June 14, 2015 

Docket Operation, M-30 

1200 New Jersey Avenue, SE 

Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001 

Ae~al PhotographJ And VldeographJ 

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RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. §21, subpart H; 14 C.F.R. 42.23(b); 14 C.F.R. 

§§61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.105; 91.109; 91.119; 91.121; 

91.151(a);(91.203(a) and (b); 91.405 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 

(a) (2) and 91.417 (a) and (b) to operate commercially for purposes in Real Estate. 

PERSONAL INFORMATION 

Name VINCENT ANTONIO PIATEK 

Company QUAD PICTURES 

ADDRESS 1911 SW CAMPUS DR. #392 

Federal Way, Washington 98023 

253-335-2531 

vincentapiatek@gmail.com 

Dear Sir or Madam, 

/ 

/ 

My name is Vincent Piatek, an owner and operator of small unmanned aircraft systems and 

I am submitting request for exemption of Section 333 of the FAA Modernization and 

Reform Act of2012 and 14 C.F.R. Part 11ofthe Federal Aviation Regulations. 

BACHGROUND 

I work is the Real Estate industry and specialize in photography and videography in Real 

Estate. When a realtor in the greater Seattle area is looking to list a piece of property they 

want to showcase the best angles of the property, it is of significant benefit to use an UAS 

for aerial photography and videography to help the listing be very unique, Giving the buyer 

a greater picture of the quality and build of the house/property. 
REGARDING THE UNMANNED AIRCRAFT SYSTEM 

The UAS I will be using is a small quadcopter weighing less than 55 pounds with any and 

all payload. These UAS's operate at a speed no greater than 30 knots and can and can 

climb to an altitude to higher then 400ft AGL. It operates only in the line of my sight as the 

sole operator and within a radius of 300ft. These flight restrictions ensure that it is not a 

hazard to the aerospace in which it will operate. This UAS fall within the safety zone that 

the FAA will, with an exemption in place, allow commercial operations of a UAS. The 

UAS I will be flying is a DJI PHANTOM 3 ADVANCED Serial number 

P76DCG I 50 I 0484. The specific specifications are found below. 

Aircraft 

Camera 

WEIGHT (INCLUDING BATTERY AND PROPELLERS) 

1280 g 

DIAGONAL SIZE (INCLUDING PROPELLERS) 

590mm 

MAX ASCENT SPEED 

5 m/s 

MAX DESCENT SPEED 

3 m/s 

HOVER ACCURACY 

• Vertical:+/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m 

• Horizontal:+/- 1.5 m 

MAX SPEED 

16 m/s (ATTI mode, no wind) 

MAX ALTITUDE ABOVE SEA LEVEL 

6000 m 

OPERATING TEMPERATURE 

ooc to 40°C 

GPSMODE 

GPS/GLONASS 

SENSOR 

Sony EXMOR l/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

LENS 

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo 

ISO RANGE 

100-3200 (video) 100-1600 (photo) 

SHUTTER SPEED 
Gimbal 

Vision Positioning 

8s -1/8000s 

IMAGE MAX SIZE 

4000 X 3000 

STILL PHOTOGRAPHY MODES 

• Single Shot 

• Burst Shooting: 3/5/7 shots 

• Auto Exposure Bracketing (AEB): 3/5 

• Bracketed Frames at 0.7EV Bias 

• Time-lapse 

VIDEO RECORDING MODES 

Phantom 3 Advanced 

• FHD: 1920x1080p 24/25/30/48/50/60 

• HD: 1280x720p 24/25/30/48/50/60 

SUPPORTED SD CARD TYPES 

Micro SD 

Max capacity: 64GB. Class 10 or UHS-1 rating required 

MAX BITRA TE OF VIDEO STORAGE 

Phantom 3 Advanced 

40 Mbps 

SUPPORTED FILE FORMATS 

• FAT32/exFAT 

• Photo: JPEG, DNG 

• Video: MP4, MOV (MPEG-4 A VC/H.264) 

OPERATING TEMPERATURE 

ooc to 40°C 

CONTROLLABLE RANGE 

Pitch -90° to +30° 

STABILIZATION 

3-axis (pitch, roll, yaw) 

MAX VELOCITY 

Less than 8 m/s (when 2m above ground) 

