This is an exemption request pursuant to Section 333 of the FAA Reform Act of 2012 for Deschutes

Aerial Photography. Deschutes Aerial Photography requests to perform

aerial photography through the use of its small unmanned aircraft commercially in airspace regulated by

the FAA. The owner and pilot is an FAA licensed Private Pilot and A&P with an A.A.S. in Aviation

Technology.

Having firsthand knowledge of the National Airspace System gives Deschutes Aerial

Photography an advantage in safely operating small UAS within our airspace.

Description of Petitioner

Steve Brock is the owner of Deschutes Aerial Photography. Steve is a Private Pilot SEL

and has vast experience operating in the National Airspace System. He has experience

flying RC Planes and small quad copters for pleasure.

Contact information:

Steve Brock

396 NW Mc Donald Rd

Prineville, OR 97754

Mailing Address:

Steve Brock

PO Box 1129

Redmond, OR 97756

sb79t@yahoo.com

907-304-2716

Exemptions

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103
14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Description of UAS and Equivalent Level of Safety

The primary UAS system that will be used is the DJI Phantom 3. The UAS will be safely operated in the

NAS by maintaining line of sight visual contact, flown only during daylight, and less than 400ft above the

ground. Flights will be operated at a lateral distance of no less than 100 feet from any persons or

property not associated with the operation. Additional safety features on the DJI Phantom 3 include

return to home functionality when GPS is available and failsafe technology that return the aircraft to the

takeoff point if batteries run low. 

The specifications for the UAS are as follows:

Weight: 1280 g

Diagonal Size: 590 mm 

Max Ascent Speed: 5 m/s

Max Descent Speed: 5 m/s

Max Speed: 16 m/s

Additionally, the max flight time for the UAS will be limited to maintain a reserve of 25% battery power.

At all times, the UAS will be operated in accordance with the safety and operational requirements of the

manual.

UAS Operations

Preflight would include checking the operation of the UAS to include the battery in both the transmitter

and the UAS, the condition of the body of the UAS and its propellers. Updates to the firmware will be

done as they become available and maintenance will be performed pursuant to the manufacturers
recommendations. The area in which the drone will be flown will be checked for powerlines, antennas,

and other obstructions. The weather conditions will be monitored throughout the flight. Wind 

conditions will be reviewed and the UAS will only be flown in daylight. As the pilot, Steve would ensure 

that he is safe to operate the drone as he would if he were flying in the aircraft himself. 

The pilot will abide by the following currency and proficiency requirements:

The pilot will possess at least a private pilot certificate

The pilot will have a minimum of 25 hours total time as a UAS rotorcraft pilot

The pilot will have a minimum of 5 hours in the make and model utilized

The pilot will have a current FAA medical certificate

A trained Observer will be used at all times during commercial operations

Conclusion:

Deschutes Aerial Photography, a small business, would like to safely operate a

UAS aerial photography business. Having a Section 333 Exemption and entering into the NAS legally

would give the business a competitive advantage. The safe and compliant operations would discourage

illegal operations and improve the industry.

Thank you for your consideration.

Sincerely,

Steve Brock

Owner/Pilot 

Deschutes Aerial Photography