To	whom	it	may	concern,

In	order	to	provide	safe aerial	videography	and	photography	for public business	interests,	I

, Torin	Johnson

, am	submitting	an Exemption	Request
to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the Federal	Aviation Regulations	for m:

14	C.F.R.	p art	21 14	C.F.R.	45.23(b) 14	C.F.R.	61.113(a)	and	(b) 14	C.F.R.	91.7(a) 14	C.F.R.	91.9(b)(2) 14	C.F.R.91.119(c)

14	C.F.R.	91.121

14	C.F.R. 91.151(a)(1) 14	C.F.R.	91.203(a)	and	(b) 14	C.F.R.	91.405(a) 14	C.F.R.	91.407(a)(1 )

14	C. F.R.	91 .409 (a)(1)	and	(2) 14	C.F.R.	91.417(a)	and	(b)

I	am	requesting	these	exemptions	so	that	I	may	s afely	operate	my registered DJI	Phantom	3	Standard UAS	commercially	along	the	guidelines of	the	accompanying	operator’s manual, FAA	guidelines for	UAS	flight,	and

sa fety	guidelines	set	by	the AMA.

Proposed	UAS	and	Operations :

The	DJI	Phantom	3 Standard weighs	less	than	three	pounds,	will	always	be
fl own under	400	feet	limit ed	via	software	by	its	GPS ,	is	electrically powered by	a	lithium	ion	battery,	carries	no	fuel	o r	crew,	and	will	be transported	in

stora ge	to	and	from	all	flight	areas. The proposed	exemptions	would	allow me	to	operate	the	DJI Phantom	3 Standard UAS	for	commercial	purposes	of aerial	videography	and photography	as	a	service	to	public	and	business

inter ests,	including:	real

- estate photography	and	videography,	wedding	and private	individual	photography	and videography,	public	and	commercial photography	and	videography,	and	agricultural photography	andvideography.	Being	a current student	in Digital	Film	a nd	Video	Production

at New	England	Institute	of	Art	in	Brookline	MA ,	I	would	also	use	this	UAS

to produce	projects	for	my	classes,	the	products	of	which may	be	publ ished
in	local	area	businesses and	on	their	respective	websites.

Commercial	operation	of	a UAS which	are	equipped	with	camera(s)	and sensors,	would	provide	professional	services	in	the	following	areas: 1.	Aerial	photography	or	video	for	public or	private	use	including	real estate,	architecture,	land	surveying,	engineering	and	other	related prof essional	activities.
2.	Aerial	video or photography	for	public or	private	use	including	television, public	events,	cinematography	and	newsgathering. 3.	Aerial	inspection/photography	of	residential/commercial	structures

under	contract	with	the	owners	or	l ocal	government	authority. 4.	Aerial	inspection/photography	of	residential/commercial	utility infrastructure	including	but	not	limited	to	electrical	power	lines,	wind
turbines	and	cell	towers. 5.	Aerial	video/photography	or	providing	live	video	feed	to	a ssist	with search	and	rescue	operations	in	cases	of	an	emergency	or	natural	disaster only	when	the	local	authorities	or	government	has	requested	it. 6.	Training	to	persons	individually	o r	belonging	to	both	private or	public organizations	to	increase	aware ness	and	improve	safety	for	c urrent	and future	UAS	operations

.

Specific	section(s)	of	14	CFR	which	I	seek	relief	and	the	reason(s)	I	seek
relief:

14	C

. F

. R.	Part	21:	Airworthiness	Certificates

Given	the	size	and	limited	operating	area	associated with	the UAS	to	be utilized,	an exemption	from	Part	21	meets	the	requirements	of	an equivalent	level	of	safety	under Part	11	and Section	333	of	the	Reform	Act.

14	C.F.R.	45.23 (b) :	Display	of	marks:	general

The DJI	Phantom	3 Standard does	not	have	a cabin,	cockpi t,	pilot	station, fuselage,	boom,	or	tail	on	which	to	mark	large	words,	numbers,	or	phrases,I	request exemption	from	the	above	regulation.	However I	will	affix	a small decal	to	the	outside	body of	the	UAS	indicating	my UAS	registration
number issued	by	the FAA,	name,	and	address

.

14	CFR.	61.1 13(a)	&	(b):	Private	pilot	privileges	and	limitations:	Pilot	in
command

Under	§	61.113	(a)	and	(b),	certified	private	pilo ts	are	limited	to
noncommercial operations.	However,	I	am	able	to	achieve	an	equivalent
level	of safety	through	current FAA	regulations	of	UAS	operation	and	AMA safety	guidelines	without	such	a	certification	because	of	the	above mentioned	safety features	of	the	DJI	Phantom	3.	A dditional	manned	airship experience	of	a	commercially	certified	pilot would not	correlate	to	the

airm anship	skills	necessary	for	operations of	a	UAS. B earing	any	pilot
certification	or	license	will	not	ensure	remote piloting	skills	of	a	UAS; given the	DJI	Phantom’s	safety features, limi ted	range	and	speed	of	the	UAS, the

ris ks	of	o perating	this	UAS	are less	than	the	ris k	levels in	commercial

activ ities	with	traditional	aircraft.

