US	Department	of	Transportation

Federal	Aviation	Administration

800	Independence	Ave	S.W.

Washington	DC,	20591

02.05.16

To	Whom	It	May	Concern:

I,	Stefan	Gill,	have	been	flying	UA's	since	2015,	my	most	recent	experience	is	with	the	DJI	Phantom	3.	I	

have	been	flying	as	a	Hobbyist	and	now	ready	to	bring	my	skills	to	a	professional	level	for	two	reasons;	

Cinematography	for	Special	Events	and	Real	Estate/Architecture.	In	doing	so	I	consider	all	safety	

precautions	and	regulations	as	foremost	with	each	flight.	

I	seek	exception	from	14	C.F.R.	21,	subpart	H;	14	C.F.R.	45.23(b);	14	C.F.R.	§§	61.113	(a)	&	(b);	14	C.F.R.	§	

91.7	(a);	14	C.F.R.	§	91.9	(b)(2);	14	C.F.R.	§	91.103(b);	14	C.F.R.	§	91.109;	14	C.F.R.	§	91.119;	14	C.F.R.	§	

91.121;	14	C.F.R.	§	91.151(a);	14	C.F.R.	§§	91.203(a)	and	(b);	14	C.F.R.	§	91.405	(a);	14	C.F.R.	§	91.407	

(a)(1);	14	C.F.R.	§	91.409	(a)(2);	14	C.F.R.	§	91.409	(a	)	(2);	and,	14	C.F.R.	§§	91.417	(a)	&	(b)	to	

commercially	operate.	

Special	Event	Cinematography

Recording	Special	Events	would	be	taken	care	of	delicately	with	my	UA.	Firstly	I,	Stefan	Gill,	would	

observe	the	flight	area	for	any	mobile	phone	base	stations,	radio	transmission	towers,	power	lines	or	

any	other	electromagnetic	interference	that	could	disrupt	flight.	 I	would	scan	the	area	for	any	large	

buildings	or	trees	that	may	affect	with	GPS	accuracy	or	flight.	Lastly,	I	would	make	sure	the	weather	is	

flight	ready	to	avoid	wind	speed	exceeding	10m/s	,	snow,	rain	and	smog	also	to	be	sure	the	UA	and	

battery	performance	is	subject	to	safe	air	density	and	temperature. 	Second	go	through	the	PRE	FLIGHT	

CHECKLIST/maintenance	and	FLIGHT	TEST	PROCEDURES	as	normal	in	a	secure	area	safe	from	persons	

and	property.	Thirdly	capturing	film	from	a	safe	distance	from	persons	and	property	avoiding	all	crowds	

and	hazards.	

Capturing	those	perfect	moments	during	a	special	event	is	important.	Capturing	it	with	aerial	

cinematography	will	help	give	the	host	a	professional	recording	to	relive	their	special	moments	without	

the	dangers	and	expenses	of	a	manned	fixed	wing	aircraft	or	helicopter.	

I,	Stefan	Gill,	consider safety	and	regulations	as	foremost	with	each	flight.	My	small	unmanned	aircraft	is	

designed	to	hover	in	place	via	GPS	and	operate	in	less	than	a	24	knot	(15	mph)	wind.	For	safety,	stability	

and	fear	of	financial	loss	I	will	not	fly	in	winds	exceeding	16	kph	(10	mph)	nor	will	I	fly	my	UA	faster	than	

30	mph	nor	exceed	the	400	foot	limit.	Built	in	safety	systems	include	a	GPS	mode	that	allows	my	UAS	to	

hover	in	place	when	radio	controls	are	released.		In	addition,	if	signal	with	the	controller	is	lost	the	UAS	

will	climb	to	a	preset	height	and	Return	to	Home	(RTH). With	three	modes	to	choose	from,	I	utilize	the	

