ADDENDUM TO 333 EXEMPTION

FIREFLY AERIAL PHOTOGRAPY SERVICES LLC

DOCKET#: FAA-2015-5548

Dear, Michael Cameron or FAA Official,

In response to the email on 1/15/2016 from Michael Cameron requesting additional information 

in the 333 exemption request for Firefly Aerial Photography Services Docket No. FAA-2015-

5548, I Daniel R. Otte Owner of Firefly Aerial Photography Services LLC do submit the 

following addendum of Aircraft make, model and type, to Petition # FAA-2015-5548:

The following Exhibits are added to this petition:

Exhibit 2 – Phantom 2 V2 User Manual

Exhibit 3 – Phantom 2 V2 Features

Exhibit 4 – Phantom 3 Professional specs

Exhibit 5 – E 384 Preflight procedures

Exhibit 6 – E 384 Pre Flight Checklist

Exhibit 7 - E 384 Flight Checklist

Exhibit 8 – Lancaster User’s Manual

Exhibit 9 – QR X900 Quick Start Guide

Exhibit 10 - MPTOM – Firefly Aerial Photography Services **

**Exhibit 10 will be submitted confidentially to 333exemptions@FAA.gov

I. Publishable Summary

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules: 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 

45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 

C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 

14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 

91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) 

to operate commercially a small unmanned aircraft system (UA) (6 lbs. or less).
Approval of the exemption requested by petitioner will allow commercial operation of 

1). Phantom 2 V2, rotorcraft 2) Phantom 3 Professional, rotorcraft, 3). Event 38 E384, 

Fixed wing 4). Precision Hawk Lancaster, fixed wing and 5). Walkera QR X900 rotorcraft 

sUAS for real estate photography, remote sensing to support (i) precision farming and other 

agriculture applications; (ii) asset management for utilities, government agencies, and private 

firms; (iii) construction and land management; (iv) disaster response and search and rescue; as 

well as (v) conducting research flights to collect data and establish and refine forensic processes, 

procedures, and tools for investigation of accidents and crimes involving UAs,(vi) real estate 

photography; and (vii) aerial cinematography photography for the motion picture/television 

industry and sports photography in Class G airspace or as otherwise prescribed in an ATO 

issued COA nationwide. The requested exemption should be granted because operation of small 

UAs, weighing no more than 55lbs. (24 kg.), inclusive of battery and payload, conducted in the 

strict conditions outlined below, will provide an equivalent level of safety, while still allowing 

commercial operations. The lightweight aircraft covered by the exemption are far safer than 

conventional operations conducted with helicopters and fixed-wing aircraft weighing thousands 

of pounds and carrying highly flammable fuel, and operating in close proximity to the ground 

and people. The seven factors Congress directed the FAA to consider when approving Section 

333 exemption petitions - size, weight, speed, operational capability, proximity to airports, 

proximity to populated areas, and operation within visual line of sight – each support the request. 

In particular, the aircraft are small, and will operate at slow speeds, and close to the ground in 

order to more safely and efficiently conduct operations that would otherwise involve a risk of 

death to the inspectors. The substantial increase of safety and decrease of risk to human life, 

coupled with the low risk use of UAs to conduct these operations, weigh heavily in favor of 

granting the exemption. 

II. Petitioner’s Contact Information 

Daniel R. Otte

Owner

Firefly Aerial Photography Services LLC

[FFAPS]

W3303 State Road 28

Sheboygan Falls, WI 53085

III. Proposed Operations

A. The UAs

The requested exemption will permit petitioner to operate 1). Phantom 2 V2, rotorcraft 2) 

Phantom 3 Professional, rotorcraft, 3). Event 38 E384, Fixed wing 4). Precision Hawk 

Lancaster, fixed wing and 5). Walkera QR X900 rotorcraft sUAS and will be operated as 

otherwise prescribed in an Air Traffic Organization (“ATO”) issued COA and all other FAA 

requirements. 
1. DJI Phantom 2 V2

The requested exemption will permit petitioner to operate the Phantom 2 V2, with a maximum 

weight of approximately 2.7 lbs. (1.2 kg), inclusive of batteries and technical payload. This 

rotorcraft operates at a speed of no more than 43 knots and has the capability to hover and move 

in the vertical and horizontal planes simultaneously. 

Please refer to Exhibits 2- for further information about the airframe, control system and 

transmitter. The FAA has previously reviewed these documents and approved exemptions for 

commercial use of the DJI Phantom 2 Vision+ in Exemption Nos. 11138, 11189, and 11191.

