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u.s. Department ofTransportation, 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 apetitionpresented by Franklin Robbins, LDR Photography for exemption pursuantto Section 333; FAA Modernization and Reform Act of2012, Public Law 112·95 FEB. 14, 2012, Section 333. I requestthis exemption to operate our UAV/UAS, DJI Phantom 3Advanced and Pro Quadcopter Aircraft, in orderto 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 butnot limited to weddings, private orpublic parties/events, business advertising, promotional events, geological surveying, and environmental studies. Overthe past yearwe have been receiving a growing number ofrequests for drone photography or videography by local municipalities, businesses and individuals. By utilizing the UAV /UAS we can provide our clients with the point ofview they're looking for at a more reasonable price andin aosafermethod than helicopters or**larger_air~rafts.** 

### Thls UAS will be operated with extreme care and responsibility as we do with all ofoutproduction equipment. The Phantom 3Advanced 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. Inaddition to the built in safety features (outlined in the UserPDF document under page 40- 44 DJI Advanced User Manual ), apre.flight safety inspection will be performed before eachuse 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 orprivate propertywithoutthe owners' permission. The UAS will only be operated within visual line ofsight and will notbe flown within 5miles ofairports 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 ofmarks; general. 14 C.F.R. 61.101(e)(4), & (5); Recreational pilotprivileges 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 pilotprivileges 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 ofthe DJI Phantom 3 ("P3")

· Gross weight: P3==1280g

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

· Maximum Ascent Speed: P3==5m/sec

· MaximumDescent Speed: P3=3m/sec ·VerticalHover Accuracy:**P3=+/~10cm** ·HorizontalHover Accuracy:**P3==+/~lm**

### --~-- ..

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

· Battery: 5400mAh 3 S 11.1V LiPo

· FlightTime:**20~25** minutes --**------~** -- --------- -------- ------ -



### Thankyouvery muchfor your time 

### and consideration for this

### importantrequest. Please letme know ifthere is any additional informationrequired for approval.

*Enclosures: DJI_Safety

_Guidelines_Disclaimer_en.pdf