October 28, 2015

To: US Department of Transportation

 Docket Management System

 1200 New Jersey Ave, SE 

 Washington, DC 20590

 (Submitted electronically to the Federal 

 Docket Management System-FDMS)

From: Kevin R. Bass, Owner

Millenium A/ V Productions

518 Keeneland Ave

Woodstock, GA 30189

Re: Request for Exemption under section 333 of the FAA Reform Act

Summary of Exemption Request 

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

Administration’s general exemption authority under Title 49, United States Code, Section 44701(f), 

Millenium A/V Productions, LLC. (“MAVP”) hereby petitions for exemptions from the following Federal 

Aviation Regulations specified in Title 14 of the Code of Federal Regulations:

14 CFR Part 21, Subpart H 

14 CFR 45.23(a) 

14 CFR 61.113(a)(b) 

14 CFR 61.133(a) 

14 CFR 91.7(a) 

14 CFR 91.109(a) 

14 CFR 91.119(c) 

14 CFR 91.9(b)(2) 

14 CFR 91.121 

14 CFR 91.151(a)(1) 

14 CFR 91.203(a)(b) 

14 CFR 91.319(a)(1) 

14 CFR 91.405(a) 

14 CFR 91.407(a)(1) 

14 CFR 91.409(a)(1)(2) 

14 CFR 91.417(a)(b)

These proposed exemptions, if granted, will allow MAVP to operate their DJI Phantom 3 Advanced 

Quadcopter with 1080p Camera and 3-Axis Gimbal and will benefit the following commercial 

applications: 
Wedding video and photography 

Sports video and photography

Disaster Response, including Emergency Search & Rescue 

Security Awareness

The DJI Phantom 3 uses an onboard camera to capture high definition imagery and video. 

MAVP’s use of the DJI Phantom 3 will grant corporations, emergency response teams, and others an 

overall greater awareness, heightened security, safety, as well as negate the need for conventional 

aircraft assistance. This results in enhanced efficiency for any activity conducted.

Operation under the anticipated exemption will be subject to strict conditions and requirements, 

ensuring at minimum, an equivalent level of safety to currently authorized operating standards and 

procedures per FAA Regulations.

The DJI Phantom is a quad-rotor design, based around a custom fabricated carbon fiber chassis. Four 

counter-rotating electric motors provide exceptional predictability, endurance, stability, and control.

Because of the complexity associated with multi-rotor aircraft the Phantom 3 relies on a GPS-based 

navigation system to maintain flight stability and provide other features. While fully manual operation is 

possible, most users, especially videographers hoping to get the smoothest possible shoots, will opt for 

one of the GPS-assisted modes 

If the Quadcopter loses the signal from the controller for any reason or the battery starts to run low the 

"return to home" feature will initialize. The aircraft will ascend to 60 feet then make a straight-line 

course back to the "home position" you will have defined during the GPS calibration process. Once 

there, it will safely descend to the ground and power itself off.

Summary

MAVP believes that approval from the FAA will enhance efficiency and safety in any operation its DJI 

Phantom 3 conducts, due to reducing the need for manned aircraft. Due to its camera-only payload 

capability, lack of cargo, fuel or combustible materials in general, aircraft size, weight, and limited 

operating area, the DJI Phantom 3 presents no major risk to individuals, nor poses any threat to National 

Security. While adhering to at least an equivalent level of safety of all current regulations, MAVP firmly 

believes exemptions to the listed regulations should be granted, and operation of its DJI Phantom 3 

commercially should be permitted.