EAGLE EYE DRONE SERVICES, LLC

3608 Green Acres RD

Metairie, Louisiana 70003

MICHAEL KEITH, Principal Operator

Tel: 504.236.8105

NOLAJET@GMail.com

United States Department of Transportation

Federal Aviation Administration

Docket Operations, M-30

1200 New Jersey Avenue, SE rm W12-140 west bldg

Washington, DC 20590-0001

DRONE REGISTRATION COMPLETED 28 DEC 2015

REGISTRATION: FA3PLW7EPK

Filed in www.regulations.gov

RE: Petition for exemption of Eagle Eye Drone Services, LLC under Section 333 of 

the FAA Modernization and Reform Act, 49 U.S.C. 44701(f) and 14 CFR Part 11.

Gentlemen and Ladies of the Federal Aviation Administration,

 Eagle Eye Drone Services, LLC (hereinafter referred to as EEDS, LLC), 

(Michael Keith, Principal) would please be considered for exemption to operate a 

DJI PHANTOM 3 PRO UAS for the purpose of :

Aerial Videography and Photography, Inspection and Survey of:

Real Estate

Construction Sites

Oil Field equipment, including well head inspection and drilling sites

Law Enforcement assistance

News Media assistance

Government facilities inspection

Security

Closed set filming for the motion picture and television industry

et al

note: we specifically petition for closed set filming as this is a major industry in 

southeastern Louisiana and we strongly feel that we have the background and 

expertise to be the safest operator in this area 
INTRODUCTION

 Principal Operator and owner of EEDS, LLC is myself, Michael Keith, who 

currently holds an Airline Transport Pilot rating with three aircraft type ratings 

and a current First Class Medical and is on this date employed as a Part 121 

Airline Captain and CheckAirman with over 22,000 hours. I have spotless flying 

and driving records. I also hold current CFII/MEI flight instructor ratings 

including Ground Instructor. (certificate 3302288)

 

Safety is my profession

Specific Regulations from which relief is requested:

14 CFR §§ 

61.23(a) and (c), 

61.101(e)(4) and (5), 

61.113(a), 

61.315(a), 

91.7(a),

91.119(c),

91.121,

91.151(a)(1), 

91.405(a), 

91.407(a)(1), 

91.409(a)(1) and (2), and

91.417(a) and (b)

OUR OPERATIONAL COMMITMENT

1. EEDS, LLC will only operate when weighing less than 55 pounds including payload. 

2. EEDS, LLC will not operate any UAS at a speed exceeding 87 knots (100 miles per hour).

3. EEDS, LLC will only operate at an altitude of no more than 400 feet AGL.

4. EEDS, LLC will only operate within visual line of sight (VLOS) of the PIC at all times.

5. All EEDS, LLC operations will utilize a visual observer (VO). The UA operate within the visual line 

of sight (VLOS) of the PIC and 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. 
6. If an EEDS, LLC UAS has undergone maintenance or alterations that affect the UAS operation or 

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

flight prior to conducting further operations under this exemption. 

7. EEDS, LLC is responsible for maintaining and inspecting the UAS to ensure that it is in a condition 

for safe operation. 

8. Prior to each flight, the EEDS, LLC PIC will conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection will account for all potential discrepancies 

including inoperable components, items, or equipment. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft will not fly.

9. EEDS, LLC will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and 

life limit requirements for the aircraft and aircraft components. 

10. Each EEDS, LLC UAS operated under this exemption will comply with all manufacturer safety 

bulletins. 

11. EEDS, LLC, will ensure the PIC will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or 

a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. 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. 

12. EEDS, LLC will not permit any PIC to operate unless the PIC demonstrates the ability to safely and 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures.

13. ALL EEDS, LLC UAS operations will be accordingly logged

14. ALL EEDS, LLC operations will be day VFR. No night operations or Special VFR (not to include 

COA) 

15. The EEDS, LLC UA will not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, 

the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued 

to the exemption holder.

16. The EEDS, LLC 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. 

19. If the EEDS, LLC UAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 

20. The EEDS, LLC PIC will abort the flight in the event of unpredicted obstacles or emergencies. 
21. The EEDS, LLC PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to operate 

after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater. 

22. Documents used by EEDS, LLC to ensure the safe operation and flight of the UAS and any 

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 aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

23. The EEDS, LLC UA WILL remain clear and give way to all manned aviation operations and 

activities at all times. 

24. The EEDS, LLC UAS will not be operated by the PIC from any moving device or vehicle. 

25. All EEDS, LLC operations will be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

26. 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. 

