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Petition for Exemption - Section 333 

October 8, 2015 

Docket Operations, M.-30 

U.S. Department of Transportation 

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 submit this petition for exemption under Section 333; 

FAA Moderni:z:ation and Reform Act of 2012, 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 order to 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 Director of Imagine NWI. We are a State of Washington 

non-profit corporation that specializes In community development training, 

coaching and consultation. We have added "Visual Impressions" as a project 

within Imagine NW! through which our videography and photography functions. 

Operating a UAS as described above will provide our non-profit with greater 

financial sustainability, and, will greatly assist our greater Whatcom County 

community with 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 of aerial photography/videography are simply not viable options for the 

average consumer as they are costly and involve greater risks to everyone 

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

involved; i.e. the use of larger aircraft 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 of the operator. 

• At all times the small unmanned aircraft will remain close enough to the 

operator for the operator to be capable of. seeing the aircraft with vision 

unaided by any device other than corrective lenses. 

• Will not operate over any persons not directly involved in the operation. 

• VVill operate during daylight-only operations. 

• 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 a weather visibility greater than 3 miles from control 

station. Will remain clear of clouds. 

• No operations will oceur in Class A terminal airspace. 

• Operations in Class 8, C, 0 and E airspace will occur only with ATC 

permission. 

• No one will act as an operator or VO 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. 

• Prior to each flight/operation of the 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 a foremost concern with each flight. My UAS is designed to 

hover in place via GPS and operate in 'less than a 28 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, 1 utilize the Fail Safe 

Mode for 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 of take off using an automated return to 

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home feature. I am constantly on alert for 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 under 400 

feet. I utilize a fully charged battery for every flight 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 of time 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 of the commencement of flight operations. 

Any and all repairs will be performed only by the 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 

I plan to operate within either's airspace (no matter the 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 of this petition are similar to those of Mr. 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); 

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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 I and Visual Impression 

follows for proper operation and safety of the Phantom 2. 

Thank you for your 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 ..... . 

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P.sn 
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Phantom 2 

CHECKLIST.. ~Vi~.Y!l.llmpressions 

command 

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Aircraft hovering -10 feet, 

confirm: 

"" Control stick inputs agree 

'* Maneuverability stable & 

correct 

3603189840 T0:12024932251 

Max Alt. Rate of Gain: 17.75 

feet/sec 

Time to reach 400 feet: 22.5 

sec 

[Based on radar testing on 

030814] 

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