US Department of Transportation

Federal Aviation Administration

800 Independence Ave S.W.

Washington DC, 20591

07.22.15

To Whom It May Concern:

I, Troy M. Malmstrom, have been flying UA's since 2010, my most recent experience is with the DJI

Phantom 3. I have been flying as a Hobbyist and now ready to bring my skills to a professional level for

three reasons; Cinematography for Golf Courses, Special Events and Real Estate/Architecture. In doing

so I consider all safety precautions and regulations as foremost with each flight.  

I seek exception from 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. §

91.121; 14 C.F.R. § 91.151(a); 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)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to

commercially operate.  

Golf Course Cinematography

I, Troy M. Malmstrom, considers safety and regulations as foremost with each flight. My small

unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph)

wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph) nor

will I fly my UA faster than 30 mph nor exceed the 400 foot limit. Built in safety systems include a GPS

mode that allows my UAS to hover in place when radio controls are released.  In addition, if signal with

the controller is lost the UAS will climb to a preset height and Return to Home (RTH).  With three modes

to choose from, I utilize the Smart Mode for aerial videography/photography. This is the safest, most

reliable and stable mode to prevent accident and hazard. When pilot communication is lost the UAS is

designed to slowly descend to point of take‐off. I do not operate my UAS near airports, Hospitals nor

Police heliports, I am also prepared to land/abort immediately to the nearest and safest ground point

that I have planned ahead of take‐off.  

Aerial footage of Golf Courses would help give the public a geographical awareness of the course before

playing. It helps Golfers improve their game when they have the ability to map out landing zones. Also

using my UA avoids the high risks in the use of a helicopter with fuel and persons on board.  

After consent of the Golf Course I, Troy M. Malmstrom operating the DJI Phantom 3, would first observe

the flight area for any mobile phone base stations, radio transmission towers, power lines or any other

electromagnetic interference that could disrupt flight. I would scan the area for any large buildings or

trees that may affect with GPS accuracy or flight. I then would make sure the weather is flight ready to

avoid wind speed exceeding 10m/s , snow, rain and smog also to be sure the UA and battery

performance is subject to safe air density and temperature. For safety, stability and fear of financial loss

I will not operate unless perfect conditions are present. I make sure I am outside the required 5 mile

radius of any airports and to stay under 400 feet from ground.  
Next I would then coordinate a safe fly time where all Persons and property are in safe distance from my

UA during take‐off and flight. Lastly I would go through my normal maintenance and pre‐flight Checklist;  

1. Remote controller, aircraft battery, and mobile device are fully charged.  

2. Propellers are mounted correctly and firmly.  

3. Micro‐SD card has been inserted if necessary.  

4. Gimbal is functioning as normal.  

5. Motors can start and are functioning as normal.  

6. DJI Pilot app connected to the aircraft.  

Then following up with flight test procedures;  

1. Place the aircraft on open, flat ground with battery indicators facing towards me.  

2. Power on the remote controller and your mobile device, then the Intelligent Flight Battery.  

3. Launch the DJI Pilot App and enter the Camera page.  

4. Wait until the Aircraft Indicator blinks green. This means the Home Point is recorded via GPS  

5. Calibrate the compass flight location.  

6. Push the throttle up slowly to take off  

7. Shoot photos and videos using the DJI Pilot app.  

8. To land, hover over a level surface and gently pull down on the throttle slowly to descend.  

9. After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or

more until the motors stop.  

10. Turn off the Intelligent Flight Battery first, followed by the Remote Controller.  

Special Event Cinematography

Capturing those perfect moments during a special event is important. Capturing it with aerial

cinematography will help give the host a professional recording to relive their special moments without

the dangers and expenses of a manned fixed wing aircraft or helicopter.  

Recording Special Events would be taken care of delicately with my UA. Firstly I, Troy M. Malmstrom,

would observe the flight area for any mobile phone base stations, radio transmission towers, power

lines or any other electromagnetic interference that could disrupt flight.  I would scan the area for any

large buildings or trees that may affect with GPS accuracy or flight. Lastly, I would make sure the

weather is flight ready to avoid wind speed exceeding 10m/s , snow, rain and smog also to be sure the

UA and battery performance is subject to safe air density and temperature.  Second go through the PRE

FLIGHT CHECKLIST/maintenance and FLIGHT TEST PROCEDURES as normal in a secure area safe from

persons and property. Thirdly capturing film from a safe distance from persons and property avoiding all

crowds and hazards.  

