PHOTOS FROM ABOVE,LLC

4401 N.W. 4th st. Suite 134

Oklahoma city,Oklahoma 73107

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform act & Part 11 of the Federal Aviation 

Regulations from 14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409; 

91.417 (a) & (b)

To Whom It May Concern:

RE: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R Part 11, Photos from Above LLC is a new and developing filming and 

photography company and operator of a small (UAS) equipped for photos and videos, hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operations of its UASs, so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA and required by Section 333.

Purpose of the proposed flight will be to provide:

 Photos and videos of real estate listing offered for rental and sale.

 Photos and videos used to promote tourism in the areas resulted in potential tax receipts 

for Local, States and US Government. 

 Photos promoting land for sale.

 Golf Course Photography.

 Cinematography.

 Monitor Crops.
 Surveys.

 Pipeline inspections.

 Property Inspections.

 Nature Photography.

 Photos and videos taken with UASs will be promoted on company’s websites (Facebook, 

Instagram and twitter.

The name and address of the Applicant is:

PHOTOS FROM ABOVE,LLC.

Attn: Caleb Owens

PH: 405-694-7176

Email:abovetheclouds2016@gmail.com

Address: 4401 N.W. 4th st.,Suite 134 Oklahoma city,Oklahoma 73107

Public Interest and National Security 

Photos from above,LLC intends to service the needs of aerial filming and photography for the 

purposes of movie making, advertising and marketing in a variety of industries. Traditional 

methods of aerial filming and photography are handled by full sized, fixed and rotor wing 

aircraft which are no longer competitive when compared to the low acquisition and operating 

costs of small unmanned aircraft systems. These cost savings can be transferred to the advertiser 

then ultimately to the consumer to promote competitiveness in the market place. Full sized 

aircraft have a greater environmental impact. They are significantly louder to operate than small, 

fully electric unmanned aircraft systems and carry a much larger carbon “footprint" adding to the

growing concern of the emissions of greenhouse gases. Being all electric is beneficial in that it is 

significantly quieter and less likely to disrupt the peace of the surrounding flight operations area. 

Full sized aircraft carry flammable fuels and flight crew and/or passengers. There is a great deal 

of danger imposed to the flight crew and/or passengers and to those on the ground in the event of

an emergency with regard to full size aircraft. This danger is considerably less in comparison 

with the UAS due to its small size, maximum forward speed and lack of flammable fuels. 

Because Photos from above,LLC will have a public presence for commercial UAS aerial filming 

and photography, we will be available and willing to assist in disaster relief. There is no threat to 

National Security due to the Transportation Security Administration security screening of 

certificated airmen. We believe that because of advancing technologies, small unmanned aircraft 

systems are much less expensive to acquire, easier to operate, and less demanding to maintain 

when compared to full size aircraft. UAS aerial services, such as filming, surveying, inspection 

and surveillance will undoubtedly promote public interest. 
General Operating Flight Crew Requirements 

 In order to maintain and advance those necessary safety and security protocols of

an emerging industry, Any/All Photos from Above,LLC PIC’s must possess and

complete the following FAA and Operator requirements before any consideration for

commercial flight takes place:

 All PIC’s must possess a commercial, private or sport pilot license and a

current FAA Medial Certificate or valid driver’s license

 All PIC’s must complete and log a minimum of 50 hours of advanced flight

simulation time using a flight simulation training program.

 All PIC’s must complete and log a minimum of 40 hours actual hands on

flight training.

 All PIC’s must possess advanced safety training and knowledge, as well as,

advanced training in Pre & Post flight planning, maintenance, checklists, etc..

 All PIC’s must pass Photos from Above,LLC’s strictly monitored final flight tests.

 UAS flight crewmembers are required to demonstrate the ability to speak and understand 

the English Language to the proficiency level required by ICAO Annex 1. This is 

accomplished by means of formal and informal interviewing during the hiring process. 

 Neither the PIC or VO shall participate in any flight operations, whether it be proficiency

flights or revenue generating flights, if the blood alcohol concentration (BAC) level is 

0.04% or higher, within 8 hours of having consumed any alcohol, while under the 

influence of alcohol, while under the influence of illegal, prescribed or over the counter 

drugs that would impair the ability to safely operate the UAS as prescribed in 14 CFR 

Part 91.17. It is the responsibility of the PIC and VO to police each self and each other. 

