November 14, 2015

U.S. Department of Transportation (DOT)

1291 Coventry ct, Maryville TN, 37803

Subject: Petition to the FAA for Section 333 Exemption

Drone Video Production

Dear Sir or Madam

Drone Video Production, hereby submits to the Federal Aviation Administration, pursuant to

the FAA Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333

of the Act. Drone Video Production requests to operate commercially its small unmanned

aircraft system (UAS) which is currently regulated by the Federal Aviation Administration.

This letter provides requested information as listed in the FAA's "Public Guidance for Petitions for

Exemptions Filed under Section 333" as described as of this date at the FAA website at

https://www.faa.gov/uas/legislative programs/section 333/how to file a petition/

Drone Video Production is an experienced aerial photographer in the State of Tennessee. We

are experienced in flying hobby helicopters for recreational purposes. We have flown small RC electric

helicopters for over three (3) years without incident. Safety is our commitment with each flight. An

extensive pre-flight safety checklist is completed and each flight is logged by the operator and verified

by our spotter. Our exemption request would permit operation of ultra-light weight, unmanned (remote

control operated) in tightly controlled and limited airspace. More company information can be viewed

on the company website at www.dronevideoproduction.org .

Purpose for the Exemption:

Drone Video Production desired to utilize an unmanned aircraft system (UAS), herein

described, to accomplish aerial photography of industrial and commercial facilities as well as realestate.

Contact Information:

Drone Video Production

Maryville, TN 37803

Mobile: 865-310-7099

Email: dronevideoproduction@gmail.com

List of Specific Sections of 14 CFR for which exemption is sought:

This listing matches the list on page 7 of the FAA's "Public Guidance for Petitions Filed under Section
333", Rev. 9/25/2014.

14 CFR 21, Subpart H -Airworthiness Certificates

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

14 CFR 91.7 (a), Airworthiness required for operation

14 CFR 91.103 (b) (2), Preflight action

14 CFR 91.105, Flight crewmembers at stations

14 CFR 91.109, Flight instruction

14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.121, Altimeter settings

14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.405 (a), Maintenance required

14 CFR 91.407 (a) (1), Operation after maintenance

14 CFR 91.409 (a) (2), Inspections

14 CFR 91.417 (a) and (b), Maintenance records

(FURTHER DETAILS ON PAGES 8-11)

In accordance with the outline given in the FAA's "Public Guidance for Petitions Filed under Section

333", the following information is provided for each numbered item listed in that guidance:

1. Aircraft Description

Design and Operational Characteristics:

• Drone Video Production plans to operate a Phantom 3 comprised of an

unmanned aircraft and a transportable ground station. This aircraft is a quad-copter

design with gross weight (battery and propellers included) of 1000 g (2.205 lbs.).

• The Phantom 3 has an HD camera for capturing aerial still photographs

and videos.

• It is equipped with four rotors that are driven by battery-powered electric motors.

Maximum airspeed is 30 knots.

• The Phantom 3 includes a Failsafe Function. It activates if the Remote Control is

powered off, the Phantom 3 has flown outside effective control range, the signal

between the Phantom 3 and the Remote Control is blocked, or if there is interference

causing a signal problem. When activated, the Failsafe Function automatically flies the

Phantom 3 back to the Home Point (the start location) and lands it. If GPS mode is not

active, the Failsafe Function will execute a controlled descend and automatic landing.

• Through the Phantom 3 Assistant software, each flight operation will be programmed

with a maximum radius distance and maximum altitude from the Home Point such that
the flight control system will limit operations to within the confines of the property to

be surveyed for Drone Video Production or Drone Video Production's Clients. These performance 

limitation

requirements are included in the UAS Operating Procedure contained in Appendix A

herein.

Manufacturer's Documentation:

Detailed manufacturer's design information (current to this date) is contained the in the

following manuals in the appendices at the end of this document:

• Appendix B- Phantom 3 Specifications

• Appendix C- Phantom 3 Quick Start Guide

• Appendix D- Phantom 3 User Manual

• Appendix E- Phantom 3 Pilot Training Guide

2. Procedures for Ensuring UAS Is In a Condition Safe for Flight

Preflight Checks:

At a minimum, the following items will be checked prior to initiating any operation. (See

Appendix A in this document for detailed procedures, Drone Video Production,

Operating Procedure V1.13.4.15)

• Operations must be in daylight hours and under visual meteorological

conditions (VMC).

