December 23, 2015

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

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

Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b);

91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1);

91.409 (a)(1) and {2}; 91.417{a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Dane

Allen Campbell Jr., operator of an Unmanned Aircraft System (UAS), hereby

apply for an 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 the FAA as required by Section 333.

I formally submit for an exemption from part 21, subpart H; and Sections

45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b),

91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code

of Federal Regulations (14 CFR). This proposed exemption would allow the

operation of UAS for the purpose of aerial data collection.

Applicant: Dane Allen Campbell Jr., 67 2nd St. , Emerson, GA 30137

dane.campbell85@gmail.com (404)307‐6604

Commercial operation of a UAS as described herein, which is equipped with a

camera and sensors, would operate in the following manner:

Conduct aerial photography and/or video for public and/or private use

in land management, land survey, structural inspection and other related

professional activities.

As described fully below, the requested exemption would permit the

operation of a UAS under controlled conditions in the NAS that would be a)

limited, b) controlled, c) predetermined, and d) will provide safety

enhancements to the already safe operations in the industry presently using

conventional aircraft.

As found in Exemption No. 13203 (Gambill), the FAA recently approved
similar use of a PHANTOM 3 UAS. I will operate a UAS, the DJI Phantom 3

which is comprised of an unmanned aircraft (UAS or Phantom), an attached

camera and a transportable ground station. The PHANTOM 3 is a quad‐copter

with a gross weight of 2.8 pounds. It is equipped with four rotors that are

driven by electric motors powered by batteries. Additional UAS details can be

found in Appendix A.

UAS Operating Parameters

I will abide by the following additional operating conditions under this

exemption, which ensures a level of safety at least equal to existing rules:

• Operate UAS below 400 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, vehicles

and structures when operations may be conducted closer than 500 feet

to any such vessels, vehicles or structures; I will conduct a safety

assessment of the risk of operating closer to those objects and determine

that it does not present an undue hazard;

• Operate the UAS for 5‐10 minutes per flight;

• Land UAS prior to the manufacturer’s recommended minimum level of

battery power;

• Operate UAS during daylight hours only within visual line of sight

(VLOS);

• Use the UAS’ global positioning system (GPS) flight safety feature

whereby it hovers and then slowly lands if communication with the

remote control pilot is lost;

• 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;

• 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. Regarding UAS operational training, I

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 performance under different temperature

and weather conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner

consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft

pilot including at least 10 hours logged as a UAS pilot with a multi‐rotor UAS.

The PIC will also have accumulated and logged a minimum of 5 hours as a UAS

pilot operating the same make and model of UAS to be used for operations. In

addition to the hour requirements, the PIC will accomplish 3 take‐offs and

landings in the preceding 90 days (for currency purposes) prior to any flight.

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated with the

UA, I feel an exemption from 14 CFR part 21, Subpart H (Airworthiness

Certificates) and § 91.203(a) and (b) (Certifications required), subject to

certain conditions and limitations, is warranted and meets the requirements

for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L.

112‐95 (Section 333).

I request an exemption from § 45.23 Marking of the aircraft because the UA

will not have a cabin, cockpit or pilot station on which to mark certain words

or phrases. Further, the two‐inch lettering is difficult to place on such a small

aircraft with dimensions smaller than the minimal lettering requirement.

Regardless of this, I can mark the UAS in the largest possible lettering by

placing the word “Experimental” on its fuselage as required by § 45.29(f) so

that anyone will see the markings.

I request an exemption from § 91.7(a) which prohibits the operation of an

aircraft without an airworthiness certificate, since there is currently no

certificate applicable to our operation, this regulation is inapplicable.

I request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and

91.417(a) and (b) Maintenance inspections since they only apply to aircraft

with an airworthiness certificate. However, as a safety precaution I will

perform a preflight inspection of the UAS before each flight as outlined in the

attached operating documents.
I request an exemption from § 91.9(b)(2) which requires an aircraft flight

manual in the aircraft, however since there are no pilots or passengers on

board the aircraft and given its size, this regulation is inapplicable. I believe

an equivalent level of safety will be achieved by maintaining a safety/flight

manual with the UAS ground station.

