Mark D. Hill

3637 24th Street

Sacramento, CA 95818

(916) 397-5438

mark_d_hill@sbcglobal.net

Attn: Document Management Facility

U.S. Department of Transportation, Docket Operations

West Building Ground Floor Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Application for Exemption

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 

C.F.R. Part 11, Mark D. Hill, a film, video & multimedia producer, hereby applies for an exemption from 

the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft 

System (UA) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long 

as such operations are conducted with and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333. 

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R . 91.103 (b) (2)

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) and 9b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) & (b)

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417

The requested exemption would permit Mark D. Hill to pursue his commercial interests in providing 

aerial videography and cinematography services to clients using a small advanced UA in the following 

areas: Real Estate, Agriculture, Marketing, Land Management/Surveying, and Special Events. Mark D. 

Hill states that all UA flights will occur over private or controlled access property and will do so with the 

property owner's consent and knowledge and that only people who have consented or otherwise have 

agreed to be within the UA’s radius during filming and photography applications.
Public Benefit 

With safety being our primary goal, this operation is a safer alternate to operating a larger petroleum 

powered aircraft requiring airborne crew members. UAs are often seen as superior to helicopters as an 

aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced 

noise and as such, a much smaller environmental impact which promotes public safety. 

Safety

Mark D. Hill has demonstrated the ability to safely and effectively fly the UA DJI Phantom 3 which will 

be used for all commercial and private purposes. Mark D. Hill will comply with local ordinances and 

laws regarding the operation of UA, and will adhere to all weather and environmental restrictions or 

limitations in reference to the operations of UA. All flights will occur in accordance with any state or 

local laws regarding privacy.

The DJI Phantom 3 has a built-in stabilized HD camera and GPS safety features which limits the height it 

flies above ground level (AGL), and limits the radius of the distance it flies from the operator. The DJI 

Phantom 3 also has a failsafe function that is triggered in the event communication is lost between the UA 

and the main controller transmitter. At that time, the UA will return to its point of takeoff and land safely. 

If the connection is restored, the PIC can regain control of flight and land manually. 

These specifications meet with the Model Aircraft Operating Standards as set below: 

 The petitioner will only operate its UA in line-of-sight of a PIC at all times and will operate at sites that 

are sufficient distance from populated areas.

 When flying the UA within three (3) miles of an airport, airport operators will be notified and the 

operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. Maximum flight 

time for each operation will be 30 minutes. 

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to 

safely land the UA. 

 The UA will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not 

more than 200 feet above an elevated platform from which videography is planned. 

 The UA operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, 

and stabilized gimbal). 

 The UA will operate at speeds of no more than 50 knots, can hover, and can simultaneously move 

vertically and horizontally. 

 Given the small size of the UA and the restricted sterile environment within which it will operate, our 

operations adhere to the Reform Act's safety requirements.
Specific Exemptions Requested

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

Because of the size of the DJI Phantom 3, there is not enough space to place all of the necessary 

information on the aircraft and exemption is requested from these requirements. We will make the UA in 

the largest possible lettering by placing the words “Hill Winery Marketing” on its fuselage as large as 

practicable so that the PIC and others assisting will easily see the markings. 

14 C.F.R. 61.113(a) & (b) 

We will not be carrying any passengers or property for compensation or hire.

14 C.F.R. 91.103 (b) (2)

The DJI Phantom 3 does not use any runway for take off. We will ensure it will remain clear of all 

ramps, taxiways and runways associated with any airport.

14 C.F.R. 91.7(a) 

An exemption is requested because the UA does not have to receive an airworthy condition by the FAA.

14 C.F.R. 91.9(b) and (b) (2) 

There is no FAA approved manual for the DJI Phantom 3. We are submitting the user manual that we 

feel will suffice.

14 C.F.R. 91.109 

The DJI Phantom 3 does not have dual flight controls and all instruction is via the one controller. An 

exemption is requested from this requirement.

14 C.F.R. 91.119 

We will not operate the DJI Phantom 3 near any power lines, light posts or any other powered obstacle or 

any congested areas. Because of the small size of the DJI Phantom 3 and the fact that there is no fuel on 

board, we feel there is little risk to flying less than 500 feet in other than congested areas to persons or 

property on the surface. We will ensure we have permission for the owner of the owner of any vehicle or 

property prior to getting with the 500 feet area. We will not violate any privacy laws. We will abort the 

flight in the event of unpredicted obstacles or emergencies. 

14 C.F.R. 91.121
The DJI Phantom 3 uses GPS signals to compute altitude so we will automatically be able to know the 

altitude above the ground at all times.

14 C.F.R. 91.151(a) & (b)

The DJI Phantom 3 uses battery power. Flights will be terminated when battery levels reach 25%, 

allowing sufficient reserve flight time to safely land the sUAS. 

14 C.F.R. 91.203(a) & (b) 

There is no cabin or cockpit entrance so this requirement does not apply. There is no requirement for an 

airworthiness certificate for the DJI Phantom 3. 

14 C.F.R. 91.205(b) 

There is no requirement for an airworthiness certificate for the DJI Phantom 3. 

14 C.F.R. 91.215 

The DJI Phantom 3 is not transponder equipped and exemption is requested. 

14 C.F.R. 91.401 - 91.417

There is no approved maintenance program for the DJI Phantom 3 but we will ensure that the UA is 

regularly maintained so to be in good operating order. Prior to each flight, the PIC will conduct a preflight inspection and determine the UA is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UA, the aircraft will not be operated until the necessary 

maintenance has been performed and the UA is found to be in a condition for safe flight. We will also 

ensure that any UA that has undergone maintenance or alterations that affect the UA operation or flight 

characteristics, (e.g., replacement of a flight critical component) will undergo a functional test flight prior 

to conducting further operations under this exemption. Functional test flights will be conducted by a PIC 

and at least 500 feet from other people. The functional test flight will be conducted in such a manner so as 

to not pose an undue hazard to persons and property. We will maintain an aircraft logbook that will 

reflect all flight time on the UA and any maintenance performed on the UA. 

Summary 

Mark D. Hill, a film, video & multimedia producer, hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System 

(UA) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such 

operations are conducted with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. I am committed to complying with all of the rules, guidelines, 

limitations, and future legislation set forth by the FAA. I agree to operate the UA in the manner that I 

have described, and for the purposes that I have described. Without the exemption request granted, I 

would be unable to safely and effectively run my business.