07-28-15 

Brenda Robeson 

Program Analyst, Airmen and 

 Airspace Rule Division 

Dear Ms. Robeson, 

Thank you for continuing your consideration for my request for exemption. Here is the 

additional information that you requested. 

1 - Desiree Ekstein's exemption would be in the public interest and be a benefit to 

the public as a whole for many reasons, environmentally and economically . By using 

an intelligent battery powered s'UAS with electronic motors it would a safe, efficient 

and economical alternative to the manned aircraft. Also by using a s'UAV it is an 

environmentally conscious alternative to the traditional aircraft with an internal 

combustion engine that would typically be used for aerial photography and 

videography. Thus reducing pollution and noise. 

Also, the UAV's operate at a much lower cost. Aerial videography and photography has 

traditionally been costly and has prohibited many small business owners access to this

service. By granting me this exemption I would have the ability to provide the service 

of videography and photography to the public at a much lower cost. 

2 - Reasons why granting my exemption would not adversely affect safety, or how 

the exemption would provide a level of safety at least equal to that provided by the rule 

from which I seek is because of the size, weight, speed and limited operating area of the 

unmanned aircraft set forth by the FAA. The DJI Phantom Vision 2+ and Dji Phantom 3 

Professional weigh less than 55#, carries no flammable fuel, air speed not more than 87 

knots. Due to the size of the DJI Phantom UAV's will poses no threat to the public. I 

have provided information regarding the Phantom UAV's they meet these requirements. 

I also will abide by the regulations set by Federal Aviation Administration and will not fly 

over 400' AGL, over private property, and Desiree Ekstein will fly at a distance at or 

greater than 5NM from the nearest airport. 

The Phantom offers additional safety features such as "Return to Home" if the GPS 

signal is lost (or it can be activated manually). I have also provided additional safety by 

installing prop guards on the UAV, and the specs sheet was included in my initial request 

but can be provided it needed again. 

For further safety, I plan to operate the UAV DJI Phantom within the line of sight with a 

visual observer, and while Desiree Ekstein is operating the DJI Phantom it would be with 

complete respect to privacy issues. 
 I, Desiree Ekstein, fully plan to operate my s'UAV in accordance with the FAA safe 

operating guidelines. Also being a female flyer, I intend to be an example to all people 

especially others in the industry, show proper procedures, and good ethics. 

3 - In support for my request for exemption, my exemption is similar to many that 

have already been granted. For reference, similar in material as #11062, 11109, 1112, 

11213. Also, Jake Coon # 12042 was granted exemption for a similar activity on July 15, 

2015. Mr. Jacob N. Anderson exemption #12181 granted July 28, 2015. And Martin L. 

Smith was also granted exemption for similar activities #12197. Ralph J. Apel was

granted exemption #11410. All with similar materials that I am seeking exemption for. 

I already stated in my original request, that Desiree Ekstein is seeking exemption from 14 CRF 

Part 21 certification for products and parts, sub part H - Airworthiness Certificates 45.23 (b), 

61.113 (a)and (b), 91.7 (a), 91.9 (b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a)and 

(b), 91.205(b), 91.215, 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 91.417 (a)and(b), part 91 sub part 

E of title 14, Code of Federal regulations. 

Exemption relief from Title 14 Code Of Federal Regulations sections 61.113a & b, private pilot 

privileges and limitations requesting relief to allow PIC (pilot in command ) from holding a 

current private pilot's license to operate the DJI Phantom. I will operate with an observer, 

within the visual line of sight. Also, the DJI Phantom vision 2+ and DJI Phantom 3 does not carry 

passengers. 

Desiree Ekstein would like exemption from Section 91.7a Civil Aircraft Airworthiness. I would 

like to follow the Airworthiness check list stated in the Manual of the DJI Phantom, as well as, 

visual inspection of the UAV to insure safe flight. 

Desiree Ekstein will follow the DJI Phantom Aircraft safety check regarding maintenance, 

overhaul, replacement, and life limit requirements. 

Request exemption from Section 91.119 Minimum Safe Altitudes. Desiree Ekstein will not 

operate the UAV not more the 400ft AGL and within 5 miles of an airport. 

Since my original filing, I have purchased the the DJI Phantom 3 Professional. I would like to 

extend my exemption to include the use of the Dji Phantom 3 as well. I am including the 

documentation and the manuals for this s'UAV. 

Thank you very much for considering my request for exemption. I am excited and looking 

forward to hearing back from you. 

Desiree EKstein