July 20, 2015

Jacob Thomas

681 Johnson Rd

Oliver Springs, TN 37840

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act”) and 14 C.F.R. Part 11, I, Jacob Thomas seeks an 

exemption from Federal Aviation Regulations (“FARs”) listed below for the 

DJI Phantom 2/ 3, a quadcopter manufactured by DJI-Innovations.

The requested summary exemption would support an application for a 

“blanket” commercial Certificate of Authorization to use the system to 

capture aerial photography and videography. The DJI Phantom 2/3 system

consists of a lightweight (2.8 lb) battery operated aircraft, a mobile device 

based ground control station and/or RC Controller, and associated 

communications equipment. The aircraft carries an onboard gimbaled 

camera that allows it to obtain photographs and video.

The requested exemption would permit, Jacob Thomas, to pursue its 

commercial interests in providing services to clients using a small advanced 

UAS in the following areas:

• Real Estate/Architecture

• Construction Site Inspection

• Marketing

• Surveying/Mapping

• Sporting Events

• Special Events/Festivals

• Radio/Cellular Communications Towers

• Stack Inspection

The regulations from which the exemption is requested are as follows:

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 61.3

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

Unmanned Aircraft System

UAS are often seen as superior to helicopters as an aerial video gathering 

platform due to the smaller size of the devices, more affordable equipment 

and personnel cost, reduced noise, and a much smaller environmental 

impact which promotes public safety.

I, Jacob Thomas, am petitioning for an exemption to operate a DJI Phantom 

2/3 with a built-in stabilized HD camera and the following GPS safety 

features:

• Restricts the height Above Ground Level (AGL) to a specified user 

generated height.

• Restricts the radius of flight from the ground station to a user-generated 

distance.

• Restricts operations within designated Class B, C, and D airspace

including a no-fly zone feature.

The DJI Phantom 2/3 also has a failsafe function that is triggered in the 

event communications are lost between the UAS and the main controller 

transmitter. In the unlikely event this occurs, the UAS will return to its point 

of takeoff and land safety. If communications are restored, the PIC can 

regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards (AC 

91-57) as set below:

· The petitioner will only operate its UAS in line-of-sight of a Pilot in 

Command (PIC) and/or ground based Visual Observer (VO) and will 

operate at sites that are ‘sufficient distance’ from populated areas 

within the sterile area described in the FOPM. Such operations will 
ensure that the UAS will “not create a hazard to users of the national 

airspace system or the public.” The orientation of flights will be such 

that the PIC or VO always has a visual on the rear mounted LED flight 

Indicator. Additional safety features on the DJI Phantom 2/3 include an 

automatic return-to-home feature enacted upon low battery level.

 When flying the UAS within three (3) miles of an airport, airport 

operators will be notified at least 72 hours prior, and the operator will 

give the right-of-way to any manned aircraft.

 Pre-flight inspection would include checking battery condition/level in 

the transmitter, control tablet, and UAS; a visual/operational check of 

the propellers; a visual/operational check of the aircraft; a 

visual/operational check of the motors; a full compass and IMU 

calibration; a visual/operational check of the transmitting radio control 

unit; a visual/operational check of the camera and gimbal unit; and a 

visual/operational check of the vision positioning system. A check for 

power-lines, antennas, and other overhead objects would also be 

performed. Wind and weather conditions would be monitored and be 

taken into account as a factor for flying.

· The radio frequency of the DJI Phantom 2/3 is in the 2.400 to 2.483 

GHz range. Maximum takeoff weight approximately 3000g. Max 

Ascent/decent speed 5 m/s. Maximum flight Velocity 16 m/s. The UAS 

to be operated by the petitioner weighs less than 3 pounds, including 

all payload (i.e. battery, camera, lens, and stabilized gimbal).

· Testing, updating and programming the DJI Phantom 2/3 firmware 

would be done on a monthly schedule.

 Flights will be terminated when battery energy levels reach 25%, 

allowing sufficient reserve flight time to safely land the UAS. If battery 

drops below a user specified level the UAS will automatically return to 

its takeoff point and land safely.

 The UAS will be programmed so it will not be operated at an altitude 

that exceeds 400 feet AGL, and not more than 150 feet above a 

significantly elevated geographic position from which videography/ 

photography is planned.

 The aerial perspective would allow my business to provide a unique 

service to local clients that is attractive and competitively priced.

· Given the small size of the UAS and the restricted sterile environment 
within which it will operate, I, Jacob Thomas, will adhere to the Reform 

Act’s safety requirements.

· The DJI Phantom 2/3 will never be flown in the flight path of manned 

aircraft. With the first condition listed, always keeping a visual line of 

sight, being of utmost importance to providing a significant level of 

public safety.

In summary, I respectfully request exemption from regulations specified 

above, under Section 333 to enable Jacob Thomas to operate efficient, 

limited, and low-risk commercial UAS operations for the activities stated 

above, respecting at all times the space and privacy of citizens and property, 

while keeping airspace safe. Granting this request would be in good public 

interest by giving an opportunity for real estate photographers and sporting 

event photographers to offer safer, unique views, and more competitively 

priced aerial photography to the general public.

I am willing and able to modify or amend any part of this request to satisfy 

the need for an equivalent level of safety. I look forward to working with 

your office. Please feel free to contact us at any time if you require 

additional information or clarification.

Thank You for your consideration,

Jacob Thomas

681 Johnson Rd

Oliver Springs, TN 37840

thomasinspectionphotography@gmail.com

(865)399-3551