Request for Section 333 Exemption Photography

April 20, 2014

by/for

Scott A. Hazzard

Aerial Answers LLC.

This document constitutes an exemption Request under Section 333 of the FAA Modernization 

and Reform Act of 2012 for Aviation Unmanned to perform Aerial Photography by/for Scott A. 

Hazzard. The use of this UAS would be utilized in aerial surveying, remote sensing, event 

photography/videography, agriculture purposes, real estate photography, aerial filmmaking 

and photography, construction site inspections and monitoring, Wildlife/ forestry monitoring 

and Educational and research operations. The UAS systems that I plan to use is a DJI PHANTOM 

3 and will be referenced in this document and also in the attached user manual. The Petitioner 

Requests Relief From the Following: Regulations from which the exemption is requested: 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. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 

(a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401 - 91.417)

1. The safe operation to the NAS and/or persons and/or property will be kept to a minimum 

by always flying the UAS within visual line of sight (VLOS), less than 200 ft above ground and 

never directly above persons or public places. The orientation of flights will be such that the 

pilot in command (PIC) always has a visual on the rear mounted LED flight Indicator. Additional 

safety features on the DJI PHANTOM 3 include, return to home, low voltage, enhanced failsafe 

along with operating in the less populated 5.8 GHZ frequency range. 

2. Pre-flight inspection would be checking battery condition/level in both the transmitter and 

UAS. The binding/link feature will not let the UAS start if communication is not established and 

the latest firmware installed. A check for power-lines, antennas and other overhead objects 

would be performed. Wind conditions would be monitored and be a factor for flying. 
3. DJI Phantom 3 e is equipped with a three-axis gimbals and using High-Def cameras. This sUAV

has a built- in capability to limit the height it flies above the ground, to limit the radius of the 

distance it flies from the operator and to exclude it from Class B, C and D airspace including a no 

fly zone feature. The Phantom also has the failsafe function of the Naza-M autopilot system 

which means when the communication between the Main Controller and the transmitter is 

disconnected, the outputs of all command sticks from controller will go to the center position. If 

the GPS signal is good enough, the system will automatically trigger Return to Home and will 

land safely.

4. The PIC will be only myself and I have a minimum of 60 hours flying time with the DJI 

Phantom 2 vision+ model and 30 hours with the DJI Phantom 3. I also have over 100 hours of 

flying time on various other models of quad copters and rotor craft. 

5. I am in good medical health and sound mental health. I have worked as a GIS Specialist II in 

the private sector for over seven years doing remote sensing, data collection and GIS analysis 

and have worked on many Federal and State government projects while employed in GIS.

6. The intended use of this DJI Phantom 3 is to expand my professional offerings and expertise 

in photography and GIS to include aerial image capturing and data collection. Through the use 

of the UAS and recent changes in the law I would like to deliver ortho mosaics, digital elevation 

models (DEM), contour maps and 3D renderings of existing structures to small and medium 

sized construction projects. This market sector would otherwise not be able to attain such 

data due to cost and such limited areas needing to be mapped from the more traditional 

method of aerial services such as helicopter or fixed wing aircrafts. To supplement this type of 

work I would like to offer some or all of the additional services listed in paragraph one. 

7. All photo flights for hire would have the date, time, GPS coordinates along with the camera 

metadata recorded on a hard drive and also backed up to a DVD. This data would be kept 

readily available for a period of 1 year after each aerial flight for hire. The sUAS will not be 

flown at night and never in the flight path of manned aircraft. The PIC (Scott A. Hazzard) will 

maintain visual eye contact on the craft at all times during flights. In the event of situations 

where an additional Visual operator is needed they will be in constant contact with the PIC for 

the duration of the flight. The DJI Phantom 3 will be programmed so that it will not be 

operated at an altitude of no more than 200 feet AGL in accordance with the guidelines 

stipulated under this COA application. The DJI Phantom 3 operated by the petitioner weighs 

less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). The sUAV will 

operate at speeds of no more than 50 knots, can 
hover, and can simultaneously move vertically and horizontally. Given the small size of the 

sUAS and the controled environments within which will operated under, the sUAS operations 

adhere to the Reform Act's safety requirements. My main objective is to offer a safe and cost 

effective means to supply contractors, realtors, first responders, and private individuals with 

aerial imagery that can help them in a positive manor at a greatly reduced risk to the general 

public and businesses alike. The petitioner (Scott A. Hazzard) will also file for a UAS Civil COA 

for mapping operations that might require flights greater than 200 ft. but less than 400ft.

Respectfully, 

Scott A. Hazzard

Aerial Answers LLC

scott@aerialanswers.com

(336) 207-8799