July 20, 2015

Forrest in Focus, LLC

4607 Belvedere Rd.

West Palm Beach, FL 33415

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (the “Reform Act”) and 14 C.F.R. Part 11, Forrest in Focus, LLC

seeks an exemption from Federal Aviation Regulations (“FARs”) listed

below for the DJI Phantom 3 Professional, a quadcopter manufactured 

by DJI-Innovations.

The requested summary exemption would support an application for a 

“blanket” commercial Certificate of Authorization to use the system to 

capture aerial photography and videography. The DJI Phantom 3 

Professional system consists of a lightweight (2.8 lb) battery operated 

aircraft, a tablet-based ground control station and/or RC Controller, 

and associated communications equipment. The aircraft carries an 

onboard gimbaled camera that allows it to obtain photographs and 

video.

The requested exemption would permit Forrest in Focus, LLC to pursue 

its commercial interests in providing services to clients using a small 

advanced UAS in the following areas:

• Real Estate/Architecture

• Construction Site Inspection

• Marketing

• Surveying/Mapping

• Sporting Events

• Special Events/Festivals
The regulations from which the exemption is requested are as follows:

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 61.3

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

Unmanned Aircraft System

UAS are often seen as superior to helicopters as an aerial video 

gathering platform due to the smaller size of the devices, more 

affordable equipment and personnel cost, reduced noise, and a much 

smaller environmental impact which promotes public safety.

Forrest in Focus, LLC is petitioning for an exemption to operate a DJI 

Phantom 3 Professional with a built-in stabilized HD camera and the 

following GPS safety features:

• Restricts the height Above Ground Level (AGL) to a specified user 

generated height.

• Restricts the radius of flight from the ground station to a usergenerated distance.

• Restricts operations within designated Class B, C, and D airspace

including a no-fly zone feature. 

The DJI Phantom 3 Professional also has a failsafe function that is 

triggered in the event communications are lost between the UAS and 

the main controller transmitter. In the unlikely event this occurs, the 

UAS will return to its point of takeoff and land safety. If 

communications are restored, the PIC can regain control of flight and 

land manually.

These specifications meet with the Model Aircraft Operating Standards 

(AC 91-57) as set below:

1. The petitioner will only operate its UAS in line-of-sight of a Pilot 

in Command (PIC) and/or ground based Visual Observer (VO)

and will operate at sites that are ‘sufficient distance’ from 

populated areas within the sterile area described in the FOPM. 

Such operations will ensure that the UAS will “not create a 

hazard to users of the national airspace system or the public.” 

The orientation of flights will be such that the PIC or VO always 

has a visual on the rear mounted LED flight Indicator. Additional 

safety features on the DJI Phantom 3 Professional include an 
automatic return-to-home feature enacted upon low battery

level.

2. When flying the UAS within three (3) miles of an airport, airport

operators will be notified at least 72 hours prior, and the 

operator will give the right-of-way to any manned aircraft.

3. Pre-flight inspection would include checking battery 

condition/level in the transmitter, control tablet, and UAS; a 

visual/operational check of the propellers; a visual/operational 

check of the aircraft; a visual/operational check of the motors; a 

full compass and IMU calibration; a visual/operational check of

the transmitting radio control unit; a visual/operational check of 

the camera and gimbal unit; and a visual/operational check of 

the vision positioning system. A check for power-lines, antennas,

and other overhead objects would also be performed. Wind and 

weather conditions would be monitored and be taken into 

account as a factor for flying.

4. The radio frequency of the DJI Phantom 3 Professional is in the 

2.400 to 2.483 GHz range. Maximum takeoff weight

approximately 3000g. Max Ascent/decent speed 5 m/s. 

Maximum flight Velocity 16 m/s. The UAS to be operated by the 

petitioner weighs less than 3 pounds, including all payload (i.e. 

battery, camera, lens, and stabilized gimbal).

5. The PIC will be only myself and I have a minimum of 15 hours 

flying time with DJI equipment, all of those hours with this

specific model, the DJI Phantom 3 Professional. I am an 

architectural photographer with over 12 years of photography 

and videography experience. Testing, updating and 

programming the DJI Phantom 3 Professional firmware would be 

done on a monthly schedule.

6. Flights will be terminated when battery energy levels reach 25%,

allowing sufficient reserve flight time to safely land the UAS. If 

battery drops below a user specified level the UAS will 

automatically return to its takeoff point and land safely.

7. The UAS will be programmed so it will not be operated at an 

altitude that exceeds 400 feet AGL, and not more than 150 feet

above a significantly elevated geographic position from which 

videography/ photography is planned.

8. I am in good medical health and sound mental health with no 

arrests or felonies.

9. The intended use of this DJI Phantom 3 Professional is to 

supplement my existing photography business with aerial 
photographs and video. The aerial perspective would allow my 

business to provide a unique service to local clients that is 

attractive and competitively priced.

10. All photo/video flights would have the date, time, GPS

coordinates along with the camera metadata recorded in an inapp flight log on the mobile device serving as the in-flight 

monitor/tablet. This flight log records flight path, altitude, flight 

time, number of images shot, amount of video shot, date, time, 

and total flight distance. Each individual flight has the capability 

of playing back (in-app) in real time and is synced across devices 

via DJI’s in-app User Center.

11. Given the small size of the UAS and the restricted sterile 

environment within which it will operate, Forrest in Focus, LLC’s 

operations will adhere to the Reform Act’s safety requirements.

12. The DJI Phantom 3 Professional will never be flown in the flight 

path of manned aircraft. With the first condition listed, always 

keeping a visual line of sight, being of utmost importance to 

providing a significant level of public safety. 

In summary, I respectfully request exemption from regulations 

specified above, under Section 333 to enable Forrest in Focus, LLC to 

operate efficient, limited, and low-risk commercial UAS operations for 

the activities stated above, respecting at all times the space and 

privacy of citizens and property, while keeping airspace safe. Granting 

this request would be in good public interest by giving an opportunity 

for real estate photographers and sporting event photographers to 

offer safer, unique views, and more competitively priced aerial 

photography to the general public.

I am willing and able to modify or amend any part of this request to 

satisfy the need for an equivalent level of safety. We look forward to 

working with your office. Please feel free to contact us at any time if 

you require additional information or clarification.

Best regards,

Forrest in Focus, LLC

Attn: Chris Forrest

4607 Belvedere Rd.

West Palm Beach, FL 33415

chris@forrestinfocus.com

(561) 512-5168

Also Attached: Phantom 3 Professional User Manual