The UA will have the following specifications or equivalent:

Airframe: DJI Phantom 2 V2

Dimensions: diagonal motor-motor distance 350 mm (approximately 13.78 in.)

Flight Control System: DJI Naza-M V2, which includes the GPS and Compass and the internal

measurement unit (IMU), containing a built-in internal sensor and a barometric altimeter that

measures both altitude and attitude. 

Transmitter (Tx): 5.728GHz-5.85 GHz DJI Remote Control

Receiver (Rx): 5.8G receiver built in to the DJI Phantom 2 Vision+

Motor: electric DJI 2312 CCW

Data Link: 2.4 GHz USB ground modem

Video Link: 5.8 GHz

OSD: DJI Vision app, open on a dedicated mobile device, which allows live telemetry to be

displayed to the visual observer, including the battery level and altitude Batteries: Lithium 

Polymer batteries with capacity of 5200mAh 

Please refer to Exhibit 2-3 for further information about the airframe, control system and 

transmitter. The FAA has previously reviewed these documents and approved exemptions for 

commercial use of the DJI Phantom 2. 

2. DJI Phantom 3 Professional

The requested exemption will permit petitioner to operate the Phantom 3 Professional with a 

maximum weight of approximately 2.7 lbs. (1.2 kg), inclusive of batteries and technical payload. 

This rotorcraft operates at a speed of no more than 43 knots and has the capability to hover and 

move in the vertical and horizontal planes simultaneously. 

Please refer to Exhibit 4 for further information about the airframe, control system and 

transmitter. The FAA has previously reviewed these documents and approved exemptions for 

commercial use of the DJI Phantom 3 Professional.
The UA will have the following specifications or equivalent:

Airframe: DJI Phantom 3 Professional

Dimensions: diagonal size (including propellers) 590 mm 

Weight (including battery and propellers) 1280g

Flight Control System: DJI Naza-M V2, which includes the GPS and Compass and the internal

measurement unit (IMU), containing a built-in internal sensor and a barometric altimeter that

measures both altitude and attitude. 

Operating frequency: 2,400 GHz-2.483 GHz

GPS Mode: GPS/Glonass

Transmitter Power: FCC-20dBm, CE-16 dBm

Video Link: 2.4 GHz

OSD: DJI GO app, open on a dedicated mobile device, which allows live telemetry to be

displayed to the visual observer, including the battery level and altitude Batteries: Lithium 

Polymer batteries with capacity of 5200mAh 

3. Event38 E384

The requested exemption will permit petitioner to operate the Event 38 E384, with a maximum 

weight of 5.9 lbs. (2.7 kg.), inclusive of batteries and technical payload. This fixed wing aircraft

operates at a speed of no more than 26 knots. 

Please refer to 5-7 for further information about the airframe, control system and transmitter. The 

FAA has previously approved the E384 for commercial flight in Exemption No. 11166.

The UA will have the following specifications or equivalent:

Airframe: E384

Control System: ArduPilot Mega 2.6 autopilot, which includes the Main Controller (MC),

Internal Measurement Unit (IMU) with a built-in internal sensor, barometric altimeter (which

measures attitude and altitude), compass, GPS, and radio receiver (Rx).

Tx: Spektrum DX5E

Rx: AR 610 Receiver

Motors: Tiger T-Motor 3515-9

Data Link: 3DR 433mhz radio

OSD: Mission Planner software, visible on a dedicated ground station laptop, which allows live

telemetry to be displayed to the visual observer, including the battery level and altitude.

Batteries: Lithium Polymer batteries with capacity of 5000 mAh

3. PrecisionHawk Lancaster System

The requested exemption will permit petitioner to operate the PrecisionHawk Lancaster 
System. Please refer to Exhibit 8 for information about the airframe and control system, 

including the UA specifications, which are proprietary business information. The FAA has 

previously approved the PrecisionHawk for commercial flights in Exemption No. 11345.

4. Walkera QR X900

The requested exemption will permit petitioner to operate the Walkera QR X900 system. Please 

refer to Exhibit 9 for information about the airframe and control systems, including the UA 

specifications.

Airframe: QR X900

Weight: 6.95 kg (Battery included)

Main Controller: FCS-RX705

Landing gear: Retractable

Parachute: Yes (Dropsafe)

Thank You for your time and attention towards approval of this exemption.

Daniel R. Otte

Owner

Firefly Aerial Photography Services LLC

W3303 State Road 28

Sheboygan Falls WI 53085