/ 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington DC 20590 

January 8, 2015 

~ . : 

RE: Request for Exemption pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012 and 14 CF.R. Part 11 

Drone Photo and Video 

Julie van der KroefLLC 

88 Taunton Lake Road 

Newtown, CT 06470-1450 

(203) 491-2555 

iulievanderkroef@sbcglobal.net, 

This petition is being submitted on my behalf without legal counsel or consulting 

servtces. 

Pursuant to Section 333 of the FAA Modernization and Reform Actof2012, and 

14 C.F.R. part 11, Drone Photo and Video, a digital imaging service, hereby 

applies for an exemption from the Federal Aviation Regulations (F ARs) listed 

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

commercially in airspace regulated by the FAA so long as operations are 

conducted with and under the conditions outlined herein or as may be set forth by 

the FAA as required by Section 333. 

The requested exemption would permit Drone Photo and Video to pursue its 

commercial interests by providing services to clients using small advanced sUAS 

in the following areas: commercial and residential real estate, commercial and 

residential building progressions, bridge, tower and structure inspections, utility 

inspections, special events, local and national natural and man-made disaster and 

rescue servtces. 

ABOUT DRONE PHOTO AND VIDEO and Julie van der Kroef LLC: 
/Drone Photo and Video is based in Newtown, Cf. Julie van der Kroef is the sole 

' proprietor of this start up business, and is anticipating an abundance of opportunity 

and discovery in this new field of endeavor. Initial focus will be on the Real Estate 

and Contracting markets, however as the technology quickly proves its value, the 

business will branch out as needed into inspections, surveys and monitoring. My 

goal is to serve the needs of the public whenever and where ever I am needed. 

Search and Rescue emergencies will also be important to my business. 

SAFETY 

Safety is a fundamental core value in all Drone Photo and Video operations. Julie 

van der KroefLLC strongly believes the safe integration of sUAS's into National 

Air Space (NAS) is of the utmost importance and will adhere to any additional 

regulations imposed by the FAA in order to maintain the safety and security of the 

National Air Space (NAS). Therefore as an ambassador of this new technology, I 

will always strive to be an exemplary representative of proper sUAS integration 

into NAS for commercial purposes. 

PILOT IN COMMAND (PIC) 

In order to maintain and advance the necessary safety and security protocols of an 

emerging industry, I present my qualifications and procedures for safe flight with 

sUAS: 

1) I hold a Student Pilot Certificate and Medical Certificate Third Class GX1691394 dated 09/17/2015. 

2) I possess a valid driver's license in Connecticut, and hold a current United 

States Passport. 

--3)Ihave logged 25 hours of in-air flight instruction time pursuant to a sport 

pilot certificate, and completed the following maneuvers: pre-flight planning 

and procedures, airport operations, take-offs and landings, go-rounds, 

performance maneuvers, navigation, slow flight and stalls, post-flight 

procedures. 

4) I have studied the following subjects in ground school: FAA regulations, 

accident reporting to NTSB, use of aeronautical charts, radio comm 

procedures, recognition of weather situations, wind-shear avoidance, 

weather reports and forecasts, safe and efficient operation of aircraft, 

collision avoidance, effects of density altitude, wake turbulence, power-
·-

plants and aircraft systems, stall awareness, national airspace classifications, 

controlled versus uncontrolled airspace, and special use airspace. 

I am committed to operating my sUAS safely within the United States airspace 

as a trained student pilot. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Drone Photo and Video, Julie van der KroefLLC, requests exemption from the 

following regulations, as well as any additional regulations that may technically 

apply to the operations of the sUAS: 

14 CFR Part 21, Sub part H, 14 CFR 21.191, 14 CFR Part 27, 14 CFR sections ./---

45.23(b), 14 CFR 45.27 (a), 14 CFR Part 61.23(a) & (c), 14 CFR Part 

61.101(e)(4)&(5), 14 CFR 61.113(a)&(b), 14 CFR 61.315(a), 14CFR91.7(a), 

14 CFR 91.9, 14 CFR 91.103, 14 CFR 91.103, 14 CFR 91.105, 14 CFR 91.109, 

14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203(a)&(b), 14 

CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 

417(a)&(b ). 

14 CFR Part 21 Subpart H Airworthiness Certificates and Safety 

This part establishes the procedures for the issuance of an airworthiness 

certificate. While the FAA continues to work to develop airworthiness 

standards for UAS, I request an experimental certificate be issued for the DJI 

Phantom 3 Professional . Previous exemptions have been granted by the FAA 

in the roto-craft UAS Section 333 approval process. 

The DJI Phantom 3 Professional is the latest model in its class from DJI, a 

worldwide leader in technologically advanced small roto-craft, and it is equipped 

with highly advanced control and navigational features to fit within the prior safety 

requirements set forth by the FAA. This aircraft features a built-in stabilized HD 

camera and GPS safety features which limit not only the height at which it files but 

also the radius from the pilot. It includes programs that exclude operations within 

designated Class B, C, and D airspace including a no-fly zone feature. Should the 

battery level get below safe level, or the communication between the pilot and the 

UAS be lost, the unit has a failsafe feature that returns it to its point of take-off to 

safely land without incident. 

14 CRF Airworthiness Standards: Normal Category Roto-craft 
.. • 

Since the sUAS is not a normal roto-craft as described in this regulation, this 

regulation does not apply, therefore I request an exemption from 14 CFR 27. 

14 CFR 45.23 (b) Display of Marks & 14 CFR 45.29 Size of Marks & 14 CFR 

45.27(a) Location of Marks 

The UAS will not have an airworthiness certificate, but as required by the 333 

Exemption, it will be registered and have its own "N" number permanently applied 

as prominently as possible. 

