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u.s. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12·140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Application I Petition for Section 333 Exemption 

Franklin L Robbins 

19 Dundee Road 

Gorham, Maine 04038 

207-318-2614 

The following is a petition presented by Franklin Robbins, LDR Photography for exemption 

pursuant to Section 333; FAA Modernization and Reform Act of2012, Public Law 112·95 FEB. 

14, 2012, Section 333. 

I request this exemption to operate our UAV/UAS, DJI Phantom 3 Advanced and Pro 

Quadcopter Aircraft, in order to provide services for profit to include aerial photography, aerial 

cinematography, aerial filming and photography for real estate, construction firms, agricultural 

modeling, crop monitoring operations, aerial mapping, special events to include but not limited 

to weddings, private or public parties/events, business advertising, promotional events, 

geological surveying, and environmental studies. 

Over the past year we have been receiving a growing number of requests for drone photography 

or videography by local municipalities, businesses and individuals. By utilizing the UA V /UAS 

we can provide our clients with the point of view they're looking for at a more reasonable price 

andin aosafer method than helicopters or larger_air~rafts. Thls UAS will be operated with 

extreme care and responsibility as we do with all of out production equipment. 

The Phantom 3 Advanced and Pro Includes many built in safety functions and notifications to 

ensure safety before and during operation. For example, this UAS will not operate in designated 

no fly zones or in poor weather conditions. In addition to the built in safety features (outlined in 

the User PDF document under page 40- 44 DJI Advanced User Manual ), a pre. flight safety 

inspection will be performed before each use and I will follow all UAS safety guidelines outlined 

by Congress (outlined in the Safety Guidelines and Disclaimer). 

Any and all repairs will be performed only by the manufacturer's authorized repair 

facilities/providers. Flights will not take place over densely populated areas or private property 
without the owners' permission. The UAS will only be operated within visual line of sight and 

will not be flown within 5 miles of airports or above 400 feet. 

Franklin L Robbins provides his clients with expertise and knowledge in 

advanced photography and video solutions to increase efficiency, 

productivity and effectiveness. He has over 30 years and the 20,000 hours 

in Private and Commercial aviation experience in single and multi engine 

Airplanes. He holds an F M Airline Transport Pilot certificate, Commercial 

Pilot; Instrument Rating, Certificate Number: 3061348. 

14 C.F.R. Part 21; CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS 

14 C.F.R. 45.23(b); Display of marks; general. 

14 C.F.R. 61.101(e)(4), & (5); Recreational pilot privileges and limitations. 

14 C.F.R. 61.113(a) & (b); Private pilot privileges and limitations: Pilot in command. 

14 C.F.R. 61.133 (a); Commercial pilot privileges and limitations. 

14 C.F.R. 61.23(a) & (c); Medical certificates: Requirement and duration. 

14 C.F.R 91.7(a); Civil aircraft airworthiness. 

14 C.P.R. 91.9(b)(2); Civil aircraft flight manual, marking, and placard requirements. 

14 C.F.R. 91.109(a); Flight instruction; Simulated instrument flight and certain flight tests. 

14 C.F.R. 91.103; Preflight action. 

14 C.P.R. 91.119; Minimum safe altiru~es:,G~n~~at_ 

14 C.F.R. 91.121; Altimeter settings. 

14 C.F.R. 91.15l(a); Fuel requirements for flight in VFR conditions. 

14 C.F.R. 91.203(a) & (b); Civil aircraft: Certifications required. 

14 C.P.R. 91.405(a); Maintenance required. 

14 C.P.R. 91.407(a)(l); Operation after maintenance, preventive maintenance, tebuilding, or 

alteration. 

14 C.P.R. 91.409(a)(2); Inspections. 

14 C.F.R. 91.417(a) & (b). Maintenance records. 
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Specifications of the DJI Phantom 3 ("P3") 

· Gross weight: P3==1280g 

· Diagon&l Size (including propellers): P3==590mm 

· Maximum Ascent Speed: P3==5m/sec 

· Maximum Descent Speed: P3=3m/sec 

·Vertical Hover Accuracy: P3=+/~10cm 

·Horizontal Hover Accuracy: P3==+/~lm 

--~-- .. ~-~Maximum Speed:.P3==-16misec 

· Battery: 5400mAh 3 S 11.1 V LiPo 

· Flight Time: 20~25 minutes 

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Thank you very much for your time and consideration for this important request. Please let me 

know if there is any additional information required for approval. 

*Enclosures: DJI_Safety _ Guidelines_Disclaimer _en.pdf