Smart	Mode	for	aerial	videography/photography.	This	is	the	safest,	most	reliable	and	stable	mode	to	

prevent	accident	and	hazard.	When	pilot	communication	is	lost	the	UAS	is	designed	to	slowly	descend	to	

point	of	take-off.	I	do	not	operate	my	UAS	near	airports,	Hospitals	nor	Police	heliports,	I	am	also	

prepared	to	land/abort	immediately	to	the	nearest	and	safest	ground	point	that	I	have	planned	ahead	of	

take-off.	
Next	I	would	then	coordinate	a	safe	fly	time	where	all	Persons	and	property	are	in	safe	distance	from	my	

UA	during	take-off	and	flight.	Lastly	I	would	go	through	my	normal	maintenance	and	pre-flight	Checklist;	

1.	Remote	controller,	aircraft	battery,	and	mobile	device	are	fully	charged.	

2.	Propellers	are	mounted	correctly	and	firmly.	

3.	Micro-SD	card	has	been	inserted	if	necessary.	

4.	Gimbal	is	functioning	as	normal.	

5.	Motors	can	start	and	are	functioning	as	normal.	

6.	DJI	Pilot	app	connected	to	the	aircraft.	

Then	following	up	with	flight	test	procedures;	

1.	Place	the	aircraft	on	open,	flat	ground	with	battery	indicators	facing	towards	me.	

2.	Power	on	the	remote	controller	and	your	mobile	device,	then	the	Intelligent	Flight	Battery.	

3.	Launch	the	DJI	Pilot	App	and	enter	the	Camera	page.	

4.	Wait	until	the	Aircraft	Indicator	blinks	green.	This	means	the	Home	Point	is	recorded	via	GPS	

5.	Calibrate	the	compass	flight	location.	

6.	Push	the	throttle	up	slowly	to	take	off	

7.	Shoot	photos	and	videos	using	the	DJI	Pilot	app.	

8.	To	land,	hover	over	a	level	surface	and	gently	pull	down	on	the	throttle	slowly	to	descend.	

9.	After	landing,	execute	the	CSC	command	or	hold	the	throttle	at	its	lowest	position	for	3	seconds	or	

more	until	the	motors	stop.	

10.	Turn	off	the	Intelligent	Flight	Battery	first,	followed	by	the	Remote	Controller.	

Real	Estate/Architecture

Arial	cinematography	in	the	housing	market	has	been	around	for	a	long	time	through	manned	fixed	wing	

aircraft	and	helicopters.	For	small	budget	real	estate	companies	and	average	homeowners	the	expense	

of	such	aerial	videography	is	cost	prohibitive.	Only	large	companies	and	high	end	Realtors	or	luxury	

homeowners	can	afford	to	absorb	such	expense.	Depriving	non-luxury	homeowners	and	lower	budget	

Realtors	from	a	valuable	marketing	tool.	Also	using	my	UA	avoids	the	high	risks	in	a	helicopter	with	fuel	

and	persons	on	board.

To	make	sure	the	operation	will	be	safely	conducted	Firstly	I,	Stefan	Gill,	would	observe	the	flight	area	

for	any	mobile	phone	base	stations,	radio	transmission	towers,	power	lines	or	any	other	

electromagnetic	interference	that	could	disrupt	flight.	I	would	scan	the	area	for	any	large	buildings	or	

trees	that	may	affect	with	GPS	accuracy	or	flight.	I'd	make	sure	the	weather	is	flight	ready	to	avoid	wind	

speed	exceeding	10m/s	,	snow,	rain	and	smog	also	to	be	sure	the	UA	and	battery	performance	is	subject	

to	safe	air	density	and	temperature.	Second	go	through	the	PRE	FLIGHT	CHECKLIST/maintenance	and	

FLIGHT	TEST	PROCEDURES	in	a	secure	area	safe	from	persons	and	property.	Thirdly	capturing	film	from	

safe	distance	from	persons	and	property	avoiding	all	hazards.	

DJI	Phantom	3	Specs

Diagonal	Size:	590mm	(including	propellers)
Weight:	1280	g	(battery	included)

Max	Ascent	Speed:	5m/s

Max	Descent	Speed:	3m/s

Max	Speed	16m/s

Operating	Frequency:	2.400GHz	–	2.483GHz

Compliance:	This	device	complies	with	part	15	of	the	FCC	Rules	as	stated	on	page	56	of	the	DJI	Phantom	

3	flight	manual.	