27. EEDS, LLC will seek the appropriate and applicable COA.

HOW THE OPERATOR WILL MAINTAIN AN EQUIVALENT LEVEL OF SAFETY

or

NO ADVERSE IMPACT TO SAFETY

Instruction, Training and safe integration to the environment within which we 

function. Additionally, 

 

Regarding the Unmanned Aircraft System

1. UAS Operational Safety and Public interest

 The UAS proposed by EEDS, LLC is an unmanned four-rotor, four-motor “quadcopter” 

manufactured by DJI. The UAS is under 45 pounds, will be flown at all times

under 400 feet AGL as measured by the UAS on-board GPS system, will be kept within line of

sight of the Pilot in Command (“PIC”), will have a separate safety Visual Observer (“VO”) at all

times in communication with and within 5 feet of the PIC, will be flown at all times at speeds of

40 miles per hour or less, will be flown at all times during daylight hours, always using Visual

Flight Rules (“VFR”) and within visual line of sight (“VLOS”), and never using first person

view by the PIC. The PIC will be able to use human vision unaided by any device other than

corrective lenses as specified by a current state-issued driver’s license. When required the PIC will 

provide the local Flight Standards District Office (“FSDO”) with notice of all of flight operations no 

less than 72 hours in advance of any intended flight. Each PIC will have a minimum of 10 hours in 
flight training in quadcopter operations (in conjunction with the required pilot certificate and 

medical) as well as a minimum of 8 hours class room instruction specific to the proposed UAS

and 10 take offs and landings within the prior 30 days. The PIC will conduct a full and complete 

inspection of aircraft prior to the initial takeoff of each flight.

2. UAS Preflight, Maintenance and Repair

 All will be accomplished and records maintained in accordance with the specific 

manufacturers procedures and protocol.

3. UAS Radio Frequencies for operations

 

 Controller and video transmission operate in the 2.400 - 2.483 GHz range

 Maximum transmitting distance is 2000 meters (never to exceed visual line of 

sight continuos visual contact)

Regarding the operation of the UAS

1. Area of operations and potential hazards

2. Proximity of airports

3. Visual line of sight operations

4. Closed set movie and television filming

5. Certificate of Waiver of Authorization (COA)

All will be maintained in accordance with FAA guidelines, regulations and 

requirements.

Regarding specifications of the UAS To be Operated:

DJI 3 Phantom Professional

 

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

Weight (Including Battery And Propellers) 1280 g ( 2.82 lbs) 

Diagonal Size (Including Propellers) 590 mm (23.23 inches)

Max Ascent Speed 5 m/s (16.4 FPS)
Max Descent Speed 3 m/s (9.8 FPS)

Hover Accuracy

• Vertical: +/- 10cm 

• Horizontal: +/- 1m 

Max Speed 16 m/s (35.8 MPH) (ATTI mode, no wind) 

Max Altitude Above Sea Level 6000 m 

Operating Temperature 0°C to 40°C 

Gps Mode GPS/GLONASS 

GIMBAL 

Controllable Range Pitch -90° to +30° 

Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER 

Operating Frequency 2.400 GHz-2.483 GHz 

Max Distance 2000m (outdoors and unobstructed) 

Video Output Port USB 

Operating Temperature 0°C- 40°C 

Battery 6000 mAh LiPo 2S 

Mobile Device Holder For tablet or phone 

Receiver Sensitivity (1%Per) -101 dBm ±2 dBm 

Transmitter Power (Eirp) 

• FCC: 20 dBm 

• CE: 16 dBm 

Working Voltage 1.2 A @7.4 V 

BATTERY CHARGER 

Voltage 17.4 V Rated Power Phantom 3 Professional 100 W

INTELLIGENT FLIGHT BATTERY 

Capacity 4480 mAh Voltage 15.2 V 

Battery Type LiPo 4S Energy 68 Wh Net Weight 365 g (12.9 oz)

Max Flight Time Approximately 23 minutes 

Operating Temperature -10°C to 40°C Max Charging Power 100 W

MONTHLY MAINTENANCE LOG 

month: year: UAS 

# 

Date Issue 

Discovered 

Date Issue 

Addressed 

Issue Description & 

Maintenance Conducted 

Maintenance Performed 

By: Print & Sign 

Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 
Vibration 

Dampening 

Other: 

UAS REGISTRATION: FA3PLW7EPK

Respectfully submitted this 28th day of December, 2015

Michael F. Keith 

EAGLE EYE DRONE SERVICES, LLC

3608 GREEN ACRES RD 

METAIRIE, LA 70003

EMAIL: NOLAJET@GMAIL.COM