 The UAS flight crewmembers shall not participate in any phone calls, phone 

conversations or operation of a two-way radio during flight operations. All proposed 

flight paths and flight operations will be discussed by Photos from Above,LLC and the 

customer prior to any flights in order to avoid unnecessary distractions. Only concise 

communications are allowed between authorized flight operations area personnel and the

UAS flight crewmembers. Every effort shall be made to prevent non-essential personnel 

from interfering with the PIC and VO in any way during flight operations. 
 All applicable licenses, certificates, permits, authorizations, waivers, exemption letters, 

flight and maintenance logbooks, personal identifications, and this Operations Manuals 

shall be made available to any law enforcing, State or National Government Entity at 

any) 

Record keeping 

 Training qualifications and record keeping are maintained and tracked for the pilot in 

command and visual observer. The PIC is responsible for the management of all training, 

maintenance and flight records. Records shall include the following, as appropriate to the 

crew position; copies of certificates and ratings, copy of current Medical Certificate and 

flight training logs.

 Maintenance will only be conducted by an authorized DJI represented who is certified by

DJI to maintain a DJI phantom 3. Records will include date, time, specific detail of work

done and name and or badge number of personal who conducted the maintenance. 

Maintenance records will be kept for 7 years. Operational and Maintenance records may 

be made available for inspection by the Federal Aviation Administration.

The UAS & Flight

The UAS is a 3 lbs battery operated quadcopter (four motors, four blades) called the DJI 

Phantom 3 Professional, which consist of:

 4k UHD video recording with fully stabilized 3-axis gimbal; Vision Positioning system 

allows stable flight.

 Lightbridge digital streaming allows live viewing of 720p video (full resolution video is 

simultaneously recorded on the internal microSD card).

 Flight battery and rechargeable remote controller. 

 DJI Pilot app for IOS and Android allows live viewing and complete camera control.

 The Phantom 3 Professional carries a fully stabilized 3-axis 4k UHD video camera for 

smooth, crisp videos and still photos.

 To allow you to see what the drone sees, DJI has engineered a new generation of their 

Lightbridge technology that allows 720p HD digital streaming of live video directly from

the drone.

 Includes GPS navigation with auto takeoffs and auto landings, intelligent high power 

flight battery, a built-in safety database of no fly zones, and a powerful mobile app for 

your iOS or Android device.

 GPS Assisted flight- Allows quadcopter to hover when no command are being sent- This 

is a nice feature in case the PIC needs to "regroup" during flight.

 Non-GPS Modes- If GPS signals are lost, aircraft goes into a mode that monitors and 

hold altitude and provides control assistance to help keep aircraft stable and under total 

control of the PIC.
 LED Status Lights on Aircraft, along with warning system equipped on the pilot app 

which allows the PIC to always have full situation awareness on his aircraft. 

Note: DJI has locked the Phantom from being able to even start the motor if you live within a 15 

mile radius of the White House. This encompasses not only D.C. but much of Prince George's 

County, Arlington, Fairfax, Silver Spring, Falls Church and Montgomery County. 

(The DJI Phantom 3 manuals will be attached to this packet)

The UAS also have two bright gold bands in front of the quadcopter, these are used for 

orientation and location of aircraft from line of site.

MAX. Ascent Speed: 5m/s

MAX. Descent Speed: 3m/s

MAX. Flight Altitude 6000m

MAX. Flight time approximately 23 minutes

GPS: GPS/GLONASS

The powerful Remote Controller allows you to pilot and maneuver the Phantom 3 Professional at

distances over 6,000 feet away, while putting selected camera controls. Built into the Remote 

control is a rechargeable LIPo battery and DJI Lightbridge, which when paired with a compatible

mobile device gives live HD view from the Phantom Camera.

Operating Frequency: 2.400 GHz-2.483 GHz

Max. Transmission Distance: 2 km

Operating Temperature Range: 0c-40c

Transmit Power: FCC: 20 dbm; CE: 16 dbm

Charger: Voltage 17.4V; Rated Power 100W

The UAS will be operated by a Pilot in Command (PIC) with the following restrictions:

 All operations will occur in Class G airspace at no more than 400' AGL. The vast 

majority of flights will be well below this limit at an average of 200' AGL to accomplish 

the best photographs and videos. 

 Any required permits will be obtained from local and state government before flights.

 The Aircraft will not operate directly above human beings at any time or within 150 feet 

of human beings.
 Maximum flight time will be 18 minutes. Battery allows 23 minutes of flight time. 

Batteries are inspected and always fully charged before use.

 The Aircraft will not operate within 5 miles of an airport/heliport without prior approval 

from said airport/heliport.

 All operations will be during the daytime and in ideal weather conditions of less than 15 

mph winds and clear skies.

 Aircraft will remain in visual line of site at all times not to exceed 1/4 miles from PIC.

 Visual observer will serve as additional eyes on the aircraft and be within voice reach to 

communicate with PIC

 Aircraft will not fly in the area of any full scale aircraft and if a full scale aircraft comes 

into airspace during the aircraft's flight, it will be landed immediately to allow right of 

way to full scale aircraft. 

