February 26, 2016

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

SPECIFIC EXEMPTIONS REQUESTED

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

Aviation Regulations from: 14 CFR 21 subpart HD14 CFR 45.23(b)D14 CFR 61.113(a) and

(b) 14 CFR 91.7(a)D14 CFR 91.9(b)(2)D14 CFR 91.103D14 CFR 91.109D14 CFR

91.119(c)D14 CFR 91.121D14 CFR 91.151(a)D14 CFR 91.203 (a) and (b) 14 CFR 91.405 

(a)D14 CFR 91.407 (a) (1)D14 CFR 91.409 (a)(1) and (2) 14 CFR 91.417(a) and (b)

Commercial operation of an UAS, as described here, which are equipped with a camera

and devices (GPS, antenna, programmers) that would provide professional services in the 

following areas:

1. Aerial photography and/or video production for public and/or private use 

including real estate, commercial, surveying, architecture and other related 

professional activities.

2. Aerial video and/or photography for public and/or private use including 

television, public events and cinematography.

3. Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local businesses.

EQUIPMENT

I plan to operate a UAS, the DJI Phantom 3 Advanced. The Phantom 3 Advanced is referred 

to as a quad-copter with an approximate weight of about 3 pounds. It is equipped with 

four brushless motors that are driven by electric motors powered by batteries. The UAS 

has a maximum airspeed of 15 m/s and has built in geo-fencing – which is programed to 

avoid zones (airports, hotels, stadiums etc.). In addition is programmed with established 

flight limits (under 400ft altitude).

Also, given the 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
OPERATING PARAMETERS

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 25 minutes.

4. Flights will be terminated at 15% battery power reserve.

5. Flights will be operated at an altitude of no more than 400 feet

6. UAS operator will be trained in the proper safety and operations of the UAS.

7. The UAS will only operate within a controlled area as defined in the Procedures.

8. The operator will post advisor notice around the controlled area.

9. The operator will have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated as required.

10. 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. 

Which in this event the first procedure will be to engaged course lock (return to 

‘home-point’ within a 60ft radius) then after, proceed with home lock (return above 

takeoff point). In the event that the above procedures fail – the operator will activate 

the ‘fail safe’ option, in which will land the UAS to the ground near the takeoff point.

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

emergencies.

SAFETY

These new unmanned aircraft (UAS) have several added safety mechanisms 

including but not limited to:

 Ground looking cameras for more stability in flight.

 More accurate GPS systems for greater reliability.

 More reliable lifting motors to run the thrust propulsion

systems.

 More reliable computer based Engine Control Units.

 Higher resolution video feeds to ground for greater situational

awareness.

 More flight data sent to the ground controls for grater

situational awareness.
 More reliable fail safe features for greater safety on the ground.

PUBLIC INTEREST

Aerial photography and videography are proven strategies to enhance marketing efforts and 

increase business success. However, until recently it was conducted through the use of costly 

manned aircraft, a prohibitive business activity for small companies. By granting this exemption 

I would be able to provide affordable services. Further, the small UAS will pose no threat to the 

public given its small size and lack of combustible fuel when compared to larger manned 

aircraft. Additionally, the operation of our UAS will minimize harm to the environment. Public 

and private events serviced by our business enhance vibrancy and add culture to the 

community and its citizens.

SUMMARY

Therefore, 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 thank you for your time and look forward to 

working with the FAA to become more knowledgeable and certified in flying UAS’

Please contact me through my email david@gpsstudios.com if any additional information 

is needed.

Respectfully,

David Arnold, Owner

GPS Studios, LLC.

P.O. Box 2362

LaGrange, GA 30240

(706) 594-1005