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 90278point 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. OperationsReal 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 Ifthere is any material omitted, I respectfully request a list of further compliances necessary for the FAA 333 exemption.

Scott Keelin

Keelin Photography