14	C.F.R	91.7 (a) :	Civil	aircraft	airworthiness

Currently	there	is	no	certificate	applicable	to	this	UAS, and	therefore it	will be	up	to myself, Torin	Johns on ,	to	determine	the	airworthiness	of	the	DJI
Phantom	3 Standard in	accordance with	i ts operating	manual. P re	and	post
fl ight	inspections	of the	propellers,	motors,	frame,	landing	stands, camera and	gim bal	unit,	connected	tablet devices,	a	compass	calibrati on	a nd properly	ensured	GPS	locks indicated	by	the	DJI Phantom’s	display	of	“Safe to	Fly”	message	will	be performed	before	and	after	every fl ight,	accurate
records are	automatically	saved	within	the	DJI	pilot	application	and	can	be accessed	at	any	time .	The se	records	will	be	dated	and	will	include	the	total flight	time	of each	flight.

14	C.F.R.	91.9	(b)(2).'	Civil	aircraft	flight	manual,	marking,	and	placard requirements

Since no	pil ots	or	passengers	on	board	this aircraft,	and	given	its	size,	this regulation is	inapplicable.	An	equivalent	level	of	safety will	be	achieved	bymaintaining	a	safety/fl ight	manual	with	the	operator. In	addition	to the official	safety/flight	manual	provided	by	DJI	upon	purchase	of	the	Phantom

3 Standard

, following	the	AMA	guidelines	f or	safe	flight	operations	and	the FAA	regulations	for UAS	operations	will	ensure	a	high	level	of	safety.

1 4	C.F.R.	91.119(c ):	Minimum	safe	altitudes

I,	Torin	Johnson, will	ensure	that	the	UAS	does	not	oper ate	any	higher	than
400	feet	at ground	level	by	se tting	the	maximum	altitude	at	400	feet	in	DJI’s pilot	application	and ensuring	this	is	set	before	each	flight	as	part	of	the

pre

- flight	inspection.	I	will	not	fly over	congested	areas	or	directly	above unprotected	people	or	moving	vehicles. All	operations	wil l	be	planned before	hand	for	proper	flight	safety	and	proper	hei ght	analysis as	to	avoid
collisions.	The	GPS	and	barom etric	sensors	equipped	on	the	DJI Phantom	3
will	ensure accurate	altitude	readings,	the	output	of	which	will	be	fed	to	my
tablet	device	in real	time as	I	operate	the DJI	Phantom	3	Standard

.

1 4	C.F.R.	91.121:	Altimeter	settings

The	DJI	Phantom	3 Standard utilizes	the	latest	GPS technologies	as	well	as	a
barometric	sensor	with	live	data feed	directly	to	the	tablet linked to	the

transmitter.	A n equivalent	level	of	safety	and	accurate	altimeter readings will	be	achieved	by	using	this.

14	C.F.R.	91. 1 51(a)(1 ):	Fuel	Requirements for fl ight	in	VFR	conditions

Lithium	ion	batteries	that	are	made	by	DJI	specifically	for	this	particular	UAS power	the	DJI	Phantom	3 .	They provide	no	more than	25 minutes	of	flight

time. Due to	the	limitations	of	the	batteries,	it	is	currently impossible	to

comp ly	with	part	91.151.

14	C.F.R.	91.203(a)	and	(b):	Civil	aircraft:	Certifications	required Currently,	there	are	no	procedures	for	providing	ai rworthiness	certificates
for	the mentioned	UAS.	I,	Torin	Johnson ,	ho wever	will fly	safely	while having	the manuals	o f	the	DJI	Phantom	3	and	abiding	by	FAA	regulations	for UAS	operation	and AMA	safety	guidelines.14	C.F.R.	91.405	(a):	Maintenance	R equired 14	C.F.R.	91.407	(a)(1 ):	Operation	after,	maintenance,	preventive

maintenance ,	rebuilding,	or	alteration.

14	C.F.R. 91.409(a)(1) and	(2):	Inspections

&

I4	C.F.R.	91.417 (a)	and	(b):	Maintenance	records

Maintenance and inspections	may	be	required	and	should	be	granted	since they	apply	to aircraft	with	an	airworth iness	c ertificate.	However	I,	Torin
Johnson ,	will	perform	both preflight	and	post fl ight	inspections	of	the	UAS before	and	after	each	flight. I,	Torin	Johnson ,	will	also	follow	manufacturer
recommendations and	keep	a	written	record	of	any	maintenance	done	to
the UAS.