ALTITUDE RANGE 
Remote Controller 

Battery Charger 

30 cm-300 em 

OPERA TJNG RANGE 

30 cm-300 em 

OPERATING ENVIRONMENT 

Surface with clear pattern and adequate lighting (Lux> 15) 

OPERATING FREQUENCY 

2.400 GHz-2.483 GHz 

MAX DISTANCE 

2000m (outdoors and unobstructed) 

VIDEO OUTPUT PORT 

USB 

OPERATING TEMPERATURE 

6000 mAh LiPo 2S 

MOBILE DEVICE HOLDER 

For tablet or phone 

RECEIVER SENSITIVITY (1 %PER) 

-101 dBm ±2 dBm 

TRANSMITTER POWER (EIRP) 

• FCC: 20 dBm 

• CE: 16 dBm 

WORKING VOLT AGE 

1.2 A @7.4 V 

VOLTAGE 

17.4 v 

RATED POWER 

Phantom 3 Advanced 

• 57W 

CAPACITY 

Intelligent Flight Battery 4480 mAh 

VOLTAGE 

• 15.2 v 
BATTERY TYPE 

LiPo 4S 

ENERGY 

68Wh 

NET WEIGHT 

365 g 

MAX FLIGHT TIME 

Approximately 23 minutes 

OPERATING TEMPERATURE 

-1 ooc to 40°C 

MAX CHARGING POWER 

100 w 

PROCEDURES FOR FLIGHT 

I will always follow procedures outline in the UAS operator's manual as to proper 

preflight inspection of all hardware, software, environmental and any other factors needed 

to ensure a safe flight. 

o If required, notify the appropriate FAA facility of our launch schedule and location. 

o Check weather for wind speed, cloud cover and any forecast change during flight. 

o Flowing takeoff I will hover 10 feet and assure the Home Point is solid and have 

Signals with the GPS. 

o I will not fly over dense traffic or crowds 

o I will give right-of-way to any manned aircraft. 

o I will stay clear of FAA controlled airspace at airports as well as restricted and 

prohibited zones. 

o Examine the aircraft, Test batteries in remote control, and in the UAS. The only 

acceptable battle level before takeoff is 90% and the UAS with be grounded before 

battery reaches 25% 

o Permission from property owner before flight. 

o With an Observer, make a walk around the area that is going to photographed or 

filmed. We will take note of any trees, light poles, power lines, and or any other 

obstacles before takeoff. 

o Go over flight path, speed, distances, and altitude. 

o The operator will make sure the site is secure and a perimeter of 25 feet of flight 

path ofUAS. 

FCC INFORMATION 

The UAS being deployed here is DJI PHANTOM 3 ADVANCED. The control link 

operates on a frequency of 2.4. The range is 2000m (outdoors and unobstructed) the 

receiver sensitivity is 1 01 dbm. 
QUALIFICATION OF UAS PIC 

The PIC will have over 100 hours of flight time with UAS. The PIC has been flying UAS 

for over 3 years starting with the DJI PHANTOM 1 and then the PHANTOM 2+ and now 

operates the DJJ PHANTOM 3 ADVANCED. Because the UAS will not carry passengers 

and will fly within a restricted area, it will exceed the safety standards set forth in 14 

C.F.R. 61.113 (a) and (b). At all times there will be an observer who will also monitor the 

UAS, surrounding buildings or obstacles and will be the second set of eyes during flight of 

the UAS. 

OPERATIONS OF UNMANNED AIRCRAFT 

The UAS will be a tool for photography and video graphing real estate in the greater 

Seattle area. Clients will be able to view aerial pictures and videos of property before 

purchase. This will give them a better understating of layout of property. 

The flight of the UAS will not pose any safety threat to public. Flight will only be during 

the daytime. Batteries level will not be lower than 90% for takeoff. There will always be an 

observer for a second eye on the UAS during flight. A full pre-flight checklist and flight 

plan after permission is granted form property owner. 

The UAS will not operate if clouds are below 800ft AGL. This UAS does not fly over 

29.1577 knots and speed will not reach over 10 knots (11.507 MPH). This will ensure great 

control of the UAS. 

