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 FAA Regulations and certain parts of the FARs.

Dear Sir or Madam: Request: In order to provide safe and environmentally-friendly aerial videography and photography for public and business interests, I, Windell B Phillips JR, would like to formally submit for exemptions from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 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), so that I may operate the DJI Phantom 3 UAS along the guidelines of the accompanying operator’s manual as well as FAA guidelines for UAS flight. Background: I, Windell B Phillips Jr., am a commercially licensed pilot (FAA License Number 2847712), with over 15 years experience piloting multiple aircraft including the King Air 200, C90A, Embraer 145, ATR 72 & 42, and more. I have also operated remote controlled aircraft for over 10 years a hobby. My experience flying professionally puts me in a position to operate these sUAS systems with a high degree of of confidence that I am operating within all applicable local, state, and federal laws, with safety for persons and property my highest concern. Granting this Exemption Does Not Compromise Safety This particular UAS weighs less than three pounds, will always be flown under 400 feet, is electrically powered by a lithium ion battery, carries no combustible fuel or crew, and will be transported in proper storage to and from all flight areas (in accordance with FAA guidelines). These proposed exemptions would allowme to operate the DJI Phantom 3 Professional UAS for commercial purposes of aerial videography and photography as a service to public and business interests, including: real-estate photography and videography, wedding and private individual photography and videography, public and commercial photography and videography, and agricultural photography and videography. Pursuant to exemption No. 12045 (Viglianti), the FAA recently approved similar use of the DJI Phantom 3 UAS. These UASs have been proven reliable and safe flying machines managed by gyroscopically-stabilized flight, ground detection, GPS- aided navigation, a built-in compass, blinking LED lights, manual and automatic failsafe modes for returning to the controller, and propeller guards in order to protect both the UAS and the environment. This particular model combines state-of-the-art, proven technology with high quality manufacturing and user-friendly control to ensure safe operation and easy maintenance. Specific section or sections of 14 CFR which I seek relief and the reason I seek relief:

14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associated with the aircrafts to be utilized by I, Windell B Phillips Jr , an exemption from Part 21 meets the requirements of an equivalent level April 24, 2015 of safety under Part 11 and Section 333 of the Reform Act. Pursuant with Exemption No. 12045, “in all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed.” 14 C.F.R. 45.23: Display of marks: general Because the DJI Phantom 3 The UAS will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark words, numbers, or phrases, I request exemption from the above regulation.14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command Pursuant to Exemption 12045, “The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138.”

14 C.F.R 91.7: Civil aircraft airworthiness Currently there is no certificate applicable to UAS, and therefore it will be up to myself, Windell B Phillips Jr , to determine the airworthiness of the DJI Phantom 3 in accordance with its official operating manual. Pre-/ post-flight inspections of the propellers, motors, frame, landing stands, camera and gimbal will be performed before and after each flight, accurate records of which will be kept with the UAS’s storage and transportation system at all times. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements Pursuant to Exemption 12045, since there are “no pilots or passengers on board this aircraft, and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator.” 14 C.F.R. 91.119(c): Minimum safe altitudes I, Windell B Phillips Jr., will ensure that the UAS does not operate any higher than 400 feet at ground level. I will not fly over congested areas. I will plan operations before hand for proper flight safety and proper height analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings

The DJI Phantom 3 utilizes electronic GPS with a barometric sensor with live data output to the mobile device attached to the transmitter. An equivalent level of safety will be achieved by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditionsThe UAS that I will fly is electrically-powered by lithium ion batteries which are made by DJI specifically for this particular UAS. They are rated at no longer than 25 minutes of flight time. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, Windell B Phillips Jr. , however will always fly safely while having the manuals of the DJI Phantom 3. 14 C.F.R. 91.405(a): Maintenance Required, 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 & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However I, Windell B Phillips Jr, will perform both preflight and postflight inspections of the UAS before and after each flight as outlined in the operating documents. I, Windell B Phillips Jr, will also follow manufacturer recommendations from said operating documents.

Public Interest: Aerial photography and videography provided to the public allows for a more cost- effective and environmentally-friendly method to capturing imagery than its alternative: manned aircraft and helicopters. The latter are expensive, create lots of noise, and are much more hazardous due to size and combustible fuel. I, Windell B Phillips Jr, in addition to using my UAS for commercial endeavors, will also offer my services upon request and with proper coordination to any official search and rescue or emergency services organization to benefit the public. Given that there is no fuel and no crew on this UAS, that it weighs under three pounds and has propeller guards, 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, or people. Given its GPS and ground- sensing capabilities, a “return” mode will safely return the craft to myself, Windell B Phillips Jr, at the push of a button or automatically when the craft is low on power. This ensures that the craft will not remain airborne in unsafe conditions.The addition of UAS-controlled aerial video and photography provides both public and commercial sectors with an environmentally-friendly and cost-effective means by which to obtain photography and videography services. Because of this, an increase of commercial activity and a gaining of more detailed understanding of private and/or farm land would help local and area communities by: reducing pollution, risk, and operating costs by alternative aerial video and photography services such as manned airplanes and helicopters, reducing carbon emissions and traffic congestion by vehicles looking to view properties such as real-estate or farm land, and increase visibility to local attractions thereby bolstering local commerce and tourism. Summary I, Windell B Phillips Jr, 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), 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 exemptions of the mentioned rules I, Windell B Phillips Jr, will be seeking to make my UAS photography/videography services available to public and commercial interests. Alternatively, public and commercial interests had previously sought the use of manned aircraft to achieve what I can offer in a safer, more cost- efficient and environmentally-friendly manner by not using combustible fuel, flying at safe heights and strictly following the usage recommendations from DJI. These include but are not limited to:

" Flying the DJI Phantom 3 safely in accordance with its operator’s manual

" Always flying below 400 feet

" Thorough inspection of UAS before and after flights and keeping inspection records with the craft at all times

" Keeping the UAS in visual sight at all times when in operation

" Using an observer to assist if needed

" Remain safely clear of and do not interfere with manned aircraft operations

" Not intentionally fly dangerously over unprotected persons or moving vehicles

" Contact an airport or control tower before flying within 5 miles of their vicinity

" Not flying in adverse weather conditions such as high winds, rain, or impai redvisibility " Not flying under the influence of alcohol or drugs

" Ensure the operating environment is safe

" Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc.

" Check and follow all local laws and ordinances before flying over private property

" Do not conduct surveillance or photograph persons in areas where there is an expectation of privacy without the individual's permission Sincerely, Windell B Phillips Jr CEO AeroPro Videos 9390 Milbank Dr. Shreveport, LA 71115 (318)-470-1314 bophillips@me.com