14 CFR 61.23 (a) (c) Medical Certificates: Requirements and Duration 

I, Julie van der Kroef LLC, possess a valid FAA student pilot medical certificate, ~~--

and current Connecticut driver's license, as well as a United States Passport. 

14 CFR 61.101 Recreational Pilot Privileges & Limitations, 14 CFR 61.113 (a) 

& (b) Private Pilot Privileges & Limitations: Pilot in Command, 61.133 

Commercial Pilot Privileges & Limitations. 

The PIC requirements stated in the 333 Exemption state the UAS PIC must hold 

eithera private, commercial or sport pilot's license to operate the sUAS for 

commercial purposes. Because the sUAS will not carry pilot or passengers, is 

remotely controlled, and the area of operation is controlled and limited, the level of 

risk is greatly diminished from a traditional aircraft. Therefore I, Julie van der 

KroefLLC, request an exemption from these regulatory requirements. 

14 CFR 61.315 (a) (c) (2) (3) Privileges & Limits of My Sport Pilot Certificate 

Drone Photo and Video, Julie van der Kroef LLC, requests exemption from these 

parts of this regulation. 

14 CFR 91.7 Civil Aircraft Airworthiness 

Drone Photo and Video, Julie van der Kroef LLC, requests exemption from this 

regulation since no such certificate will be necessary for the Dll Phantom 3 

Professional Drone. The sUAS will be inspected and tested prior to each flight. 

14 CFR 91.9 Civil Aircraft Flight Manual, Marking and Placard . 

Requirements AND 14 CFR 91.203 (a) & (b) Civil Aircraft: Certifications 

Required 
Drone Photo and Video, Julie van der KroefLLC, request exemption from these 

regulations, as the manual for the Dll Phantom 3 Professional will be with the PIC 

at the ground control station 

14 CFR 91.103 Preflight Action 

As the PIC in command of the sUAS, the following will apply to all flight plans: 

Pre and post-flight checklists will include inspection of all of the sUAS parts 

and systems. 

Preflight safety assessments including weather conditions and other areas of 

concern regarding environment of flight. 

Obtain proper clearance of National Air Space, and proper permission of 

land use. 

Manage spectator safety at all times. Keep proper documentation available. 

Follow manufacturer's recommendations for maintenance, overhaul, 

replacement, inspection, and life limit requirements for aircraft and parts. 

Drone Photo and Video will only conduct operational flights under ideal 

visual meteorological conditions (VMC) and within visual line of sight 

(VLOS) only. No flights to exceed 87 knots (100 miles an hour). No flights 

over 400 AGL. No flights at night. No flights within five miles of an 

airport. No flights if visibility is less than 3 statute miles. No flights in or 

over populated areas. 

Maximum flight times will be determined by the battery life, landing with 

20% reserve. 

The sUAS will weigh less than 55lbs. fully loaded with cameras, lens and 

gimbal. 

The minimum crew will include PIC and sUAS visual observer. 

14 CFR Flight Crew Members at Stations 

This regulation does not apply, so Drone Photo and Video requests exemption. 

\ 
14 CFR Flight Instruction; Simulated instrument light and certain flight tests 

The sUAS ground-based control station consists of a hand-held radio transmitter 

which can be operated by both student and instructor for a "hands-on'' learning 

experience. This technique meets the intent of 91.109 and provides an equivalent 

level of safety. 

14 CFR 91.119 Minimum Safe Altitudes: General 

This regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to a person, vessel or structure. Exemption is 

requested because the typical mission of the sUAS would be photography or 

survey and it would be necessary to operate closer than the 500 feet listed. 

14 CFR 91.121 Altimeter Settings 

This regulation requires the aircraft shall maintain cruising altitudes by reference to 

an altimeter setting available within 1 OONM of the aircraft. Since the sUAS will 

always fly below 400 feet AGL and will not be cruising in airspace with 

conventional aircra~ a collision hazard does not exist. An AGL altimeter is 

transmitted via radio from the sUAS on-board computer to the display screen held 

by the PIC, which provides a constantly updated AGL readout. 

14 CFR 91.151 (a) Fuel Requirements 

Drone Photo and Video requests exemption to the word "fuel'' and ask instead for 

the word "energy" (i.e. battery power). As PIC, I will ensure proper battery power 

reserve as recommended by the manufacturer. 

14 CFR Subpart E 91.401 - 91.417- Maintenance, Preventive Maintenance, 

Alterations 

As the PIC, I will ensure that routine maintenance and inspections of the aircraft 

will be performed before the aircraft is returned to service. I will ensure airworthy 

condition prior to each flight, and at two hour intervals during use. I will perform 

routine repairs by replacing worn propellers, checking electrical connections, 

updating software and firmware for the on-board computer, and other 

recommended procedures from the manufacturer. Additional work will be 

performed by a certified repair center, or the manufacturer itself. A written pilot's 

log will be kept of all such maintenance. 
IMP ACT ON THE PUBLIC - The use of the unmanned aircraft system in lieu of a 

manned aircraft will enhance safety and reduce environmental impact compared to 

similar operations conducted with much larger, fuel laden manned aircraft. The 

use of U AS to facilitate commerce can help encourage economic growth. It is in 

the interest of the public to grant exemption to Drone Photo and Video, Julie van 

der KroefLLC. 

PROPOSED UAS FOR EXEMPTION 

Drone Photo and Video, Julie van der Kroef LLC, proposes to use the DJI __.--

Phantom 3 Professional for commercial photography and videography. It is at this 

time I formally ask for exemption. I request approval to update the DJI series 

systems software and hardware within the parameters of imposed FAA regulations. 

Thank you for your consideration, 

Julie van der Kroef LLC 

Drone Photo and Video 

88 Taunton Lake Road 

Newtown, CT 06470 

(203) 491-2555