The intended area of operation will be in rural settings, as well as neighborhood. Potential 

hazards are power lines, trees, structure, streetlights. Low flight speed ofthe UAS when in 

operation for videography and photography for intended purpose, the PIC and observer 

will be able to safely maneuver the UAS around the hazards. The UAS also had 

capabilities to hover is place and fight the wind because of GPS location. 

The UAS will NEVER be flown near the airports so as to pose any sort of safety concerns 

to pilots in the area. UAS Will never be flown within 5 miles radius of any large 

international airport and 0.6 miles of a smaller regional airport. If the UAS is in flight and 

tires to fly into a no fly zone, the UAS will stop and return home. If required by the FAA, I 

will notify the FSDO of my flight operations prior to flight. 

14 C.F.R. Part 21, Subpart H, 91.203(a) & (b) Airworthiness Certificate 

Because the UAS in under 55lbs, fully loaded, and does not carry pilot, passenger, any 

explosive material or flammable fuel, operates in a fully restricted and controlled 

environment, I request exemption from 91.203 part A & B. 

14 C.F.R. 45.23 B Marking The Aircraft 

The UAS will not have an airworthiness certificate and because there is no entrance to the 

cabin, cockpit, or pilot station, there is no place inside the aircraft to place the word 

"Experimental" on the exterior ofthe UAS. However, due to size 2 inch lettering will not 

be possible. 
14 C.F.R. 61.113 A & B Private Pilot Privileges And Limitations: Pilot in Command 

Unlike civil aircraft, the UAS doesn't carry living things on board; rather, it is controlled 

remotely via a safe and restricted location. The risks during operation are so minuscule the 

PIC will exceed the present level of safety required for a commercial pilot to operate a 

rotorcraft. 

14 C.F.R. 91.9 B(2): Civil Aircraft Flight Manual In The Aircraft 

Because the UAS has not cockpit or storage space on board the flight manual will be 

carried by the PIC and observer at all time when operating the UAS. 

14 C.F.R. 91.103 B(2): Preflight Action 

An extensive pre-flight inspection will take place before every flight. See Page 5 

(Procedures for Flight) for pre-flight checklist. 

14 C.F.R. 91.105: Flight Crewmembers at Station 

Because there are no human life aboard the UAS, regulation 91.105 should be exempt for 

my purpose of using my UAS. But the PIC and observer will be on the ground and have 

visual ofUAS at all time. 

14 C.F.R. 91.109: Flight Instruction 

The UAS does not have dual controls. The PIC communicates to the UAS via radio 

Control Box. The FAA had approved exemption for flight training without fully functional 

dual controls for a number of aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

The UAS will never reach a flight altitude greater than 400ft AGL. It will always be flown 

with permission and consent of property owner. 

14 C.F.R. 91.121: Altimeter Settings 

The UAS doesn't use an altimeter. It has GPS (connects to 18 satellites) to determine the 

altitude. Will need and exemption since normal protocol is to set the altimeter to the 

barometric pressure reading at the time of flight. Before takeoff of the UAS, I will ensure 

that GPS altitude is working correctly. 

14 C.F.R. 91.151: Fuel Requirements For Flight in VFR Condition 

The battery life of the DJI PHANTOM 3 ADVANCED is capable of23 minutes (with mild 

temperature conditions) of flight and will not take flight with battery life lower than 90%. 

The UAS will not fly higher than 400ft AGL and 300ft away, at the furthest feet away the 

UAS will take no longer than 2 minutes to reach the ground. Battery life at 25% will be 

about 5mins of flight time, plenty oftime to safely get home and land. Battery life and time 

remaining of flight is displayed on the 1 0" screen visible to the PIC and observer at all 
time. When battery life reaches 25% the UAS will automatically return home and land 

from place of takeoff. 

14 C.F.R. 91.203 A & B: Carrying Civil Aircraft Certification And Registration 

The UAS does not have any storage on board to carry such documents. UAS weight under 

55lbs and doesn't have an on board pilot operating it. If required by the FAA, they will be 

carried at all time by the PIC. 

14 C.F.R. 91.405 A; 407 A(l); 409 A(2); 417 A & B: Maintenance Inspection 

This regulation applies to aircraft that have an airworthiness certificate and should not 

apply to the operation of my intended use for the UAS. Before each flight, maintenance of 

the UAS such as cleaning of motors, light, inspection of props and body for damage will 

take place. Each flight is logged on the software and also hand written. If required by FAA 

log book and software will be surrendered upon request. 