Real Estate/Architecture

Arial cinematography in the housing market has been around for a long time through manned fixed wing

aircraft and helicopters. For small budget real estate companies and average homeowners the expense

of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury
homeowners can afford to absorb such expense. Depriving non‐luxury homeowners and lower budget

Realtors from a valuable marketing tool. Also using my UA avoids the high risks in a helicopter with fuel

and persons on board.

  

To make sure the operation will be safely conducted Firstly I, Troy M. Malmstrom, would observe the

flight area for any mobile phone base stations, radio transmission towers, power lines or any other

electromagnetic interference that could disrupt flight. I would scan the area for any large buildings or

trees that may affect with GPS accuracy or flight. I'd make sure the weather is flight ready to avoid wind

speed exceeding 10m/s , snow, rain and smog also to be sure the UA and battery performance is subject

to safe air density and temperature. Second go through the PRE FLIGHT CHECKLIST/maintenance and

FLIGHT TEST PROCEDURES in a secure area safe from persons and property. Thirdly capturing film from

safe distance from persons and property avoiding all hazards.  

DJI Phantom 3 Specs

Diagonal Size: 590mm (including propellers)

Weight: 1280 g (battery included)

Max Ascent Speed: 5m/s

Max Descent Speed: 3m/s

Max Speed 16m/s

Operating Frequency: 2.400GHz – 2.483GHz

Compliance: This device complies with part 15 of the FCC Rules as stated on page 56 of the DJI Phantom

3 flight manual.  

Design and Operational Characteristics of the Phantom 3

Three positioning modes;

1. GPS and vision positioning and uses GPS/GLONASS for positioning.

2. Vision positioning is available but GPS is not  

3. Neither GPS nor vision positing is working and it’s only using its barometer for positing return to home

are where you last record point of take‐off.  

There are three (3) cases that will trigger Return To Home (RTH) procedure; they are Smart RTH, Low

Battery RTH and Failsafe RTH.  Press and hold the button to start the RTH procedure. Then the LED

around the RTH Button will blink white to indicate the aircraft is entering RTH mode. The aircraft will

then return to the last recorded Home Point.  To cancel it, Press this button again and you will regain the

control of the aircraft.  

1. Smart RTH_You may control the aircraft's orientation to avoid collision during the Smart RTH. Press

the Smart RTH button once to start the process, press the Smart RTH button again to exit Smart RTH and

regain the control.  

2. Low Battery RTH_The low battery level failsafe is triggered when the DJI Intelligent Flight Battery is

depleted to a point that may affect the safe return of the aircraft. Users are advised to return home or

land the aircraft immediately when these warnings are shown. DJI Pilot app will advise user to return the

aircraft to the Home Point when low battery warning is triggered. Aircraft will automatically return to

the Home Point if no action is taken after 10 seconds countdown. User can cancel the RTH by pressing
once on the RTH button. The thresholds for these warnings are automatically determined based on the

current aircraft altitude and its distance from the Home Point. Aircraft will land automatically if the

current battery level can only support the aircraft to land to the ground from the current altitude. User

can use the remote controller to control the aircraft’s orientation during the landing process. The

Battery Level Indicator is displayed in the DJI Pilot app, and is described below  

3. Failsafe RTH_Is activated automatically if remote controller signal (including video relay signal) is lost

for more than 3 seconds provided that Home Point has been successfully recorded and compass is

working normally. Return home process may be interrupted and the operator can regain control over

the aircraft if a remote controller signal is resumed.  

Max Height & Radius Limit Flying Height and Distance

The user may change these settings in the DJI Pilot App. Once complete, the Phantom 3 will fly in a

restricted cylinder that is determined by these settings. The tables on page 40 in the flite manual

attachment show the details of these limits.  

On the DJI Phantom 3 as a default a “warning zone” has been set around safety zones. When you fly

within 320 feet of the 5 mile radius of the restricted flying zone a warning message will appear on the

DJI Pilot App. and there is a graph to show in detail on page 42 of DJI Phantom 3 flight manual

attachment. That includes for category A areas and category B areas, big and small airports.  

Respectfully Submitted,  

Troy M. Malmstrom

digital_processes,llc

6706 Windward St

Cincinnati, OH 45227

480.203.7060

troy@dpfab.co