• Area to be surveyed is defined on a plot plan drawing with path of flight and

altitudes for each leg of the flight clearly marked.

• Flight path is at least 500ft. from all non-participating persons, vessels,

vehicles and structures unless protective barriers or structures are present,

or permission is granted or such operations present no hazard to the Pilot in

Command, the Visual Observer, trainees, and other essential persons.

• Flight plan and schedule has been reviewed with site leadership and

communicated to all Drone Video Production and Client

personnel in the area.

• Remote control, smart battery, range extender, and ground station monitor

are fully charged.

• Propellers are mounted correctly.

• Damping absorbers are in good condition, not dry-rotted or worn.

• Anti-drop kits have been mounted correctly.

• Micro-SD card has been inserted.
• Gimbal is functioning as normal.

• Compass has been calibrated.

• Flight radius and altitude limits have been set with the Phantom 3 Assistant

software, not to exceed 400ft. AGL altitude, and radius limited to the

property boundaries of Drone Video Production or Drone Video Production’s Client site.

• The Visual Observer (VO) is stationed at the required initial observation

point according to the flight plan and in view of the Pilot in Command (PIC)

 and has means for continual verbal communication.

• There are no inoperable components.

• All site required safety permits are approved in in possession of the PIC.

• Motors can start and function as normal.

• Flight Indicator Lights on the aircraft verify that the Home Point is set to

current location.

• Record the Preflight Check, date and sign, and file it in the Equipment

Inspection and Maintenance Record Book.

3. Radio Frequency (RF) Spectrum for Control

The Remote Control ground station operating frequency is 5.278- 5.85 GHz and is FCC

compliant with communication distance in an open area of 800 m (875 yds.)

Operating Frequency 5.728GHz-5.85 GHz

Communication Distance (open area) FCC Compliance: 800m

Receiver Sensitivity (1%PER) -93dBm

Transmitter Power FCC Compliance: 100mW

Working Voltage 120 mA@3.7V

Built-in LiPo Battery Working Current/Capacity 3. 7V, 2000mAh

4. Qualifications for The Pilot in Command (PIC)

Logged Hours:

The PIC will have accumulated and logged a minimum of 25 hours of total time as a UAS

rotorcraft pilot with a multi-rotor UAS prior to operations. The PIC will have also

accumulated and logged a minimum of 5 hours as UAS pilot specifically operating the

Phantom 3, prior to operations. The PIC will have accomplished, during dedicated

training sessions, 3 take-offs and landings in the preceding 30 days. Training,

proficiency, and experience-building flights in dedicated training sessions will be

included in the accumulated and logged hours.
Emergency and Evasive Maneuvers:

The PIC will have demonstrated the ability to safely operate the Phantom 3 in a manner

consistent with how it will be operated in surveying Drone Video Production’s Client properties,

including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures. The logged hours referenced above will

document this.

5. Description of Intended UAS Operations

• Operations will be restricted to Class G airspace.

• No operations will occur within 5 miles of a non-towered airport reference point as

denoted on a current FAA-published aeronautical chart, unless a letter agreement with

the airport's management is obtained, and the operation is conducted in accordance

with a Notice to Airman (NOT AM) as required by the Certificate of Waiver or Operation

(COA).

• The Phantom 3 will be utilized to survey industrial and commercial facilities. The use of

small unmanned aircraft systems provides more immediate and thorough information

than is presently available by other means. Expense for scaffolding, rental of manned

aircraft, rental of equipment, and lost time is saved. Safety is improved by reducing fall

risk for workers and reducing potential for manned aircraft accidents.

• As described in "2. Procedures for Ensuring UAS Is in a Condition Safe for Flight",

altitude and distance limits will be entered into the Phantom 3 Assistant software prior to

commencement of flight. This will restrict the operation to Drone Video Production’s Client property.

