Sarah Vander Woude

674 Graafschap Rd

Holland, MI 49423

U.S. Department of Transportation,

Docket Operations West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Regarding: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part

11 of the Federal Aviation Regulations.

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, I, Sarah Vander Woude, hereby apply for an exemption from the Federal Aviation

Regulations (FARs) listed below to allow operation of my Small Unmanned Aircraft System (sUAS)

commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such

operations are conducted with and under the conditions outlined herein or as may be established by

the FAA as required by Section 333.

The granting of this exemption request will provide immediate benefit to commercial and residential

real estate industries, architectural firms, home builders, land developers, travel agencies, resorts, and

film production companies in need of aerial application both within and outside of the United States.

The use of UAS in industries such as these provides a more informational and enticing viewpoint, from

normally unreachable areas, with more efficiency and cost effectiveness than by airplane or

helicopter. Each of these industries require photo and video in order to advertise or market homes,

buildings and large areas of land or travel destinations and greatly benefit from a photo and video

service that can provide an experience encompassing larger areas, not achievable at the ground

level. With marketing and advertising achieving a higher level of service to potential buyers and

clients, there is a resulting increase in business that will ultimately help to accelerate the economy as

a whole. Countries outside of the United States will greatly desire and benefit from the content we

provide and are a part of; seeing increased tourist activity and advancement of economical growth.

The general public will benefit from safe and efficient services that are conservative to fuel, time,

emissions, noise etc. I desire to utilize the state-of-the-art DJI Phantom 3 unmanned aircraft system

(UAS) in accordance with laws and regulations regarding Unmanned Aircraft System (UAS) operations

conducted within the National Airspace System (NAS) and in compliance with the Standards of the

International Civil Aviation Organization (ICAO).

The name and address of the applicant is:

Sarah Vander Woude

674 Graafschap Rd

Holland MI, 49423

Email: SarahJVanderWoude@gmail.com
Phone: 708-646-8018

Regulations from which exemption is requested:

● 14 CFR 21, Subpart H –Airworthiness Certificates

● 14 CFR 45.23 (b), Display of marks; general

● 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

● 14 CFR 91.7 (a), Airworthiness required for operation

● 14 CFR 91.9 (b) (2), Civil Aircraft flight manual, marking, and placard requirements

● 14 CFR 91.103 (b) (2), Preflight action

● 14 CFR 91.109, Flight instruction

● 14 CFR 91.119 (c), Minimum safe altitudes

● 14 CFR 91.121, Altimeter settings

● 14 CFR 91.151, Fuel requirements for flights in VFR conditions

● 14 CFR 91.203 (a) and (b),Civil aircraft: Certifications required

● 14 CFR 91.405 (a), Maintenance required

● 14 CFR 91.407 (a) (1), Operation after maintenance

● 14 CFR 91.409 (a)(1) (2), Inspections

● 14 CFR 91.417 (a) and (b), Maintenance records

Unmanned Aircraft System

UASs are often seen as superior to helicopters or ground based aerial photography systems (i.e.

crane, bucket-truck) due to the smaller device, cheaper equipment, lower personnel costs, reduced

noise, and much smaller environmental impact which promotes public safety.

I, Sarah Vander Woude, am petitioning for an exemption to operate a DJI Phantom 3 with built-in HD

camera and GPS safety features which limits flight height capability (AGL), limits the distance of flight

from its operator, and excludes the sUAS from operation within designated Class B, C, and D airspace

including no-fly zones feature. The DJI Phantom 3 also has failsafe function that is triggered in the

event communication is lost between the sUAS and the main controller transmitter. In the event of

such transmission loss, the sUAS will return to its point of takeoff and land safely or within a distance

to the operator that transmission and control can be regained.

Procedures for Ensuring UAS Is In a Condition Safe for Flight:

Preflight Checklist: As a minimum, the following items will be checked prior to initiating an UAS

operation with DJI Phantom 3

1. Before Departing For Site

a. Aircraft and Remote Controllers fully charged

b. Tablets fully charged

c. Ensure Firmware is Updated on AC and RC

d. Cache location maps into all DJI Pilot App Devices
e. Check weather - Winds under 23 MPH or 10 mps, visibility for 3 statute miles, Cloud

layer above 500’

f. A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance

and not less than 48 hours prior to the operation.

