T o u r d e p o t. u s Photography and Video Production

boris_levitsky@sbcglobal.net (650)278-4048 1

January 07, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D. C. 20590

Applicant:

Boris Levitsky

Owner

Tourdepot.us 

Photography and Video Production

6135 Shelter Creek Lane

San Bruno, CA 94066

boris_levitsky@sbcglobal.net

(650)278-4048

www.tourdepot.us

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Boris Levitsky operator of an 

Unmanned Aircraft System (UAS), hereby apply, on behalf of Tourdepot.us Ultimate Photography and 

Video Production Company for exemption from the listed Federal Aviation Regulations (" FARs") to 

allow commercial operation of its UAS, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by FAA as required by Section 333.

I would like to formally submit for an exemption from part 21, subpart H; paragraphs 61.23(a)&(c); 

61.101(e),(4) and (5); 61.113(a)&(b); 61.315(a); 91.7(a); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)&(1); 91.409(a)&(1)&(2); 91.417(a)&(b), and any other rules the FAA deems necessary, to 

enable Tourdepot.us for commercial operate unmanned aircraft systems ("UAS") for aerial photography 

and video.

NAS Safety

As described fully 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 “....establish requirements for the safe operation of such aircraft 

systems in the national airspace system.”

In addition, given the small size of the UAS’s involved and the restricted controlled environment within 

which they will 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 UASs to 

commence immediately. Also due to the size of the UASs and the controlled areas in which the relevant 

UASs 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: Tourdepot.us by Boris Levitsky the 

owner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and 

that operate with the 
 T o u r d e p o t. u s Photography and Video Production

boris_levitsky@sbcglobal.net (650)278-4048 2

limitations listed herein. These limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which Boris Levitsky agrees to be bound when conducting commercial 

operations under an FAA issued exemption including:

How it benefits public

Tourdepot.us is Ultimate Photography and Video Production Company specializes in photography and 

video for real estate property tour, events and commercial production. Owner operator Boris Levitsky is a

professional with for 25+ years of experience, BA in photojournalism. The company main focus on 

promote real estate agents as a local real estate experts and creating a powerful web presence and generate 

more business. The power of aerial photography and videography unleash property tour via smooth 

seamless footage outdoor and indoor and on top of that, it provides a remarkable chance to show case the 

advantage of location, access, as well as surrounding features from angles not available in the past. When 

shopping for property potential buyers are not just looking at the house itself. The surrounding areas and 

neighborhoods play a huge role in determining whether they interested in purchase. UAS, as described 

herein, which are equipped with camera(s) and sensors, would provide professional services in the 

following areas: Aerial photography and/or video for public and/or private use including services in areas 

of Real Estate, Commercial and Residential, Private events, Cinematography, Building or Construction

sites, Architecture, Vineyards, Special Occasion, Facilities Inspection, Commercial operation and 

Agriculture as well.

About UAS

Specifically Tourdepot.us seeks to operate UAS for real estate property tour, commercial production, 

events and facilities inspection using the DJI Phantom 3 Professional, 3DR Solo, Yuneec Q500+ and 

Typhoon and DJI Inspire 1 pro/raw. I have attached DJI Phantom 3 Use Manual V1.6

1. The UAS will weigh less than 3 pound. Max. speed 23m/s (ATTI mode no wind) UAS is a quad-copter 

with and equipped with four rotors that are driven by electric motors powered by battery. Max. flight time 

23 minutes. I have attached DJI Phantom 3 Use Manual V1.6

USA Operating Parameters

We will abide by the following additional operating conditions under this exemption, which ensures a 

level of safety at least equal to existing rules: 

 Flights will be operated at an altitude of no more than 400 feet AGL

• Operate UAS below 300 feet and within a radius distance of 1000 feet from the controller to 

aid in direct line of sight visual observation; 

 

• Obtain permission from the owner/controller of any vessels, structures when operations may be 

conducted closer than 500 feet to any such vessels or structures; we will conduct a safety assessment 

of the risk of operating closer to those objects and determine that it does not present an undue hazard; 

• Carful evaluate location and follow to pre flight screen play scenario and fly in particular direction to 

obtain the best video footage for video editing. Flying back from the subject, fling straight up. Flying 
 T o u r d e p o t. u s Photography and Video Production

boris_levitsky@sbcglobal.net (650)278-4048 3

from side to side and minimize careless flying around the subject. Limit UAS on flying distance for from 

start to finish controlling UAS and keeping aircraft always in visual line of sight (VLOS).