The Failsafe Function integral with the Phantom 3 will assure this aircraft stays within

the area deemed safe for operation.

• Industrial facilities of the type mentioned above have strict safety procedures which

must be satisfied. Drone Video Production's respect for compliance with these procedures is vital to

assuring positive Client relationships and continuing business. All safety procedures for

personnel will be strictly adhered to as well as all laws and regulations.

6. Proposed Speed, Altitude, Visibility and Distances

Speed:

The Phantom 3 is capable of a maximum speed of 15m/s (29.2 knots). In order to

conserve power, and thereby maximize flight time, and to assure good quality still

photographs and video, the Phantom 3 will be operated at a slow speed along the flight

path, typically 2m/s (3.9 knots) or below. Higher speeds may be used from time to time
when traversing a section of the property of no interest and not included in a given

study.

Altitude:

Altitudes below 400ft. AGL are adequate for the complete range of facilities and

structures to be surveyed. The integral Flight Control System will be set to limit the

altitude to always be below that level.

Distance:

The integral Flight Control System will be set to limit the radial distance from the Home

Point (point off light commencement) such that the Phantom 3 will stay within the

boundary of the property lines. The PIC will operate the equipment to assure those

limits are not reached and will maneuver the Phantom 3 to follow the preplanned flight

path within the property boundaries.

The Phantom 3 will not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud when visibility is less than 3 statute miles from the PIC.

Operations will be aborted immediately if the PIC encounters unpredicted obstacles or

emergencies. Safe descent and landing procedures will be followed in accordance with

operating documents.

7. Description of the Area of Intended Operations

As described in "5. Description of Intended UAS Operations", the Phantom 3 operation will be

restricted to Drone Video Production’s Client property. Drone Video Production and Client

personnel on the site will be made fully aware of the operation prior to commencement of

operations.

8. Proximity of Airports

Operations will be restricted to Class G airspace.

No operations will occur within 5 miles of a non-towered airport reference point as denoted on

a current FAA-published aeronautical chart, unless a letter agreement with the airport's

management is obtained, and the operation is conducted in accordance with a Notice to Airman

(NOT AM) as required by the Certificate of Waiver or Operation (COA).

9. Operation within Visual Line-of-Sight (VLOS)

In addition to the PIC, all operations will include a Visual Observer (VO). The VO will assure that

the Phantom 3 is always within their visual line-of-sight (VLOS), as well as the PIC's, at all times.
The VO and the PIC will be able to communicate verbally at all times utilizing two-way radios

available at Drone Video Production’s Client sites.

10. Procedures for Preflight Safety Assessment

Prior to each flight, the PIC will inspect the Phantom 3, including the ground control station, in

accordance with the Preflight Checklist (see "2. Procedures for Ensuring UAS Is In a Condition

Safe for Flight"). If the Preflight Check indicates any unsafe conditions or a non-functioning

safety-critical part, the flight will not commence until the needed maintenance is performed and

a satisfactory Preflight Check can be completed. All maintenance and alterations performed will

be documented and filed in the Equipment Inspection and Maintenance Record Book.

11. Notifications

As required, a Notice to Airmen (NOT AM) will be requested not more than 72 hours in advance

and not less than 48 hours prior to an operation.

In addition, any notifications required by the FAA Flight Standards District Office will be made.

12. Certificate of Waiver or Authorization (COA)

Prior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate of Waiver

or Operation (COA) will be obtained for each aircraft. Services will start with one aircraft, with

additional units added as needs for operations increase over time. Each Phantom 3 aircraft will

be identified with its serial number, registered in accordance with 14 CFR part 47, and have

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will

be as Iarge as practicable.

Specific Regulations for Which Exemption is Sought:

1. 14 CFR 21, Subpart H -Airworthiness Certificates

14 CFR 21 covers the certification procedures for products and parts. Subpart H specifies

requirements for Airworthiness Certificates for various aircraft types. Small unmanned aircraft

systems are not specifically called out and addressed in these rules.