Public	Interest	and	Public	Safety:

Aerial	photography	and	videography allows	for	a	more safe,	cost	effective, and	environmentally friendly	meth od	to	capturing	imagery	than manned
aircraft s and	helicopters. Manned	aircrafts are	expensive	to	operate	and

m aintain,	create	a	high	level	of	noise, require	high	level	of	experience, and
are	much	more	hazardous	due	to	size	and combustible	fuel, especially	if
fl own	at low	heights

. I,	Torin	Johnson ,	in	addition	to	using	my	UAS	for	commercial uses,	will	also offer	my services	free	of	charge	upon	request	and	with	proper	coordination to	any	official search	and	rescue	or	emergency	services	organization. Use	of a	UAS	as	opposed	to	manned	aircrafts for	aerial	videography	or photography	reduces carbon	emissions	and	traffic	co ngestion	by vehicles looking	to	View	prope rties	such	as	real

- estate	or	farm land,	and	increase visibility	to	local	attractions; bolstering	local	commerce	and even tourism.

Given	that	there	is	no	fuel	and	no	crew	on	this	UAS, and th at	it	weighs
under	three pounds ,	as	well	as	having	a	low	maximum	speed	(less	than 25mph),	safe operation	of	this	craft	does	not	pose	any	immediate	danger	to the	environment,	wildlife, infrastructure	or	people.	DJI	has	a	“No	Fly	Zone” for	major	cities	and	points	of interest	that	h ave	registered	as	a	“do	not	fly zone.”	Operation	of	the	Phantom	3 Standard cannot happen	in	these locations,	as	any	flight	capabilities	becomes	blocked	by	the	UAS	itself	ifwithin	range	and	the	operator	is	notified of	the	restricted	zone .	Given	its GPS	and	g round sensing	capabilities, a	failsafe	“Return	To	Home”	mode	will safely	return	the	craft	to	the	operator	at	the	push of	a button	when	the craft	is	operating outside	of	its	transmitter’s	range. This	ensures	that	the
craft	will	not	remain	airborne	in unsafe conditions	and	pose	any	public danger. The	UAS	will	also	“Return	To	Home”	if	battery	life	depletes	to	a significantly	low	level.

Summary

I, Torin	Johnson ,	am	seeking	exemption	from	the	following	rules:

14	C.F.R.	Part	21 14	C.F.R.	45.23(b)

14	C.F.R.	61 .113(a)	and	(b) 14	C.F.R.	91.7(a) 14	C.F.R.	91.9(b)(2) 14	C.F.R.91.119(c)

14	C.F.R.	91.121

14	C.F.R. 91.151(a)(1) 14	C.F.R.	91.203(a)	and	(b) 14	C.F.R.	91.405(a) 14	C.F.R.	91.407(a)(1) 14	C.F.R.	91.409(a)(1)	and	(2) 14	C.F.R.	91.417(a)	and	(b)

With	the	ex e mptions	of	the	mentioned	rules	I

, Torin	Johnson ,	will	be seeking	to make	my	UAS	photography	and videography	services	available	to public	and commercial	interests.	Alternatively,	public	and	commercial interests	had	previously	sought the	use of	mann ed	aircr aft	to	achieve	what I	can	offer	in	a	safer,	more	cost

- efficient	manner	by	flying	at	safe	heights
and strictly	following	the	recommendations	from	D JI	and	safety	procedures put	in	place by	the AMA

. These	include	but	are	not	limited	to:

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	ea ch	operational	flight	will	be	25 minutes. 4.	Flights	will	be	terminated	at	15%	battery	power	reserve. 4.	Flights	will	be	operated	at	an	a ltitude	of	no	more	than	400	feet	AGL 5.	UAS	operator	will	be	trained	and	certified	in	the	proper	safety	and operations	of	the	UAS. 6.	The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the
Procedures. 7.	The	operator	will	post	advisor	noti ce	around	the	controlled	area. 8.	The	operator	will	have	been	trained	in	operation	of	UAS	generally	and received	up

- to

- date	information	on	the	UAS	to	be	operated	as	required. 9.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have

c apability	to	return	to	a	pre

- determined	location	within	the	Security
Perimeter	and	land. 10.	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted obstacles	or	emergencies.

T hank	you	for	your	time	and	effort	in	processing	this	request	and	look
forward	to cooperating	with	the	FAA	in	its	continued	commitmen t	for	the safe	operation	of	UAS.

Sincerely,

Torin	Johnson
3	Church	S t Andover,	MA 01810 TMJohnson1291@gmail .com 978

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