I request an exemption from § 91.119 which prescribes safe altitudes for the

operation of civil aircraft, but it allows helicopters to be operated at lower

altitudes in certain conditions. I will not operate our UAS above the altitude of

400 feet above ground level (AGL) and will also only operate in safe areas away

from the public and traffic, thus “providing a level of safety at least equivalent

to or below those in relation to minimum safe altitudes.” Given the size, weight,

maneuverability, and speed of the UAS, an equivalent or higher level of safety

will be achieved.

I request an exemption from § 91.121 Altimeter settings as it is inapplicable

since the UAS utilizes electronic GPS with a barometric sensor.

I request an exemption from § 91.151(a) Fuel requirements for flight in VFR

conditions. The UAS is 100% electric and two low battery alerts are issued

‐per the operating documents, the UAS will be landed at the first alert. Also,

our flights will last only 5‐10 minutes each, and the UAS has an automated

function, which results in immediate landing when a low battery is detected.

The PIC will not begin a flight unless (considering wind and forecast weather

conditions) there is enough power to fly to the first point of intended landing

and, assuming normal cruising speed, land the UA with 30% battery power

remaining.

Public Interest

Aerial photography and videography are proven strategies to enhance

marketing efforts and increase business success. The industry is not new.

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

economic growth by providing information to companies and the public

looking to relocate or build in the metro areas I service. Public and private

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

community and its citizens.
Summary

I will comply with all of the following conditions and limitations should this

exemption be provided:

1) Operations will be limited to the following aircraft described in the

operating documents, which is a quad‐rotor aircraft weighing 2.8 pounds:

Phantom 3 Unmanned Aircraft System.

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 400 feet above

ground level (AGL), All altitudes reported to ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot In

Command (PIC) at all times.

5) All operations will utilize a visual observer (VO). The UA will be operated

within the visual line of sight (VLOS) of the VO at all times. The VO and PIC

will be able to communicate verbally at all times. The PIC will be designated

before the flight and will not transfer his or her designation for the duration

of the flight. The PIC will ensure that the VO can perform the functions

prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and

made available to the Administrator upon request. Any revisions to the

operating documents will be presented to the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a

condition for safe flight. If the inspection reveals a condition that affects the safe

operation of the UAS, the UAS will not be operated until the necessary

maintenance has been performed and the UAS is found to be in a condition for

safe flight. The Ground Control Station will be included in the preflight

inspection. All maintenance and alterations will be properly documented in the

aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight

characteristics, e.g. replacement of a flight critical component, will undergo a

functional test flight. The PIC who conducts the functional test flight will make

an entry in the aircraft records.

9) The pre‐flight inspection section in the operating documents will account

for all discrepancies, i.e. inoperable components, items, or equipment, not

already covered in the relevant sections of the operating documents.
10) I will follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

11) I will carry out maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, and alterations will be noted in the aircraft records, including total

flight hours, description of work accomplished, and the signature of the

authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between

inspections.

14) UAS operations will be conducted by a PIC possessing at least a private

pilot certificate and at least a current third‐class medical certificate. The PIC

will also meet the flight review requirements specified in 14 CFR 61.56 in an

aircraft in which the PIC is rated on his or her pilot certificate.

15) Prior to operations conducted for the purpose of aerial

videography/photography and for real estate listing videos and public and

private events and similar operations, the PIC will have accumulated and

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a

UAS pilot with a multi‐rotor UAS.

16) Prior to operations conducted for the purpose of aerial

videography/photography and for real estate listing videos and public and

private events and similar operations, the PIC will have accumulated and

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as

UAS pilot operating the make and model of the UAS to be used in operations.

The PIC will accomplish 3 take‐offs and landings in the preceding

90 days.