Drone Video Production will, in lieu of airworthiness certification by aforementioned rule, if exemption 

is granted, ensure that the Phantom 3 system is in compliance with its operating documents as

described herein. The PIC will assure that all Preflight Checks are completed and documented

and the Phantom 3 is in full compliance with all manufacturers' operation and maintenance
documents.

Due to consideration of the size, weight, speed, and limited operating area associated with

Drone Video Production’s proposed Phantom 3, we believe it will not create a hazard to users of the 

National Airspace System (NAS) or the public. Therefore, a request is made for exemption from 14 CFR

part 21, and any associated noise certification and testing requirements of part 36.

2. 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

14 CFR 61.113 (a) and (b) prohibit private pilots from fulfilling the role of PIC if the aircraft is

carrying property for compensation, unless the flight is only incidental to that business or

employment.

Drone Video Production believes that due to the size, weight, speed, and limited operating area 

associated

with Drone Video Production's proposed Phantom 3 operation, a PIC possessing the aforementioned 

training

and logged hours, would ensure safety and prevent creating any hazard to users of the National

Airspace System (NAS) or the public. We therefore request an exemption from these parts of 14

CFR.

3. 14 CFR 91.7 (a), Airworthiness required for operation

Lf the exemption from 14 CFR 21, Subpart H (item 1 above) is granted, no airworthiness

certificate will be required. On this basis, exemption from 14 CFR 91.7 (a) is requested,

presuming that airworthy condition by definition in the rule means having an airworthiness

certificate. Drone Video production will, in lieu of airworthiness certification by 14 CFR 21, ensure that 

the

Phantom 3 system is in compliance with its operating documents as described herein. The PIC

will assure that all Preflight Checks are completed and documented and execute full compliance

with all manufacturer's operation and maintenance documents.

4. 14 CFR 91.103 (b) (2), Preflight action

14 CFR 91.103 (b) (2) specifies that the PIC be familiar with aircraft performance under expected

values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Since the Phantom 3 will not be operating out of airports this rule is not applicable. On this

basis and on the basis that the operating documents cover requirements for operation safety,

an exemption from this rule is requested.

5. 14 CFR 91.105, Flight crewmembers at stations

This part requires certain actions by on board crewmembers. Since the Phantom 3 is unmanned,
an exemption from this rule is requested.

6. 14 CFR 91.109, Flight instruction

14 CFR 91.109 describes requirements for flight instruction and requires that the aircraft used

for flight instruction have fully functioning dual controls. The details pertain to manned

airplanes and are not applicable to a small unmanned aircraft system such as the Phantom 3.

Flight training will be required for the Phantom 3 pilot as detailed on page 5 herein, "4.

Qualifications for the Pilot in Command (PIC)." Compliance with these training requirements

with logged hours assures that the required competency for safely operating the Phantom 3 will

be maintained. On this basis an exemption from this rule is requested.

7. 14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.119 (c) requires that no operation is permitted below 500 feet above the surface,

except over open water and sparsely populated areas. The proposed use of the Phantom 3 is

specifically for altitudes that range from the surface to maximum 400 feet AGL. On the basis of

the aforementioned safety procedures, we believe there will be no increased hazard to users of

the National Airspace System (NAS) or the public will be created by the Phantom 3 as detailed

here.

8. 14 CFR 91.121, Altimeter settings

14 CFR 91.121 provides specific rules for altimeter settings for cruising altitude and flight level of

aircraft and speaks of altimeter stations along the route and the elevation of the departure

airport. In lieu of these specific requirements, most suitable for manned airplanes, the Phantom

3 has barometric altimeter and GPS derived altitude limitations. All altitudes reported to Air

Traffic Control (ATC) will be in feet above ground level (AGL). On this basis, an exemption from

this rule is requested.

9. 14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.151(a) requires that no person may begin a flight under Visual Flight Rule (VFR)

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to

fly after that for at least 30 minutes, or (2) at night, to fly after that for at least 45 minutes.

The Phantom 3 has a built-in Low Battery Level Warning Function:

9 

1) If the smart battery is depleted to the point that may affect the safe return of the aircraft,

the low battery level warning notifies the PIC to take action.

