Scott Lawrence Photography, LLC

PO Box 404

Gurnee, IL

312.488.9787

scott@scottlawrencephoto.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave S.E.

Washington, D.C. 20590

Re: Request for Exemption under Section 333 of FAA Modernization and Reform Act of 2012

from 14 CFR §§ 21(h), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a),

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a)

and (b).

Dear Sir or Madam:

Through this filing, the petitioner, Scott Lawrence Photography, LLC, is seeking an Exemption

from Section 333 of the FAA Modernization and Reform Act of 2012 in order to commercially

operate Small Unmanned Aircraft Systems (sUAS).

As a licensed private pilot and professional photographer, the pilot in command (PIC), Scott

Lawrence, intends to use sUAS for aerial data collection – primarily photography and

videography of residential and commercial real estate. Other applications may include property

inspection, surveying, mapping and cinematography.

Scott Lawrence has held a private pilot license (certificate# 3504360) since 1999 and also holds

a valid Illinois Driver’s License.

The proposed operations will be conducted with a DJI Phantom 3 and DJI Inspire 1, both small

UAS that weigh less than 55 lbs.

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Publishable Summary

With this filing, the petitioner is seeking exemption from 14 CFR §§ 21(h), 61.23(a) and (c),

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(b) (c), 91.121, 91.151(a)(1),

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).

Through this filing, the petitioner, Scott Lawrence Photography, LLC, is seeking an Exemption

from Section 333 of the FAA Modernization and Reform Act of 2012 in order to commercially

operate Small Unmanned Aircraft Systems (sUAS).

As a licensed private pilot and professional photographer, the pilot in command (PIC), Scott

Lawrence, intends to use sUAS for aerial data collection – primarily photography and

videography of residential and commercial real estate. Other applications may include property

inspection, surveying, mapping and cinematography.

Scott Lawrence has held a private pilot license since 1999 and also holds a valid Illinois Driver’s

License.

The proposed operations will be conducted with a DJI Phantom 3 and DJI Inspire 1, both small

UAS that weigh less than 55 lbs.

Contact Information

Scott Lawrence

Scott Lawrence Photography, LLC

P. O. Box 404

Gurnee, IL 60031

312.488.9787

scott@scottlawrencephoto.com

Proposed Operations And Aircraft

The PIC has held a private pilot license since 1999 and has several years of experience building

and operating RC vehicles.

The requested exemption seeks operation of the DJI Phantom 3 and DJI Inspire 1, both small

UAS, weighing under 55 lbs, including batteries and payload.

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The DJI Phantom 3 specifications:

● Weight (battery & propellers included) 1280 g

● Max. Ascent Speed 5 m/s

● Max. Descent Speed 3 m/s

● Max. Speed 16 m/s

● Max. Flight Time 23 minutes

● Operating Temperature 0 degrees C to 40 degrees C

● GPS Mode GPS/GLONASS

● Remote Controller Frequency 2.400­2.483 GHz

The DJI Inspire 1 specifications:

● Weight (battery & propellers included) 2935 g

● Max. Ascent Speed 5 m/s

● Max. Descent Speed 4 m/s

● Max. Speed 22 m/s

● Max. Flight Time 18 minutes

● Operating Temperature ­10 degrees C to 40 degrees C

● GPS Mode GPS

● Remote Controller Frequency 5.725­5.825GHz, 2.400­2.483 GHz

The proposed sUAS will be operated below 400 feet AGL. Most flights will take place below 200

feet AGL. The aircraft will only be operated in Daytime VFR conditions: no less than 500 feet

below and no less than 2,000 feet horizontally from clouds or when visibility is at least 3 statute

miles.

Operations of the proposed sUAS will be conducted with a line of sight view to the PIC and

visual observer (VO).

Prior to each flight, the PIC will conduct a preflight inspection of the aircraft to ensure it is safe to

fly. In addition, checklists will be used for all phases of operation–from preflight to postflight

debrief.

Each aircraft will be properly maintained and updated based on any future safety bulletins. Any

maintenance, repairs or software updates will be recorded in a maintenance log. Should the

aircraft require significant maintenance or repair, a test flight will be conducted under extra

precaution with the PIC and VO keeping a distance of 500 feet from bystanders.

Should the aircraft lose communications with the transmitter or begin to operate erratically, flight

will be aborted as soon as possible using the aircraft’s built in Return­to­Home functionality.

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As a licensed private pilot, the PIC, Scott Lawrence, will maintain a current FAA medical

certificate and meet the required flight review standards.

Public Interest and Safety

The proposed operations offer an opportunity to showcase the petitioner’s community from a

unique perspective in a manner that does not risk a manned crew, heavy aircraft and fuel

necessary to capture similar images.

When operating in a building inspection capacity, the proposed operations eliminate a

significant fall risk for humans that would otherwise need to climb multiple stories via ladders.

Privacy

While the proposed operations are not expected to cause an invasion of privacy, should any

concerns arise during flight, the PIC will yield to those concerns and determine a different flight

route. Operations conducted on private property will be conducted with permission from the

property owner or authorized agent. In situations where neighboring properties are in close

proximity to the area of operation, PIC will make every effort to notify potentially impacted

neighbors. For flights occurring over public areas, there is no expectation of privacy.

Regulations from Which Exemption is Requested

With this filing, the petitioner is seeking exemption from 14 CFR §§ 61.23(a) and (c),

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c) (b), 91.121, 91.151(a)(1),

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).

In addition, based on the proposed aircraft size, weight, speed, and limited operating area, the

petitioner also seeks relief from 14 CFR part 21, certification procedures for products and parts,

Subpart H—Airworthiness Certificates.

Exhibit List

1. DJI Phantom 3 Manual

2. DJI Phantom 3 Quick Start Guide

3. Intelligent Flight Battery Safety Guidelines

4. Safety Guidelines Disclaimer

5. DJI Inspire 1 Manual

6. DJI Inspire 1 Quick Start Guide

7. DJI Inspire 1 Maintenance Manual

8. DJI Inspire 1 Safety Guidelines

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Thank you for your timely review of this filing. I look forward to operating the proposed aircraft in

a safe and legal capacity to further showcase my community.

Scott Lawrence

Scott Lawrence Photography, LLC

312.488.9787

scott@scottlawrencephoto.com

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