August 3, 2015

U.S. Department of Transportation, Docket Operations W est Building Ground Floor, Room W1 2

- 140 1200 New Jersey Avenue, SE Wa shington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (t he Reform Act), I, Kevin Robinson, owner of SkyEye Photography, hereby apply for an exemption from Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of a DJI Phantom 3 Professional four rotor UAS with an attached DJI Gim bal Mount holding a 4K UHD Camera for the purpose of aerial photography and video for a variety of industries. As the Reform Act allows the FAA to “establish requirements for the safe operation of such aircraft systems in the national airspace system”, I, Kevin Robinson use of the Phantom 3 Professional will provide the following benefits and enhance or provide an equivalent level of safety. 1. The Phantom 3 has a maximum takeoff weight of less than 3 pounds and thus offers a lightweight, small and compact video platform compared to manned aircraft. 2. The Phantom 3 offers significant safety, noise, emission, security and environmental benefits not available to larger manned aircraft. 3. The Phantom 3 has numerous safety features such as Failsafe mode,

au tomatic Return home feature should signal between PIC and UAS be interrupted, GPS based altitude and distance locks, Flight Limits function and low battery warnings. W e feel that these features addressed in more detail below and in the Phantom 3 User Manua l provide an equivalent level of safety. 4. Operations utilizing the 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. The safe operation of the UAS will be the first priority before, during and after every operation. 2. The UAS pilot will have the required sports Pilot certificate and will be considered the PIC whether flying or supervising and will be responsible for the safe operation of the UAS at all times. 3. The DJI Phantom 3 has a maximum takeoff weight of 1300 grams or approximately 2.9 pounds. It has a diagonal length of 590mm and a maximum speed of 16 meters per second. 4. The UAS utilizes GPS/GLONASS location and is controlled by a 2.4 GHztransmitter. 5. Al l UAS operations will be conducted at Visual Line Of Sight

(VLOS) at no more than 400 feet AGL. 6. No UAS operations will be conducted within 5 NM of an airport. 7. No UAS operations shall occur over densely populated areas, large assemblies of people, st adiums, government buildings, power lines, or major roads. 8. All nonparticipating persons shall be a minimum of 500 feet from the UAS. 9. If a nonparticipating person comes within 500 feet of the UAS, flight operations will cease immediately. 10. All UAS operations shall take place during daylight hours under conditions equivalent to Visual Flight Rules (VFR) with the UAS no more than 3/4 NM from the PIC. 11. All UAS operations will have a PIC and a Visual Observer (VO) present and all operations will be w ithin line of sight (LOS) of the PIC and VO. 12. The UAS will yield to all manned aircraft at all times. 13. All required permits and permissions will be obtained from local and state government should they be required. 14. A pre

-flight inspection by the P IC 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. 15. 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. 16. Prior to all UAS operations a pre

-flight meeting will be held by the PIC 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. 17. The PIC will have accumulated and accurately logged a minimum of 25 hours total time as a UAS rotorcraft pilot with a minimum of 10 hours as a UAS pilot with a multi

- rotor UAS and 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. 18. The Phantom 3 UAS will utilize GPS/GLONASS location, auto return home and will never be operated at belo w 20% batter capacity. The DJI Phantom 3 UAS is a small and safe sub 3

- pound plastic and composite aircraft utilizing four propellers driven by a 4480 mAh LiPo 4s 15.2v smart battery with a MAX flight time of 23 minutes. The remote control/transmitter ope rates at 2.4 GHz. The aircraft’s software has been set to FAA regulations of 400’ ceiling and recognizes zones around airports and forbids flight within 1.5 miles of the center of a type A airport, and outside the 1.5 miles up to 5 miles the altitude incre ase from 35’ to 400’ in a conical fashion. For example: at 1.5 miles out your limit is 35’ and at 3.25 Miles from the center the max altitude AGL is 217.5’. I think this feature is great and allows those who wish to take photos with their drone at say 10’ AGL 2 miles from an Airport; they are more than safe in doingso. The incorporated FLY SAFE technology also restricts flights in areas deemed

not permitted by the FAA, for example W ashington D.C. The aircraft will automatically return to point of origin o r descend in place should signal with the transmitter be lost. 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 signifi cantly reducing current risk levels involved with utilizing manned aircraft for aerial photography.

The exemption requests follow below. The DJI Phantom 3 User’s Manuals links are as follows: Quick Start Guide: http://download.dji

innovations.com/downl oads/phantom_3/en/Phantom_3_Professional_Quick_Star t_Guid e_en.pdf

User Manual: http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Man ual_v1. 0_en.pdf

Sincerely, Kevin Robinson SkyEye Photography 3812 Hunters Tra il Mesquite, Tx 75150 2kevo2@gmail.com 469

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