 At any time Aircraft is being flown, signs will be posted in least three (3) locations, 

warning of UAS operations are being conducted and to stay at 200' away at all times of 

landing and takeoff areas. 

 UAS will never be used as an invasion of privacy and only be used for purposes listed 

above.

 The UAS will never be flown near, in or over stadiums; or over large gathering of 

persons.

 The equipment is not inexpensive and I take general public and aviation safety seriously. 

I have developed pre-flight plans, and maintenance plan to make sure the aircraft is 

always in safe flying condition. 

REASONS FOR EXEMPTIONS

Exemption Request Section 333 of the FAA Reform Act & Part 11 of the Federal Aviation 

Regulations from:

14 C.F.R. Parts 21, 45.29, 45.23:

The aircraft has no area to display numbers or letters that are at least 2” in size. To my 

Knowledge there are no registration systems for UAS. We will place in the largest letters “Photos

from Above,LLC” on the top of the aircraft. 

14 C.F.R. 91.7:

To my knowledge there are no aircraft airworthiness certificates for UAS. We will before each 

flight run through the enclosed pre-flight checklist to ensure airworthiness.

14 C.F.R 91.9(b):
There is no cockpit to include said manual. Operating manual will be kept with PIC.

14 C.F.R. 91.103:

Since there will not be a FAA approved quadcopter manual to be provided we will need to be 

exempt. We will again follow our enclosed pre-flight checklist to ensure safety and 

airworthiness.

14 C.F.R. 91.109:

UAS are controlled by transmitter and do not have the capability for dual controls. It is our 

understanding there have been other aircraft approved without dual controls.

14 C.F.R. 119:

Since flights will never be above 400’ AGL and usually around 200’ AGL, we requested an 

exemption as the altitude cited in 14 CFR 91.119 would cause us to exceed said 400’ AGL.

14 C.F.R.91.121:

UAS does not have a traditional altimeter. The DJI Phantom 3 Professional uses sophisticated 

technology which enables precise GPS coordinates that gives real time positioning including 

altitudes and speeds all displayed on an Iphone or Ipad.

14 C.F.R. 91.51:

The UAS does not use traditional fuel but battery power. The battery provides for up to 23 

minutes of flight. Battery power levels will be monitored using an apple application which gives 

the PIC the capability to enable the return home feature telling the UAS to return home and land.

No flight will last longer than 18 minutes as an extra safety net. 

All batteries are only used if freshly charged, all batteries are visually inspected and volt tested 

before each flight.

14 C.F.R. 91.203:

There is no cockpit to include said certificate or registration documents. Any certificates, 

exemptions or registration documents will be with the PIC on the ground level.

14 C.F.R. 91.405, 91.407, 91.409, 91.47:

As there are no airworthiness inspections available therefore we request an exemption. Again we 

will perform pre-flight checklists to ensure safety. If our pre-flight checklist does not pass, we 

will abort flight. Any items of concern will promptly be repaired using similar components and 

records will be kept through maintenance records.

We are prepared to modify or amend any part of this petition for exemption to meet or exceed 

concerns of safety; we do look forward to working with the FAA to provide a great service to our

community and profession in a safe manner. 
Sincerely,

Caleb Owens

President

PHOTOS FROM ABOVE, LLC.
Pre-Flight Checklist

o Make sure you are using genuine parts and that all parts are in mint condition

o Ensure the remote controller, intelligent Flight Battery, and mobile device are fully charge

o Ensure that there is no foreign object stuck to the camera lens, the micro-SD card has been 

inserted into the camera, and gimbal can rotate freely before powering it on.

o Ensure the propellers are securely mounted onto the motors, and the motors can start and 

function normal.

o Make sure propellers are not chipped or damaged

o Check all electrical wiring for security

o Follow the on screen instructions to calibrate the compass

o Ensure the DJI pilot app and aircraft firmware have been upgraded to the last version

o Make sure your flight area is outside the No-Fly Zones and flight conditions are suitable for 

flying the Aircraft

o Make sure wind velocity is less than 15 MPH

o Before starting DJI Phantom make sure you are in an open area clear of trees, power lines or 

any obstacles. 

o Make sure you located at least 5 Miles from an airport unless received authorization from an

authorized personnel. 
o Make sure any by standby personal are at least 150 feet from DJI Phantom at all times when 

in operation. 

o Set up cones notify people of DJI operations in three distinct locations

Post flight

o Turn Off UAS

o Disconnect batter from UAS

o Set Radio control transmitter power switch to off

o Perform general visual inspection of UAS

Loss of Communication

o In the event of loss of communication with the UAS utilized the return home feature.