17) The PIC will not operate the UAS for the purpose of aerial

videography/photography and for real estate listing videos and public and

private events and similar operations, unless the PIC has demonstrated and

logged in a manner consistent with 14 CFR 61.51(b), the ability to safely

operate the UAS in a manner consistent with the operating documents,

including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.
18) UAS operations will not be conducted during night, as defined in 14 CFR

1.1. All operations will be conducted under visual meteorological conditions

(VMC).

19) The UA will not operate within 5 nautical miles of an airport reference

point as denoted on a current FAA‐published aeronautical chart.

20) The UA will not be operated less than 500 feet below or less than 2,000

feet horizontally from a cloud or when visibility is less than 3 statute miles

from the PIC.

21) If a UA loses communications or loses its GPS signal, it will return to a

predetermined location within the planned operating area and land or be

recovered in accordance with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to

the intended landing point and land the UA with 30% battery power

remaining.

24) I will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting operations outside approved

conditions, and also request a Notice to Air‐man (NOTAM) not more than 72

hours in advance, but not less than 48 hours prior to the operation.

25) Before conducting operations, the radio frequency spectrum used for

operation and control of the UA will comply with the Federal

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203 will be available

to the PIC at the Ground Control Station of the UAS any time the UAS is

operating. These documents will be made available to the Administrator or

any law enforcement official upon request.

27) The UAS will remain clear and yield the right of way to all manned

aviation operations and activities at all times.

28) The UAS will not be operated by the PIC from any moving device or

vehicle.
29) The UA will not be operated over congested or densely populated areas.

30) Flight operations will be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from the UA and/or debris in the event of an

accident. I will ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave

such protection and are within 500 feet of the UA, flight operations must

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential

persons do not present an undue hazard to those persons per §

91.119(a).

31) All operations will be conducted over private or controlled‐access

property with permission from the land owner/controller or authorized

representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

32) Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

will be reported to the FAA's UAS Integration Office (AFS‐80) within 24 hours.

Accidents will be reported to the National Transportation Safety Board (NTSB)

per instructions contained on the NTSB Web site: www.ntsb.gov.

If you have questions or need additional information, please contact me at

dane.campbell85@gmail.com or (404)307‐6604.

Thank you,

Dane Allen Campbell Jr.
APPENDIX ­ A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

Dane Allen Campbell Jr. only utilizes safe and reliable UASs. DJI is an industry

leader in small UAS production. DJI UASs are loaded with ground breaking

software enabling the user to set parameters which will not allow flight into

controlled airspace. Parameters can also be set to limit flight to no higher than

a predetermined and set altitude as well as limit flight to a predetermined and

set distance. In addition, DJI software provides real‐time altitude and location

information to the PIC via the linked monitor (smart phone/tablet devices)

DJI Phantom 3

1. Aircraft

a. Supported Battery ‐ DJI 4480 mAH LiPo Battery

b. Weight (Battery & Propellers Included) ‐ 2lbs 11.810oz (1242g)

c. Hover Accuracy (Ready to Fly) ‐ Vertical: .8m; Horizontal: 2.5m

d. Max Yaw Angular Velocity ‐ 200/s

e. Max Tilt Angel ‐ 35 1.1.1.6 Max Ascent Speed ‐ 6m/s

f. Max Descent Speed ‐ 2m/s

g. Max Flight Speed ‐ 15m/s (NOT RECOMMENDED)

2. Gimbal

a. Working Current ‐ Static: 750mA; Dynamic: 900mA

b. Control Accuracy ‐ ±0.03

c. Controllable Range ‐ Pitch: ‐90 ‐ 0

d. Maximum Angular Speed ‐ Pitch: 90/s

3. Camera

a. Operating Temperature Range ‐ 32F ‐ 104F (0C ‐ 40C)

b. Sensor Size ‐ 1/2.3”

c. Effective Pixels ‐ 14M

d. Resolution ‐ 4384x3288

e. HD Video Recording ‐ 1080p30 & 720p

f. Recording Field of View ‐ 110/85