• Use the UAS’ global positioning system (GPS) confirm home point, and wait for safe to fly indication 

appear. In event 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.

• Land UAS prior to the manufacturer’s recommended minimum level of 30% battery power.

• Conduct all operations under the flight safety protocols (including posting a warning sign reading: 

“Attention Aerial Photography in Progress – Remain Back 150 feet”) contained in the operating 

documents and will actively analyze flight data and other sources of information to constantly update 

and enhance safety protocols; 

• Operate UAS during daylight hours only within visual line of sight (VLOS); 

• Contact respective airports if operations will be within 5 miles to advise them of his 

estimated flight time, flight duration, elevation of flight and other pertinent information; 

• Always obtain all necessary permissions prior to operation; have procedures in place to 

abort flights in the event of safety breaches or potential danger.

 Only operate in safe environments that are strictly controlled, are away from

power lines, elevated lights, airports and densely populated areas (defined by areas depicted in 

“yellow” on VFR charts and through obtaining information regarding congested areas from the local 

Flight Standards District Office (FSDO); 

• Conduct extensive preflight inspections and protocols, during which safety carries primary 

importance (reference PHANTOM Flying Flow Chart and User Manual). 

 

 Regarding UAS operational training, we have flown numerous practice flights in remote areas as 

hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of 

the UAS’ and practice to control aircraft and video shooting in different flying path scenario flight 

performance under different temperature and weather conditions and time a day. 

 The operator will provide all contact information follow by aircraft registration number and operator 

contact and post advisor notice around the controlled area.

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

emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. I 

am looking forward to working with your office. Please contact me at any time if additional information 

or clarifications are needed.
 T o u r d e p o t. u s Photography and Video Production

boris_levitsky@sbcglobal.net (650)278-4048 4

Summary

A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which The Tourdepot.us by Boris Levitsky Operator Seeks Exemption

The Tourdepot.us by Boris Levitsky seeks exemption from part 21, subpart H; paragraphs 61.23(a)&(c); 

61.101(e),(4) and (5); 61.113(a)&(b); 61.315(a); 91.7(a); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)&(1); 91.409(a)&(1)&(2); 91.417(a)&(b), 

A Brief Description Of The Nature Of The Exemption The Tourdepot.us Seeks:

This exemption will permit The Tourdepot.us by Boris Leviysky to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography over Bay Area, 

California. 

Any Additional Information, Views, Or Arguments Available To Support

The Tourdepot.us Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 

2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS

may operate safely in the NAS. As such, Tourdepot.us request for exemption may be granted pursuant to 

the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification.

As discussed in detail above, The Tourdepot.us, by Boris Levitsky will operate the DJI Phantom 3

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security.

Conclusion

As set forth herein, The Tourdepot.us by Boris Levitsky seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit 

safe operation of the DJI Phantom 3 professional UAS commercially, without an airworthiness certificate, 

for the limited purpose of conducting aerial video and photography. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform 

Act of 2012, while also advancing the interests of the public, by allowing The Tourdepot.us, by Boris 

Levitsky to safely, efficiently, and economically operate the DJI Phantom 3 Professional UAS 

commercially within the NAS. Wherefore in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, The Tourdepot.us by Boris Levitsky owner 

operator respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of FMRA Section 333 and 14 C.F.R. Part 11from part 21, subpart H; paragraphs; 

61.23(a)&(c); 61.101(e),(4) and (5); 61.113(a)&(b); 61.315(a); 91.7(a); 91.103; 91.119(c); 91.121; 

91.151(a); 91.405(a); 91.407(a)&(1); 91.409(a)&(1)&(2); 91.417(a)&(b), and permit to operate the DJI 

Phantom 3 professional UAS commercially for the purpose of conducting aerial video and photography 

over Bay Area, California.
 T o u r d e p o t. u s Photography and Video Production

boris_levitsky@sbcglobal.net (650)278-4048 5

Sincerely

Thank you.

Boris Levitsky

Owner

Tourdepot.us 

Photography and Video Production

6135 Shelter Creek Lane

San Bruno, CA 94066

boris_levitsky@sbcglobal.net

(650)278-4048

www.tourdepot.us

Ultimate Photography and Video Production Company.