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 Regula tions (“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 syste m 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 carri es 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/FestivalsThe 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 C FR 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 an d 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 P ilot in Command (PIC) and/or ground based Visual O bserver (VO) and will ope rate 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 a nautomatic 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 checki ng 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 contro l 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 m onitored 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 rang e . 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 a m a n 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 whi ch 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 aerialphotographs and vid eo. The aerial perspective would allow my business to provide a unique service to local clients that is attractive and competitive ly priced
. 10. All photo/video flights would have the date, time, GPS coordinates along with the camera metadata recorded in an in app 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 wi ll 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. W ith 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 m ore 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 Belved ere Rd. West Palm Beach, FL 33415 chris@forrestinfocus.com

(561) 512 - 5168
Also Attached: Phantom 3 Professional User Manual