February	26,	2016

U.S.	Department	of	Transportation

Federal	Aviation	Administration

800	Independence	Avenue,	SW

Washington,	DC	20591

SPECIFIC	EXEMPTIONS	REQUESTED

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

Aviation	Regulations	from:	14	CFR	21	subpart HD14	CFR 45.23(b)D14 CFR 61.113(a) and

(b) 14	CFR 91.7(a)D14 CFR	91.9(b)(2)D14 CFR 91.103D14 CFR 91.109D14	CFR

91.119(c)D14 CFR 91.121D14 CFR 91.151(a)D14 CFR	91.203	(a) and	(b) 14	CFR 91.405	

(a)D14 CFR	91.407 (a) (1)D14	CFR 91.409	(a)(1) and	(2) 14	CFR 91.417(a)	and (b)

Commercial	operation	of	an	UAS,	as	described	here,	which	are equipped	with a camera

and devices (GPS,	antenna, programmers) that	would	provide	professional	services	in	the	

following	areas:

1. Aerial	photography	and/or	video	production	for	public	and/or private	use	

including	real	estate,	commercial,	surveying,	architecture and	other	related	

professional	activities.

2. Aerial	video	and/or	photography	for	public	and/or	private	use including	

television,	public	events	and	cinematography.

3. Aerial	inspection/photography	of	residential/commercial	structures under	

contract	with	the	owners	or	local	businesses.

EQUIPMENT

I plan	to	operate	a UAS,	the	DJI	Phantom	3	Advanced.	The	Phantom	3	Advanced is referred	

to	as	a quad-copter	with	an	approximate	weight	of	about	3 pounds.	It	is	equipped	with	

four brushless	motors	that are driven by electric	motors	powered	by	batteries.	The UAS	

has	a maximum airspeed	of	15 m/s	and	has	built	in	geo-fencing – which	is	programed to	

avoid	zones	(airports,	hotels,	stadiums etc.). In	addition	is programmed	with	established	

flight limits	(under 400ft	altitude).

Also,	given	the size	of	the	UAS’s	involved	and	the	restricted controlled	environment	within	

which	they	will	operate,	the	applicant fits	within	that	zone	of	safety	(an	equivalent	level	of	

safety)	in	which Congress	envisioned	that	the	FAA must,	by	exemption,	allow commercial	

operations	of	UASs	to	commence	immediately.	Also	due to	the	size	of	the	UASs	and	the	

controlled	areas	in	which	the	relevant UASs	will	operate,	approval	of	the	application	

presents	no	national security	issue.	Given	the	following,	the	grant	of	the	requested

exemptions	is clearly	in	the	public	interest
OPERATING	PARAMETERS

1. The UAS will weigh less than 55 lbs.

2. Flights	will	be	operated	within	line	of	sight	of	operator.

3. Maximum	total	flight	time	for	each	operational	flight	will	be	25 minutes.

4. Flights	will	be	terminated	at	15%	battery	power	reserve.

5. Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet

6. UAS	operator	will	be	trained	in	the	proper	safety	and	operations	of the	UAS.

7. The	UAS	will	only	operate	within	a controlled	area	as	defined	in	the Procedures.

8. The	operator	will	post	advisor	notice	around	the	controlled	area.

9. The	operator	will	have	been	trained	in	operation	of	UAS	generally and	received	upto-date	information	on	the	particular	UAS	to	be operated as	required.

10. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS will	have	capability	

to	return	to	a pre-determined	location	within	the Security	Perimeter	and	land.	

Which	in	this	event	the	first	procedure will	be	to	engaged	course	lock	(return	to	

‘home-point’	within	a 60ft radius)	then	after,	proceed	with	home	lock	(return	above	

takeoff point).	In	the	event	that	the above	procedures	fail – the	operator	will activate	

the ‘fail	safe’ option,	in	which	will	land	the	UAS	to	the	ground near the takeoff point.

11. The	UAS	will	have	the	capability	to	abort	a flight	in	case	of unpredicted	obstacles	or	

emergencies.

SAFETY

These	new	unmanned	aircraft	(UAS)	have	several	added	safety mechanisms	

including	but	not	limited	to:

 Ground looking	cameras for	more	stability in flight.

 More accurate GPS systems for greater reliability.

 More reliable lifting motors to	run the thrust propulsion

systems.

 More	reliable	computer based Engine Control Units.

 Higher resolution	video feeds to ground for greater situational

awareness.

 More	flight data sent to the ground controls for	grater

situational awareness.
 More	reliable	fail safe features for	greater	safety on the	ground.

PUBLIC	INTEREST

Aerial	photography and	videography	are	proven	strategies	to	enhance	marketing	efforts	and	

increase	business	success.	However,	until	recently	it	was	conducted	through	the	use	of	costly	

manned	aircraft,	a	prohibitive	business	activity	for	small	companies.	By	granting	this	exemption	

I	would	be	able	to	provide	affordable	services.	Further,	the	small	UAS	will	pose	no	threat	to	the	

public	given	its	small	size	and	lack	of	combustible	fuel	when	compared	to	larger manned	

aircraft.	Additionally,	the	operation	of	our	UAS	will	minimize	harm	to	the	environment.	Public	

and	private	events	serviced	by	our	business	enhance	vibrancy	and	add	culture	to	the	

community	and	its	citizens.

SUMMARY

Therefore, the	applicant respectfully	requests	that	the	FAA	grant	the requested	

exemption	and	are	prepared	to	modify	or	amend	any	part of	this	request	to	satisfy	the	

need	for	an	equivalent	level	of	safety.	I thank	you	for	your	time	and	look	forward	to	

working	with the	FAA	to become	more	knowledgeable	and	certified	in	flying	UAS’

Please	contact	me	through	my	email david@gpsstudios.com if any	additional	information	

is	needed.

Respectfully,

David	Arnold,	Owner

GPS	Studios,	LLC.

P.O.	Box	2362

LaGrange,	GA	30240

(706)	594-1005