2. Location On-Site Check

a. Operation is during daylight hours ( official sunrise to sunset, local time)

b. Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and

structures unless protective barriers or structures are present, or permission is

granted, or such operations present no hazard to the Pilot in Command, Camera

Operator and other essential persons.

c. Check flying area free of overhead obstructions including wires, low flying AC, trees,

tall buildings Weather meets conditions stated above

d. Confirm flight plan with camera operator

3. Physical Aircraft Check

a. Desired ND filter attached to camera

b. Camera locked in place

c. SD card in Camera

d. Motors Clear of Foreign Object Debris (FOD)

e. Check propellers for melting, misshapen or cracks

f. Propellers are hand tight

g. Prop locks are firmly attached and quick release plastic base has no cracks or fissures

4. Remote Controller Check

a. Antennas are oriented properly

b. Switch to P-GPS mode

c. Check battery level of RC for minimum 75% 6. DJI Pilot APP Check

d. Maximum flight altitude set = 400 Feet

e. Failsafe mode, Set for 10M clearance above lowest obstacle in flight plan

f. RC signal lost set to Return-to-Home

g. Check sensors

h. Acceleration between “-1.0 to +1.0”

i. Compass MOD between “1400=1599”

j. Check IMU

k. Image Transmission Channel set and stable

l. Battery Cells all 4.28V or greater, at least 98% battery, ensure no greater than .2V

between battery cells

m. Ensure enough satellites are locked on

n. Turn other devices on Airplane Mode

o. Face AC into the wind allowing for movement towards operator in case of emergency

p. Check heading of aircraft

q. Ensure home point is accurately set on map

Proposed Flight Operations:

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a

current FAA-published aeronautical chart, unless a letter agreement with the airport’s management is
obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as required

by the Certificate of Waiver or Operation (COA).

The UAS will be utilized for the following:

1. Aerial videography for public and/or private use including, but not limited to, marketing,

tourism promotion, residential real estate, commercial real estate, architecture, builders, land

developers, resorts, golf courses, events, film production and other related professional

activities.

2. Aerial photography for public and/or private use including, but not limited to, marketing,

tourism promotion, residential real estate, commercial real estate, architecture, builders, land

developers, resorts, golf courses, events, film production and other related professional

activities.

3. Aerial photography for public and/or private use including but not limited to television, public

events and other cinematography projects.

4. Aerial videography for public and/or private use including but not limited to television, public

events and other cinematography projects.

UAS Weight:​Under 55 lbs, approximately (2935g) 6 pounds 7.5 ounces

Proposed speed: ​Will typically be slower, between 5-25 MPH for better quality video and photo.

Altitude: ​Below 400 ft. Above Ground Level (AGL) provides adequate visual perspective or area and

structures to be surveyed (flight control systems will be set to limit altitude)

Flight Time:​Each flight will be 15 minutes or less. Flights will be terminated at 25% battery power

reserve or 30 minutes of flight time whichever occurs first.

Distances: ​The unmanned aircraft must remain close enough for the operator to be capable of seeing

the aircraft with vision unaided by any device. The UAS will not be operated less than 500 feet below

or less than 2,000 feet horizontally from a cloud when visibility is less than 3 statute miles from the

PIC. Operations will be aborted immediately if the PIC encounters unpredicted obstacles or

emergencies. Safe descent and landing procedures will be followed in accordance with operating

documents.

Area of Operation:​I will primarily operate in the state of Michigan, with ability to travel to any

approved location both in and outside of the United States, in compliance with NAS limitations and

requirements to operate a UAS around those areas in accordance with all applicable parts of 14 CFR

including, but not limited to, parts 45, 47, 61, and 91.

In conclusion, I respectfully request exemption under Section 333 to enable myself to operate

efficient, limited, low-risk commercial sUAS operations for the activities stated respecting at all times

the space and privacy of the public and its property, while maintaining airspace safety.

Respectfully,

/s/ Sarah Vander Woude