Design	and	Operational	Characteristics	of	the	Phantom	3

Three	positioning	modes;

1.	GPS	and	vision	positioning	and	uses	GPS/GLONASS	for	positioning.

2.	Vision	positioning	is	available	but	GPS	is	not	

3.	Neither	GPS	nor	vision	positing	is	working	and	it’s	only	using	its	barometer	for	positing	return	to	home

are	where	you	last	record	point	of	take-off.	

There	are	three	(3)	cases	that	will	trigger	Return	To	Home	(RTH)	procedure;	they	are	Smart	RTH,	Low	

Battery	RTH	and	Failsafe	RTH.	 Press	and	hold	the	button	to	start	the	RTH	procedure.	Then	the	LED	

around	the	RTH	Button	will	blink	white	to	indicate	the	aircraft	is	entering	RTH	mode.	The	aircraft	will	

then	return	to	the	last	recorded	Home	Point.		To	cancel	it,	Press	this	button	again	and	you	will	regain	the	

control	of	the	aircraft.	

1.	Smart	RTH_You	may	control	the	aircraft's	orientation	to	avoid	collision	during	the	Smart	RTH.	Press	

the	Smart	RTH	button	once	to	start	the	process,	press	the	Smart	RTH	button	again	to	exit	Smart	RTH	and	

regain	the	control.	

2.	Low	Battery	RTH_The	low	battery	level	failsafe	is	triggered	when	the	DJI	Intelligent	Flight	Battery	is	

depleted	to	a	point	that	may	affect	the	safe	return	of	the	aircraft.	Users	are	advised	to	return	home	or	

land	the	aircraft	immediately	when	these	warnings	are	shown.	DJI	Pilot	app	will	advise	user	to	return	the	

aircraft	to	the	Home	Point	when	low	battery	warning	is	triggered.	Aircraft	will	automatically	return	to	

the	Home	Point	if	no	action	is	taken	after	10	seconds	countdown.	User	can	cancel	the	RTH	by	pressing	

once	on	the	RTH	button.	The	thresholds	for	these	warnings	are	automatically	determined	based	on	the	

current	aircraft	altitude	and	its	distance	from	the	Home	Point.	Aircraft	will	land	automatically	if	the	

current	battery	level	can	only	support	the	aircraft	to	land	to	the	ground	from	the	current	altitude.	User	

can	use	the	remote	controller	to	control	the	aircraft’s	orientation	during	the	landing	process.	The	

Battery	Level	Indicator	is	displayed	in	the	DJI	Pilot	app,	and	is	described	below	

3.	Failsafe	RTH_Is	activated	automatically	if	remote	controller	signal	(including	video	relay	signal)	is	lost	

for	more	than	3	seconds	provided	that	Home	Point	has	been	successfully	recorded	and	compass	is	

working	normally.	Return	home	process	may	be	interrupted	and	the	operator	can	regain	control	over	

the	aircraft	if	a	remote	controller	signal	is	resumed.	

Max	Height	&	Radius	Limit	Flying	Height	and	Distance

The	user	may	change	these	settings	in	the	DJI	Pilot	App.	Once	complete,	the	Phantom	3	will	fly	in	a	

restricted	cylinder	that	is	determined	by	these	settings.	The	tables	on	page	40	in	the	flite	manual	

attachment	show	the	details	of	these	limits.	
On	the	DJI	Phantom	3	as	a	default	a	“warning	zone”	has	been	set	around	safety	zones.	When	you	fly	

within	320	feet	of	the	5	mile	radius	of	the	restricted	flying	zone	a	warning	message	will	appear	on	the	

DJI	Pilot	App.	and	there	is	a	graph	to	show	in	detail	on	page	42	of	DJI	Phantom	3	flight	manual	

attachment.	That	includes	for	category	A	areas	and	category	B	areas,	big	and	small	airports.	

Respectfully	Submitted,	

Stefan	Gill

Diamond	Video

27	Family	Lane

Levittown	NY	11756

(631)	428	7246

stefan@whitediamondvideo.com