned aircraft will remain close enough to the operatorforthe operatorto be capable of.seeing the aircraftwith vision unaided 

### by any device otherthan corrective lenses. • Will not operate over any persons notdirectly involved in the operation. • VVill operate during daylight-onlyoperations. • Will yield right-of

.. way to other aircraft, manned or unmanned. • Maximum 

### airspeed 

### will be under 30 mph. 

### • Maximum altitude

### will be 400 feet above ground level. • Will operate with aweathervisibility greaterthan 3 miles from control 

### station. Will remain clear ofclouds. • No operations will oceur in Class Aterminal airspace. • Operations in Class 8, C, 0 and Eairspace

### will occuronly with ATC permission. 

### • No one will 

### act as an operator orVO for more than one unmanned aircraft operation 

### at one time. • Operating remote control frequency will be 2.4GHz ISM. • There 

### will be no careless or reckless operations. 

### • Priorto 

### each flight/operation 

### ofthe UAS, I

### will conduct 

### a Pre-Flight Safety Inspection. [See Attachment 1] • Operations will strictly follow the procedures and methods as recommended by the UAS manufacturer. [See Attachments 2·51 Since I am certified as a FAA Private Pilot, I am keenly aware and personally vested in safety as aforemost concern with each flight. My UAS is designed to hover in place via GPS and operate in 'less than a28 wind. For safety, stability and fear of

### financial loss 

### 1 will not

### fly in winds exceeding 18 mph. Built in safety 

### systems include a

### GPS mode that allows my 

### UAS to hover in 

### place when radio controls are released. Wrth three modes to choose from, 1utilize the 

### FailSafe Modefor aerial video and photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost 

### UAS is designed 

### slowly descend to point oftake off using an automated return to



### 2OCT-10-2015 04:24 FROM:NEW WAY MIN 3603189840 T0:12024932251

home feature. I am constantly on alertfor any manned aircraft and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near 

### my location. Utilizing 

### battery power rather,than combustible 

### fuels, flights generally last between five (5) to ten (10) minutes, with an altitude under400 feet. I utilize afully charged battery for everyflight as an added safety precaution and we have 5 spare batteries fully charged as back-ups. Furthermore the UAS offers pre
..sets to alert me when the battery has discharged to 30%, so there is plenty 

### oftime to land prior

### to the batteries expiration. The complete flight time for each battery is between 20 and 23 minutes with the 30% level generally reached within 16 minutes ofthe commencement offlight operations. Any and all repairs will be performed only bythe manufacturer's authorized repair facilities/ providers. Our 

### primary geographical focus for operating the UAS will be Whatcom County, Washington. There are two FAA regulated**J~irports** that fall within this area; Bellingham International Airport (Class 0) and Lynden Airport (Class E). Anytime Iplan to operate within either's airspace (no matterthe intended UAS expected altitude) I

### will call the respective ATC controlling authority seeking permission. 1 have each airspace mapped out on my Google Earth system, thus giving me during planning a precise situational awareness understanding. The requests ofthis petition are similarto those ofMr. Chris Ballardj Mr. Jase W. RobaK, Mr. Todd, Thomas Drone Pies, and Mr. Mike Lloyd Lloyd &Associates, all who have received Section 333 exemptions for comparable aircraft for similar operations. 'The specific sections of 14 C.F.R.from which I am $eeking exemption are: Part 21; 

### 45.23(b); 61.101(e)(4), & (5); 61.113(a) & (b); 61.133 (a); 61.23(a} 

### &(c); 

### 91.7(a) 91.9{b)(2); 91.103(b); 91.109(a); 91.119; 

### 91.121: 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1);

3 P.4/?OCT-10-2015 04:24 FROM:NEW WAY MIN

91.409(8)(2}: 91.417(8) & (b)

. 3603189840 T0:12024932251

.Please find included**Atta~.bm.:tn.~**

### ..**~r bj.J1~** for 

### materials Iand 

### Visual Impression follows for 

### proper operation and 

### safety ofthe Phantom 

### 2. Thankyou foryour consideration. 

### Sincerely,

Jeff Littlejohn, Executive Direc:tor Imagine NWNisual Impressions
Attachmen_ts or..
...**b!~ka:** 1. Visual Impressions
- Phantom 2 Checklist [See below] 2. DJI Fly 

### Safe- No Waypoint Zones; and, No Fly 

### Zones**h~P-~:/Iwww.dji.comlfJy-$~fe** 3. OJI Phantom 2 Quick Start Guide**http://downLQ~q ~-~m:** **innovations.C-Qr:nl.dqwnloads/pha.otgm_2/~n/P_!:I.~!'JTOM2** Quick Start**~IJ.i~~-~n~.** 

### pgf 4. DJI Phantom 2 User Manual**_b.!!Q://downiQ/3d.qji~ innovatjgQ~.gQrn/download_$fphantgm** **2/en/PHANTO.M~~V§.~r** 

### Manual v1 .4 

### en. 

### pqf 5. DJI Smart Flight Battery Safety Guidelines**tJ~p:.ffdownload.dj.i.~**

### iD~~:~~i~~;,o~~g_gwnloads/P.h~ntom_2 vision

### plus/Sm~rt_£!!ght Battery_$.f:lfe! y_ ...

### P

......

4 

### P.snOCT-10-2015 04:24 FROM:NEW WAY MIN 3603189840 T0:12024932251

Phantom 2 CHECKLIST..**~Vi~.Y!l.llmpressions**

command



### 5OCT-10-2015 04:24 FROM:NEW WAY MIN

Aircraft hovering -10feet, confirm: "" Control stick inputs agree '* 

### Maneuverability stable & 

### correct 3603189840 T0:12024932251

MaxAlt. Rate ofGain: 17.75 feet/sec Timeto reach 400feet: 22.5 sec [Based on radartesting on 030814]

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