January 21, 2016

Delahoyde Projects Incorporated

Steve Delahoyde / President & Owner

1011 Seward Street

Evanston, IL 60202

773-544-0461

sdelahoyde@gmail.com

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 21 subpart H 14 CFR 45.23(b); 14 CFR 

61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 

CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b) 14 CFR 91.405 

(a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b). 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

The objective of Delahoyde Projects Incorporated, and its owner, Steve Delahoyde, through 

requesting this exemption, is to provide an additional and safe production option for a variety of 

commercial, public, and residential uses, specifically with use of our Unmanned Aircraft System, 

the DJI Phantom 3 Professional (FAA Registration Number N203CZ). 

BACKGROUND 

For more than a decade and a half, Steve Delahoyde has worked in the film,video and media 

production industry, creating content for corporations, universities, ad agencies, individuals and 

media companies. In 2012, he created Delahoyde Projects Incorporated, a full-scale production 

company based in Illinois. Since then, Delahoyde Projects has worked on hundreds of 

productions in all variety of location and capacity, with a flawless safety record.

Delahoyde Projects Incorporated seeks an exemption to operate its DJI Phantom 3 

Professional, a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA), for compensation 

or hire within the United States.

BASIS FOR PETITION

The requested exemptions will allow Delahoyde Projects Incorporated to provide aerial video 

and photography for its clients, maintaining all safe operating parameters and regulations 

defined by the FAA and all other local and regional agencies.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 CFR Part 11, Delahoyde Projects Incorporated and the corporation’s owner, Steve 

Delahoyde, the operator of the Unmanned Aircraft Systems (UAS), hereby applies for an 
exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of 

designated UAS, with the understanding that such operations are to be conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by 

Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would, or have the ability to, provide professional services in the following areas:

1. Aerial video and photography for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news-gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

5. Training for persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the 

National Airspace System (NAS).

As described in total below, the requested exemption would permit the operation of designated

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase 

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to create requirements for the safe 

operation of such aircraft systems in the national airspace.

Delahoyde Projects Incorporated plans to operate the DJI Phantom 3 Professional, an 

unmanned aircraft (UA or Phantom 3 Professional), which it has fully registered with the FAA 

(N203CZ). The Phantom 3 Professional is referred to as a quad-copter with a maximum gross 

weight of approximately 3 pounds. It is equipped with four rotors that are driven by electric 

motors powered by a single battery. The unmanned aircraft has a maximum airspeed of 16 m/s 

and is controlled on ground by use of a remote control aided by GPS and other telemetry.

Given the small size of the UAS involved and the restricted, controlled environment within which

they operate, the applicant fits within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to 

commence immediately. In addition, due to the size of the UAS and the controlled areas in 

which the relevant UAS will operate, approval of the application presents no national security 

issue. 

Given the following, the grant of the requested exemptions is clearly in the public interest: 

Delahoyde Projects Incorporated proposes that the exemption requested herein apply to civil 

aircraft that have the characteristics and that operate with the limitations listed herein. These 
limitations provide for an exceptional level of safety to operations. These limitations and 

conditions to which Delahoyde Projects agrees to be bound when conducting commercial 

operations under an FAA issued exemption including:

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of the UAS operator.

3. Maximum total flight time for each operational flight will be 20 minutes.

4. Flights will be terminated at 15% battery power reserve.

4. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL)

5. UAS operator will follow all guidelines of proper safety and operations of the UAS.

6. The UAS will only operate within a controlled area as defined in the Procedures.

7. The operator will have been trained in operation of UAS generally and received up-‐to‐date 

information on the particular UAS to be operated as required.

8. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-‐determined location within the Security Perimeter and land.

9. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

The Reasons Why Granting Delahoyde Projects Request Would Be in The Public Interest; 

That Is, How It Would Benefit the Public As A Whole:

Granting the present petition will further the public interest by allowing Delahoyde Projects 

Incorporated to safely, efficiently, and economically perform aerial video and photography over 

certain areas of the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the 

National Airspace System (NAS), reduce pollution, and provide significant benefits to the U.S. 

economy. Notably, the benefits of Delahoyde Projects’ proposed operation of the DJI Phantom 3 

Professional UAS, will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion of the National Airspace System.

The DJI Phantom 3 Professional UAS is solely battery-powered and is a safe, efficient, and 

economical alternative to the manned aircraft traditionally used to obtain aerial video and 

photography. By reducing the amount of manned aircraft needed to perform aerial images, an 

exemption allowing the use of a DJI Phantom 3 Professional UAS by Delahoyde Projects would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 

Professional UAS do not require an airport for takeoffs or landings. Likewise, a reduction of 

manned aircraft conducting aerial video and photography missions would result in fewer aircraft 

that must be handled by air traffic control during the ground, takeoff, departure, arrival, and 

landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 

Professional UAS.

Conducting aerial images with the DJI Phantom 3 Professional UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using solely 

battery-powered electric motors, the DJI Phantom 3 Professional produces no air pollution, and 

is the most viable environmentally conscious alternative to the internal combustion engine 

aircraft that are typically utilized for aerial video and photography, while burning many gallons 

per hour of leaded and pollution-causing aviation fuel. The DJI Phantom 3 Professional UAS, 

while greatly reducing the carbon footprint of aerial videography and photography, also 

eliminates noise pollution, as UAS craft are propelled by battery-powered electric motors, rather 

than much larger, much louder internal combustion engines.

By using the DJI Phantom 3 Professional UAS to perform aerial videography and photography, 

the substantial risk to life and property in the air and on the ground, which is generally 

associated with traditional manned aircraft flight operations, will be greatly reduced or 

completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, 

the DJI Phantom 3 Professional UAS (weighing approximately 3 pounds at their maximum gross 

weight, with a very small size, and with no fuel on board), has significantly less physical 

potential for damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations.

3. Performing Aerial Video and Photography Operations with the DJI Phantom 3 

Professional UAS Will Benefit the Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UAS is an economical 

alternative to using manned aircraft to conduct similar aerial visual capture operations. Allowing 

United States-based companies, like Delahoyde Projects, to remain competitive and contribute 

to growth of the nation’s economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, 

United States-owned and operated companies are encouraged and find it necessary to adopt 

new and alternative technology in order to remain competitive. Operating the battery-powered 

DJI Phantom 3 Professional UAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without the 

traditionally-high operational cost of a manned aircraft.

By operating the DJI Phantom 3 Professional UAS, companies such as Delahoyde Projects 

Incorporated, can remain competitive and profitable, and therefore, provide greater job 

stability to its employees and contractors, which will contribute to growth of the United States’ 

economy. Improved financial performance of U.S.-based companies, through commercial use of 

the DJI Phantom 3 Professional UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive regionally, nationally, and abroad. 
4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

Delahoyde Projects’ proposed operation of the DJI Phantom 3 Professional UAS will not 

implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated 

only in compliance with operating documents, which requires property owner involvement as 

well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

Accordingly, Delahoyde Projects respectfully requests that the FAA grant the requested 

exemption and is prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. I look forward to working with your office. Please contact me at any 

time if additional information or clarifications are needed.

Thank you for your review of this material.

Sincerely,

Steve Delahoyde

Delahoyde Projects Incorporated

1011 Seward Street

Evanston, IL 60202

773-544-0461

sdelahoyde@gmail.com