1 March 1, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

Washington, DC 20590

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

Aviation Regulations

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Attachments: These attachments are too large for submission vi a the submission portal.

They are available at this website for viewing or download.
http://www.dji.com/product/phantom

- 3/download

1. Phantom 3 Professional Quick Start Guide (EN) v1.0

2. Phantom 3 Professional User Manual (EN) v1.0

3. Phantom 3 Safety Guidelines and Disclaimer

Dear Sir or Madam:

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), David J. Cavanaugh, President of DCDIGITAL, Inc., (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an exemption from the
Federal Aviati on Regulations ("FARs") to allow for commercial operation for aerial imaging to be used in real estate cinematography.

Applicant

David J. Cavanaugh, President

DCDIGITAL, Inc.

1750 Castle Rock Road

Frederick, MD 217012 Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (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 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Extent of relief I seek, and why

14 CFR Part 21 subpart H

The UAs to be operated carries neither pilot nor passenger and carries no explosive
materials or flammable liquids. Given the size, weight, speed, and limited operating area
associated w ith the aircraft to be utilized, I request exception. In the restricted environment and under the conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without
said restri ctions.

14 CFR 45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to
market certain words or phrases. Lettering would be very difficult to place on such a
small aircraft and dimensions would need to be smalle r than required minimum. Understanding the importance of lettering I will mark my UAS with the largest possible letters by placing the word "Experimental" or assigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required.3 14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthin ess. Given the
size of the aircraft for maintenance and use of safety check list prior to each flight an equivalent level of safety will be provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on t he
aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual.

A n equivalent level of safety will be maintained by keeping the flight manual at ground

con trol point where the pilot will have immediate access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will
be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those f ound in attachment "DJI Pilot Training". An equivalent level of safety will be provided by preflight protocol to properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight
control is achie ved through the use of a control box that communicates with the aircraft
via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the
aircraft.

14 CFR 91.113 (a) and (b)

DCDIGITAL, Inc. can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry pilot nor pass enger. While helpful, a pilot’s license will not ensure remote control piloting skills.

14 CFR 9 1.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude
read out. I believe an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live flight data monitoring and confirming current al titude along with altitude of launch site shown on GPS altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration documents on the aircraft. There is no room, capacity,4 or pilot on board to adequately such documents. An equivalent level of safety will be achieved by keeping these documents, to the extent they are applicable to the UAS, at the ground control point where pilot has immediate acce ss to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these section only apply to aircraft with an a irworthiness certificate, these sections do not apply to this applicant. As a safety precaution, oper ator will perform preflight inspections and ensure UAS is in working condition before initiating each flight.

DCDIGITAL, Inc. is seeking relief from all FARs above preventing applicant from conducting aerial photography and video of real estate taken at le vels less than 400ft, at a speed less than 33.5 mph, and with a maximum flight time of 25 minutes,. The drone

to be used is a DJI Phantom 3 Professional Edition. At 2.82 pounds the weight of the UAS
meets the definition of "small unmanned aircraft" found i n section 331

. "The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds much less than it s top speed of 33.5 mph. Due to the UAS being battery powered there are no combustible fuels on board. Maximum flight time for this particular UAS is 25 minutes battery life, flights to be terminated with 30 % battery life remaining. Given the size, weight, speed, and limited operating area associated with the
aircraft to be utiliz ed I find this exception to be reasonable with an equivalent, or greater, level of safety to be reached by the operator.

Safety Precautions:

1) I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport manager has been made.

2) I land my UAS prior to manufacturer recommended 30% minimum level of battery

power

. 3) I pilot my UAS through remote control by line of sight

. 4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then slowly lands if communication with the remote control pilot is lost

. The Phantom 3 also has optic and proximity sensors to ensure a safe and accurate landing.

5) I actively analyze flight data and other sources of information to constantly update
and enhance safety p rotocols.

6) I conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance

. 7) I always obtain all necessary permissions prior to operation; and,5 8) I have procedures in place to abort fl ights in the event of safet y breaches or potential danger.

Public Interest

The use of an UAS in the real estate industry provides both buyers and sellers a higher
level of service. For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulti ng in a quicker sale of their home. Quicker home sales also helps accelerate the economy as a whole.

Buyers experience the benefit of encompassing a whole property, sometimes several acres, in one photo or a short video. Not only does this benefit the spec ific home seller or home buyer, but it benefits the general public because it is much more efficient than traditional ways of using a plane or helicopter to achieve the same result. We can now provide this level of service while being conservative with fue l, time, emissions, noise, and other resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will poses much less of a safety concern for the general public when compared to larger manned aircraft.

Thank you for your consideration.

David J. Cavanaugh

, President DCDIGITAL, Inc.
1750 Castle Rock Road Frederick, MD 21701

240

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- 9331 dcdigitalonline@mac.com