2) The thresholds for these warnings are automatically determined based on the current
aircraft altitude and its distance from the Home Point.

3) A color coded battery level indicator shows battery level, and an estimated remaining flight

time in minutes is displayed.

4) When the critical battery level warning activates, the aircraft will gradually descend and land

automatically.

As standard operating procedure, the PIC will immediately return the Phantom 3 to the Home

Point for a battery swap when the battery level reaches 25%.

On the basis of these specific safety features of battery power level monitoring, and operating

procedures, an exemption from this rule is requested.

10. 14 CFR 91.405 (a), Maintenance required

Please see exemption request explanation in item 15 below (14 CFR 91.417).

11. 14 CFR 91.407 (a) (1), Operation after maintenance

Please see exemption request explanation in item 15 below (14 CFR 91.417).

12. 14 CFR 91.409 (a) (2), Inspections

Please see exemption request explanation in item 15 below (14 CFR 91.417).

13. 14 CFR 91.417 (a) and (b), Maintenance records

Parts 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), and 91.417 (a) and (b), contain requirements for

maintenance of larger aircraft. In lieu of adapting these rules for the Phantom, Drone Video Production

is requesting an exemption on the basis that it will inspect the Phantom 3

and ensures that it is in a condition for safe flight prior to beginning any operation. We propose

that adherence to the operating documents describing the requirements for maintenance,

inspection, and record keeping, are sufficient to ensure that safety is not adversely affected.

PUBLIC BENEFIT

Granting this Section 333 Exemption would benefit the public in the following ways:

• Public Safety: Common practice for industrial facility construction projects and periodic

site-wide industrial facility visual assessment involves utilization of manned aircraft. The potential risk to 

life and property is order of magnitudes less for use of a small unmanned aircraft system as compared to 

conventional aerial photography by manned

fixed wing aircraft.
• Industrial Safety: In order to accomplish inspections of difficult to access areas at high

elevations requires either erection of scaffolding or lifting personnel by crane in

protective enclosures to view the subject of interest. Fall protection gear and

compliance with OSHA rules governing such work is crucial for life safety. The ultimate

protection, however, would be to not involve personnel in such activity and instead

complete this work with an unmanned aircraft system.

• Energy Savings and Environmental Protection: Reduction of frequency of manned

aircraft used to do aerial photography and surveys for construction sites and industrial

facilities results in burning less fuel thereby saving energy and reducing emissions of

combustion gases.

REASONS SAFETY NOT ADVERSELY AFFECTED AND IS AT LEAST EQUIVALENT TO EXISTING RULE

The key features of the proposed Phantom 3 unmanned aircraft system that assure that safety

to the public and safety of the National Airspace System (NAS) is not adversely affected are the

following:

• Credentials and training for the Pilot in Command (PIC), along with detailed operating

procedures, assure that the level of competency required for successful and safe flight

operations is achieved.

• The built-in Flight Control System, which includes a Failsafe Function, assures immediate

return to the Home Point and safe landing under failure scenarios, thereby preventing

injury or damage.

• Visual Line-of-Sight (VLOS) operation provided by the PIC and the Visual Observer (VO),

and their ability to communicate verbally at all times, assures full operational control.

• Detailed operations and maintenance procedures, including a Preflight Checklist,

provide assurance of mechanical integrity and full functioning of Phantom 3 unmanned

aircraft system prior to commencement of any operation.

SUMMARY FOR PUBLICATION IN FEDERAL REGISTER

Petition for Exemption

Docket No.: FAA-2015-xxxx

Petitioner: Drone Video Production

Section of 14 CFR 14 CFR 21 Subpart H, 61.113{a) and {b), 91.7 (a), 91.103 (b) {2), 91.105, 91.109,91.119
(c), 91.121, 91.151,91.405 (a), 91.407 (a) {1), 91.409 (a) {2), 91.417 (a) and (b).

Description of Relief Sought: The petitioner is seeking an exemption to utilize an unmanned aircraft

system (UAS) to accomplish aerial photography, surveys and assessments of realestate, as well as

industrial, and commercial facilities.

Dakota K. McAfee

Owner

Drone Video Production