John Desmedt 

5099 Rock Springs Rd 

Warrenton, VA 20187 

571-439-5386 

Subject: Petition for exemption under Section 333 

Purpose: To safely integrate UAS for aerial real estate photography below 200ft AGL. 

Anticipated start date: 17 OCTOBER2015, pending COA 

UAS Platform: Dll Phantom 3 Professional. Operator's manual attached. 

Dll Phantom 3 Professional UA design specifications (more detail available in attached manual): 

• Weight: 2.82lbs (including camera) 

• Size 22.33 inches 

1. Safety 

Safety features: 

• Fail-safe return-to-home when control signal is lost. 

• Flight recorder. Flight data from each flight to the on-board storage device. Data 

includes telemetry, aircraft status information and other parameters. 

• GPS enabled 

• Vision positioning system 

• Barometer 

• Onboard compass 

• Battery indicator light 

• Redundant control system 

• Intelligent flight battery 

Aircraft limitations: 

• Max ascent speed 16.4 ft/sec 

• Max decent speed 9.84 ft/sec 

• Vertical hover accuracy 4 inches 

• Horizontal hover accuracy 5 ft 

• Max speed 3 1 knots 

• Max altitude 19,000ft (All flights will be limited to <200' AGL) 

• Max flight time 23 minutes 

During all UAS operations, safety will remain the number one priority. No flights will occur in 

congested areas or above people. All flights will be limited to within subject property 

boundaries for aerial photographs and the UA will not exceed 200' AGL. Flights will be limited 
to line of sight with PIC and only take place in VFR conditions. The UA is not water resistant 

and will only be flown in good weather. 

Pre-flight checklist: 

0 Remote controller fully charged 

0 Flight battery fully charged 

o Mobile device fully charged 

0 Four propellers mounted correctly and firmly 

0 Micro-SD card has been inserted 

0 Maximum altitude set to 200' AGL 

0 Maximum distance fi·om controller set to 400' 

0 Gimbal is functioning normally 

0 Motors start and function normally 

0 Dll Pilot app is successfully connected to the aircraft 

0 Compass calibrated 

0 Strong GPS signal acquired 

0 Timer set for 15 minutes 

Take-off 

0 Start timer 

0 Climb to 5' AGL and hover 

0 Rotate clockwise 360 deg 

0 Rotate counter-clockwise 360 deg 

0 Confirm GPS signal 

Inflight 

0 Maintain visual with U A at all times 

0 Check battery status 

o Confirm GPS signal 

Return and land 

0 After 15 minutes of flight or 20% battery power remaining, whichever comes first, land 

2. Inspections and maintenance. Inspections will occur before and after each flight. User 

level maintenance will be conducted as necessary to ensure safety. Repairs will be made by 

manufacturer. 

3. Radio Frequencies. Operating frequency range is 2.400-2.483 GHz 

4. PIC qualifications. 

a. I will be the sole PIC for the UAS 

b. A minimum of one observer/assistant will be present during flights 

c. Private pilot's license, certificate number 3570473- not addressed by 

manufacturer 

d. Zero hours with DJI Phantom 3 -No flight experience required according to 

manufacturer 
e. I have 40+ unlogged hours with other remote controlled vehicles including fixed 

and rotary wing aircraft 

5. Medical requirements. 

a. Not addressed by manufacturer 

b. I have a current third class medical certificate 

6. UAS intended operations. 

a. The DJI Phantom 3 Professional is a UAS designed for a novice level operator for 

aerial photography. 

b. I will use it system for its intended purpose. 

7. Flight operations. Self-imposed constraints: 

a. Time of operations: Daytime only 

b. Maximum operating altitude 200' AGL 

c. Maximum operating speed 10 knots 

d. Minimum visibility 3 miles 

e. Minimum distance from clouds: 500 ft below (will not fly if ceiling is less than 

1000') 

f Maximum wind speed: 10 knots 

g. No property with less than 0.25 acres will be photographed using the UAS. 

h. If a helicopter or other low-flying aircraft is sighted during flight, the UA will be 

moved out of the flight path and landed as soon as safely possible. 

8. Intended flight area. 

a. All flights will take place within 25 mile radius of my home address. 

b. Each flight will be limited to within the property boundaries of the subject 

property. 

c. No flights will be take place over populated areas. 

d. Each home owner will provide written authorization for aerial photography prior 

to flight. 

9. Proximity to airports. 

10. VLOS. 

a. No flight operations will take place within 5 miles of an airport 

b. I am aware of the IAD SFRA 

a. PIC will maintain visual line of site with the aircraft at all times 

b. If it is determined prior to flight that maintaining VLOS will not be possible, 

flight will be canceled 

c. My priority is safety. My intent is to safely take aerial photographs and safely 

recover my U A after each flight, with no effect to the local population. 

Maintaining VLOS at all times is the key task to accomplish my intent. 

d. Buildings and trees present the biggest hazard to maintaining VLOS. 

e. Choosing the proper ground location for the PIC will be the most important part 

of the flight planning process in order to mitigate risk. 
f The second risk mitigation is the Dll Phantom 3 Professional's built-in return-tohome function. If control communication is lost, the U A will return to its take-off 

point and land_ 

11. Pre-flight risk assessments and mitigation. 

a. Prior to conducting aerial photography, I will log a minimum of 5 hours of flight 

time in unpopulated areas to test the system and gain confidence in its functions 

and operation. 

b. Prior to each flight, a detailed map reconnaissance will be conducted to confirm 

feasibility and identify safety concerns. Satellite imagery with subject property 

boundaries will be printed out and on-hand, on-site. 

c. Once on-site, property boundaries from the satellite imagery will be verified and 

associated with geography. 

d. At no time will the UA be flown over roads 

e. Pre-flight checklist will be used prior to each flight 

Summary. Please consider my exemption request. My priority is safety. I understand that 

systems are imperfect and while deployed in Iraq and Afghanistan, many UAs crashed. I 

understand that is a risk, which is why I am imposing detailed risk mitigation controls including 

detailed planning prior to flight, pre-flight checks, maintaining VLOS at all times, operating 

below 200' AGL, only flying within subject property boundaries, obtaining written consent from 

homeowner, only flying in good weather, limiting flights to 65% of expected flight time or 20% 

of battery power remaining. I chose the Dll Phantom 3 Professional as my platform because I 

feel it provides the highest level of safeguards for safe flight operations.