December 18, 2015 

U.S. Department of Transportation 

Federal Aviation Administration

800 Independence Ave., S.W. 

Washington, D.C. 20591

To Whom it may concern,

I am a Full time Firefighter/Paramedic in the city of Los Angeles, active private pilot, and 

professional photographer operating under Keelin Photography. The purpose of this letter is to 

formally request an exception to Section 333 for UAS drone photography with intent to 

operate commercially and comply with FAA regulations concerning UAS in the National 

Airspace System. My main focus is to safely and effectively fly without creating undue hazard or 

disruption to the public. 

With intention to expand my photography business to aerial photography servicing the 

Southern California area, operating a UAS commercially would benefit the public to have the 

option of more safely and efficiently obtaining aerial images for real estate, weddings, and 

other photography or videography needs. This also has the potential for reducing larger 

combustion engine aircraft in the National Airspace System for photography needs. 

1. Safety and Design

My UAS system is currently the DJI Phantom 3 Professional. The leader in the drone industry, 

DJI has proven a safe and effective option for four brushless motors capable of up to 23 

minutes operating time on a full charge of its smart Li-Po battery. The DJI Phantom 3 

professional consists of a 3 axis control system, auto takeoff, auto hover, auto return to home, 

live telemetry of flight data, GPS navigation, Sonar and visual Positioning sensors, intelligent 

flight modes, and permanently affixed camera and gimbal system. 

DJI Phantom 3 Professional weighs 1280 grams, has a maximum speed of 37 mph, will be 

operated at no higher than 400 ft AGL, max flight time of 23 minutes, operates on 2.400 

GHz-2.483 (compliant with all FCC regulations), safe transmission distance of up to 5km 

unobstructed (which will not occur when flying drone visual line of sight), safe operating 

temperature range of 0-40 degrees Celsius, 

The performance of the UAS depends largely on operating the drone visual line of sight. The 

remote control is uniquely paired with only one drone and if communication is lost due to 

malfunction, low battery, or damage to either radio component, the DJI Phantom 3 Professional 

will return to its home point that is designated at the beginning of each flight or at a new home 

Keelin Photography

6614667753-466-7753 KeelinPhotography@gmail.com 2020 Artesia Bl. APT 22 , Redondo Beach CA 90278
point designated during flight. A pre-designated return to home altitude is set within the DJI 

app for the iPhone 6 that is connected to the remote control at all times. Depending on 

surroundings, a safe altitude is determined for every flight area as remain clear of all obstacles. 

A digital flight manual is kept within the iBooks app, along with a flight log and recorded 

telemetry for each flight is recorded. Currently I have over 7 hours of logged flight time with 63 

individual flights and have a very thorough understanding of the DJI Phantom 3 Professional’s 

flight characteristics and how it responds to remote control input. I also have a very thorough 

understanding of the in-depth DJI app for iPhone 6 which displays the current GPS position of 

the drone, altitude, distance away from user, vertical speed, ground speed, flight battery status 

(including time left and percentage), remote control battery status, remote control and 

telemetry signal strength, camera and video settings, flight map, and intelligent flight modes 

(Course lock, waypoints, point of interest, follow me, and home lock) 

2. Procedures

Prior to safely operating any aircraft, a pre-flight inspection is required. For the DJI Phantom 3 

Professional, this includes removing the gimbal clamp, making sure the 4 propellers are tight 

on each of the four motors. The two propellors with black dots spin counter-clockwise and the 

two propellors without black dots spin clockwise. 

The battery is firmly installed and clicked into place. The remote controller is designed for 

secure use of iPhone or other tablet use to be mounted directly on top of the remote 

controller. The iPhone is plugged into the remote control directly with a USB cable. All 

components of the UAS are inspected prior to takeoff to make sure there is no visible damage, 

deformity, cracks, or abnormalities. The inspected components include: Four propellers, four 

motors, Front LED indicators, fixed landing gear, gimbal and camera, camera status indicator, 

intelligent flight battery, vision positioning sensors, antennas, remote control antennas, mobile 

device holder, control sticks, return to home button, battery level LED’s, Status LED, and overall 

condition of entire UAS. 

Relevant maintenance for the DJI Phantom 3 Professional includes calibrating the compass 

when flying in a new location, tightening the propellors before each flight, and ensuring the 

motors work properly and able to hover with a GPS lock before fully committing to operating 

the aircraft. I have kept an in depth maintenance log for the DJI Phantom 3 Professional and 

each of the intelligent batteries. 

3. Pilot in Command

I have logged 170 hours of private pilot in command of single engine aircraft operating in the 

National Airspace System and have a thorough understanding of the extremely congested 

local airspace in Southern California. I plan not to operate within 5 miles of any airport, below 

400 feet, or over congested or inhabited areas of unprotected persons. If wishing to operate 

within 5 miles of an airport, contact and permission will be obtained with the controlling 

agency. My third class medical is up to date and will be renewed before expiration to maintain 

my private pilot medical requirements. 

4. Operations
Real Estate photography will be my main focus with other services offered for weddings or a 

new angle on family portraits. With safety in mind, I will never operate the UAS to create any 

hazard 

I will have one visual observer who's sole responsibility is to be a second set of eyes to 

maintain watch for potential obstacles and/or other aircraft. My observer will be trained in 

operation of the UAS and understand its workings thoroughly in case of emergency operations 

are necessary for the observer to take over flight. I have developed a training program to 

ensure my observer is able to safely and effectively return the UAS to the home position. 

For takeoffs and landings, the UAS will need an area free of obstacles and people, in which the 

visual observer will also oversee that no person enter the area. During flight, the UAS will not 

be operated during any visible precipitation or near any clouds (2000 feet horizontal and 500 

feet below clearance). The DJI Phantom 3 Professional will be operated at slow speeds, much 

slower than the manufacturers top speed of 37 mph. 

Flight times for commercial operation will not exceed 15 minutes (which is 65 percent of the 

manufacturers rated battery life for drone usage) this will pad the envelope of safety for 

effective drone use. I currently have 4 batteries which will give me 1 hour total of flight time. 

The DJI Phantom 3 Professional will not be operated from any moving device or vehicle and 

will remain clear of all manned aircraft. Any operation over private property will require 

expressed written consent to operate and film. The UAV will remain a minimum of 500 feet 

away from all non participating persons. The UAV will only be operated during daylight hours 

under VMC. 

With the evolving laws concerning use of UAS, taking the time with any person inquiring the 

legality of drone operation is a great consideration in mind. Professionalism and public 

perception is essential for the advancement and acceptance of drone usage in the National 

Airspace System. 

Potential hazards include fire and debris scattered if the aircraft malfunctions. With an 

appropriate Class A,B, and C Fire Extinguisher, a fire caused by the UAS could be mitigated 

with proper training which I have obtained. If injury were to occur, I carry a first aid kit and also 

have extensive paramedic training to mitigate any medical or trauma issue created by the UAS. 

In closing, 

I, Scott Keelin, will be the sole operator and retain full responsibilities of all UAV operations 

under Keelin Photography. I intend to comply with all current and changing regulations 

regarding UAS operation in the National Airspace System. I will continue to educate myself 

about safe operations and maintain my aircraft to safe standards. Registration of the aircraft will 

occur on December 21, 2015. My background as a firefighter/paramedic involved with 

emergency operations in concordance with my training as a private pilot has effectively given 

me the foundation required for the safe regard and operation of the UAS. At no point in time is 

a picture or video worth damage to someones property or life. Thank you for your time and If 
there is any material omitted, I respectfully request a list of further compliances necessary for 

the FAA 333 exemption. 

Scott Keelin 

Keelin Photography