SUMMARY 

I Vincent Piatek feel my operation of my UAS will meet/exceed all current safety 

standards and regulations set by the FAA. I am seeking exemption from the following 

rules: 

REGULATION FROM WHICH THE EXEMPTION IS REQUESTED 

14 C.F.R. §21, 

14 C.F.R. 45.23(b); 

14 C.F.R. §§ 61.113(a) & (b); 

14 C.F.R. 91.7 (a); 

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

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

14 C.F.R. 91.105; 

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); 

14 C.F.R. 91.203 (a) and (b); 

14 C.F.R. 91.405 (a); 

14 C.F.R. 91.407 (a) (1); 

14 C.F.R. 91.409(a) (2); 

91.417(a) & (b) 

STATUATORY AUTHORITY FOR EXEMPTION 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. 

This statutory authority includes exempting civil aircraft, as the term is defined under §401 

01 of the Act, including sUASs, from the requirement that all civil aircraft must have a cur 

rent airworthiness certificate. 
The Administrator may grant an exemption from a requirement of a regulation pres 

cribed under subsection (a) or (b) of this section or any sections 4470244716 of this Title 

If the Administrator finds the exemption in the public interest.3 Section 333(b) ofthe Refor 

m Act assists the Secretary in determining whether sUASs may operate in the National Air 

space System ("NAS") without creating a hazard to the user, the public, or a threat to natio 

nal security. In making this determination, the Secretary must consider: 

• The sUAS's size, weight, speed, and operational capability 

• Whether the sUAS operates within the visual line of sight of the operator 

• Whether the sUAS operates outside of highly populated areas and away from close 

proximity to airports 

If the Secretary determines that a sUAS "may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in 

the national airspace system. 

Holder's proposed sUASs are multirotor vehicles, weighing 15 or fewer lbs. 

including payload. They will operate under normal conditions at a speed of no more than 5 

0 mph and have the capability to hover, and move in the vertical and horizontal plane simul 

taneously. They will operate only in line of sight and will operate only within the sterile are 

a described in the attached Exemption Request Addendum (hereinafter "the Addendum"). 

Such operations will ensure that the sUASs will "not create a hazard to users of the nationa 

l airspace system or the public. 

Given the small size of the sUASs involved and the area within which they will ope 

rate, Holder's application falls squarely within the zone of safety (an equivalent 

level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations ofsUASs to commence. Also due to the small size ofthe sUASs 

and the low altitudes and limited areas in which Holder's sUASs will operate, 

approval of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of 

safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety and reduced environment impacts, the grant ofthe requested exe 

mptions is in the public interest. Accordingly, Holder respectfully requests that the FAA gr 

ant therequested exemption without delay so a sUAS can be leveraged on 

several projects that are already in construction. 

PUBLIC INTREST 

The fact the pilot has over 5 years of experience flying sUAS's demonstrates Quad 

Pictures without incident shows a high regard for safe operation with an understanding of 

F ARs, pre-flight inspection, knowledge of operation and difference in airspace 

classification, maintenance and repair, as well as being trained to high safety standards. 

The DJI Phantom 3 is an extremely safe, efficient, and an economical alternative to 

manned, fix wing aircraft that are currently being used for aerial imaging of real estate 

property's. Three reasons why the public would benefit from granting Quad Pictures · 

exemption from these regulations 1) reduce the number of manned aircraft in the NAS. 2) 
The DJI P3 is much quit and would reduce air and noise pollution. 3) Reduce the risk of 

life and property the ground because of no flammable materials on board and the size of 

the DJI P3. 

Satisfaction of the criteria provided in the section 333 of the reform act of 2012 size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security, provides adequate justification 

for the grant of the requested exemption allowing commercial operation of the DJI 

Phantom 3 (serial number P76DCG15010484) in the purpose of commercial real estate 

photography. 

I respectfully request exemption for the above listed regulations in order to conducted 

aerial videography and photography for Real Estate. 

Please contact me at any time for any further information. 

Thank you for your time. 

Sincerely, 

Vincent Piatek 

Quad Pictures 

1911 SW Campus Dr. #392 

Federal Way, WA, 98023