July 10, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

To whom it may concern,

Light Control is a full service lighting design firm with a focus on sustainable 

architectural and landscape lighting serving the Scottsdale area.

This document requests an exemption under Section 333 of the FAA 

Modernization and Reform Act of 2012 for Aviation Unmanned to perform aerial 

photography/videography by Light Control. The primary use of this Unmanned 

Aircraft System (UAS) is to obtain aerial photos, video and/or digital media to 

utilize for commercial purposes and services. Details of the UAS, the DJI 

Phantom 3, is referenced in this document.

The requested exemption would permit Light Control to pursue commercial 

interests and services in the following areas:

• Design

• Marketing

• Real Estate and Architecture

• Surveying and Mapping

• Photometric Light Analysis

• Review of Installation and Construction

• Educational Material

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com
A. Address and Contact Information: 

Kevin J. Flower

Principal

Light Control

15220 N 78th Way

Scottsdale, AZ 85260

Office: 480-621-5442

Mobile: 602-448-5007

kevin@lightcontrolaz.com

lightcontrolaz.com

Tyler T. Hollmann

Programmer/Sustainability Consultant

Light Control

15220 N 78th Way

Scottsdale, AZ 85260

Office: 480-621-5442

Mobile: 928-202-8539

tyler@lightcontrolaz.com

lightcontrolaz.com

B. Sections of 14 C.F.R from which Light Control seeks exemption: 

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates.

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

3. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks.

4. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard 

Requirements.

5. 14 CFR 91.119 Minimum Safe Altitudes.

6. 14 CFR 91.121 Altimeter Settings.

7. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions.

8. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive 

Maintenance, and Alterations.

9. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)

(1) Observer Medical. 

C. Public Interest Benefits: 

Light Control wishes to create a low-risk, managed, and efficient platform for 

acquiring photos, video and digital media for purposes stated above. The use of 

the UAS provides a platform that is unobtrusive, less energy intensive, and safer 

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com
to its surrounds. This would allow Light Control to educate the public, design 

industry, and construction industry into the benefits and uses of the UAS 

platform. This in turn will create an informed public institution.

D. Introduction to UAS 

UAS are a compact and efficient tool used in aerial photos, video, and digital 

media gathering due to more affordable equipment and personnel cost, reduced 

noise, and a much smaller environmental impact. 

Light Control is seeking exemption in order to operate the DJI Phantom 3 

(manufacturer technical specifications included below) UAS which includes built 

in GPS and image/ultrasound positioning systems as well as the following 

features: 

• Restricts the height above ground level (AGL) to a specified user-generated 

height. 

• Restricts the radius of flight from the ground station, takeoff location and base 

of aerial operations, to a user-generated radius. 

• Restricts operations within designated airspace with the support of a built-in 

no-fly zone feature.

• The DJI Phantom 3 also has an integrated failsafe function that is triggered in 

the event communications are lost between the UAS and the remote controller. 

In the unlikely event this occurs, the UAS will ascend to a defined altitude, 

return to its point of takeoff, and land safety. If communications are restored, 

the pilot in command (PIC) can regain control of flight and land manually. 

Aircraft Technical Specifications:

Weight (Battery & Propellers Included) 

1280 g 

Max. Ascent Speed 

5 m/s 

Max. Descent Speed 

3 m/s 

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com
Max. Speed 

16 m/s (ATTI mode, no wind)

Max. Flight Time 

Approximately 23 minutes 

Remote Controller Specifications:

Operating Frequency 

2.400 GHz-2.483 GHz 

Transmitter Power(EIRP) 

FCC: 20 dbm; CE:16 dbm 

E. Operation Guidelines 

1. Operations are limited to the DJI Phantom 3.

2. The UAS will weigh less than 55 pounds including payload.

3. The UAS will not exceed the speed of 87 knots (100 miles per hour).

4. The UAS will be operated at an altitude of no more than 400 feet AGL.

5. The UAS will be operated within visual line of sight (VLOS) of the PIC at all 

times.

6. All operations will utilize a visual observer (VO). The UAS must be 

operated within the visual line of sight (VLOS) of the PIC and VO at all 

times.

7. Operating documents and property use agreements/authorization will be 

available at the ground station.

8. Functional testing flights will be conducted by a PIC with a VO.

9. Light Control will maintain and inspect the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and 

determine the UAS is in safe flight condition.

11. The UAS will be operated in compliance with all manufacturer safety 

bulletins and boundaries.

12. The UAS will not be operated within 5 nautical miles of an airport 

reference point (ARP).

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com
13. The UAS will not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC. 

14. If the UAS loses communications or loses its GPS signal, the UAS will 

return to a pre-determined location within the private or controlled-access 

property. 

15. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies. 

16. All operations will be conducted over private, public, or controlled-access 

property with permission from the property owner/controller/public 

authority or authorized representative. Permission from property owner/

controller/public authority or authorized representative will be obtained for 

all flights to be conducted. 

We respectfully request exemption under Section 333 to permit Light Control to 

conduct efficient, limited, and low-risk commercial UAS operations for the 

activities stated herein while respecting at all times the space and privacy of 

citizens and property, and following the incurred FAA regulations.

Sincerely,

Kevin J. Flower

Principal

Tyler T. Hollmann

Programmer/Sustainability Consultant

Light Control 15220 N. 78th Way Scottsdale, Arizona 85260 T 602.448.5007 kevin@lightcontrolaz.com www.lightcontrolaz.com