Shawn Straight

Owner

StraightEdge Creative, LLC

4533 Seils Way

Orlando, FL 32812

407-380-1601

EIN: 20-5696832

UAS CERTIFICATE NUMBER: FA3TL9H4K9

2/4/2016

FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from

14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

To whom it may concern:

My name is Shawn Straight. I am a freelance Graphic Designer and creative services professional. I own a design studio called 

StraightEdge Creative. I am petitioning for an exemption for Section 333 of the FAA Reform Act of the Federal Aviation Regulations.

I have been a creative professional for over 23 years and have owned my own business since September 10, 2001. Part of my business 

has been photography, videography, editing and production services. The use of a small drone for these purposes, will greatley enhance 

business opportunities for myself and my clients.

I will be able to provide exciting and cost-effective aerial photography and video to businesses throughout central Florida and the United 

States. As a small business owner, many of the businesses I deal with are a startups and other small businesses. Being able to provide 

aerial photography would give these businesses opportunities for marketing and growth that they may not otherwise be able to afford.

I currently own a DJI Phantom 3 Professional Camera Quadcopter. I have logged many hours with this specific drone as well as others. 

In addition, I have been flying various types of model aircraft (airplanes, helicopters, etc.) for over 10 years as a hobbyist and have 

become quite proficient. The opportunities for flying a drone (UAS) are increasing and very promising. I intend to use the drone within 

the limits of the law and public and personal safety. I am also in the process of attaining a pilot’s license. Until then, I have professional 

pilots that already have a 333 Exemption that can operate the drone for me.

I am very passionate about what I do and this is an extension of that passion. I am really looking forward to be able to receive an 

exemption and be able to provide these services to clients.

Thank you for your consideration.

Shawn Straight
Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a)

& (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 

91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), I, Shawn Straight, hereby apply for an exemption 

from Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of a UAS with camera for the purpose of aerial 

photography, cinematography and videography.

As the Reform Act allows the FAA to “establish requirements for the safe operation of such aircraft systems in the national airspace system,” I, 

Shawn Straight, will use the DJI Phantom 3 Professional to provide the following benefits and enhance or provide an equivalent level of safety: 

1. The DJI Phantom 3 has a maximum takeoff weight of less than 3 pounds and thus offers a lightweight, small and compact video platform 

compared to manned aircraft.

2. The DJI Phantom 3 offers significant safety, noise, emission, security and environmental benefits not available to larger manned aircraft.

3. The DJI Phantom 3 has numerous safety features such as Failsafe mode, automatic Return home feature should signal between PIC and 

UAS be interrupted, GPS based altitude and distance locks, Flight Limits function and low battery warnings. These features addressed in 

more detail below and in the Phantom 3 User Manual provide an equivalent level of safety.

4. Operations utilizing the DJI Phantom 3 Professional will provide a benefit to the general public and serve the public interest by providing the services of aerial photography and video to numerous businesses and individuals for considerably less than the previously only 

available option of utilizing manned aircraft at an equivalent level of safety. The Unmanned Aircraft System, Operations and an Equivalent Level of Safety The safe operation of the UAS will be the first priority before, during and after every operation. I will only operate in 

reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas. I 

will conduct extensive preflight inspections and protocols, during which safety carries primary importance. The DJI Phantom 3 has a maximum takeoff weight of 1300 grams or approximately 2.9 pounds. It has a diagonal length of 590mm and a maximum speed of 16 meters 

per second. The UAS utilizes GPS/GLONASS location and is controlled by a 2.4 GHz transmitter. All UAS operations will be conducted 

at Visual Line Of Sight (VLOS) at no more than 400 feet AGL.

5. No UAS operations will be conducted within 5 NM of an airport.

6. All nonparticipating persons shall be a minimum of 500 feet from the UAS.

7. If a nonparticipating person comes within 500 feet of the UAS, flight operations will cease immediately.

8. All UAS operations shall take place during daylight hours under conditions equivalent to Visual Flight Rules (VFR) with the UAS no more 

than 3/4 NM from the PIC. All UAS operations will have a PIC and a Visual Observer (VO) present and all operations will be within line 

of sight (LOS) of the PIC and VO.

9. The UAS will yield to all manned aircraft at all times.

10. All required permits and permissions will be obtained from local and state government should they be required.

11. At no time shall the UAS be operated with missing or manufacturer unapproved parts, or in any condition that could pose a hazard to any 

other aircraft or structure or person on the ground.

12. The Phantom 3 UAS will utilize GPS/GLONASS location, auto return home and will never be operated at below 20% battery capacity.

Petition for Exemption
The DJI Phantom 3 UAS is a small and safe sub 3 pound plastic and composite aircraft utilizing four propellers driven by a 4480 mAh LiPo 4s 

15.2v smart battery with a MAX flight time of 23 minutes. The remote control/transmitter operates at 2.4 GHz. The aircraft’s software has been 

set to FAA regulations of 400ʹ ceiling and recognizes zones around airports and forbids flight within 1.5 miles of the center of a type A airport, 

and outside the 1.5 miles up to 5 miles the altitude increase from 35ʹ to 400ʹ in a conical fashion. For example: at 1.5 miles out your limit is 35ʹ 

and at 3.25 Miles from the center the max altitude AGL is 217.5’. I think this feature is great and allows those who wish to take photos with 

their drone at say 10ʹ AGL 2 miles from an Airport, they are more than safe in doing so. The incorporated FLY SAFE technology also restricts 

flights in areas deemed not permitted by the FAA, for example Washington D.C.

The aircraft will automatically return to point of origin or descend in place should signal with the transmitter be lost. The UAS is unmanned, operates at low altitudes, does not run on combustible fuel, has very low decibel level noise emissions and has a small payload capacity and short 

flight time, thus significantly reducing current risk levels involved with utilizing manned aircraft for aerial photography.

Additionally, past purchasers of aerial photography have had to contract with manned aircraft operations at a significant expense. Shawn 

Straight’s UAS operations will provide a public benefit in allowing more people to access aerial photography and videography at a significantly 

lower price and in the process we will be providing that data at a greater or at least equivalent level of safety as compared to similar manned operations. It is the applicants belief that the small size of the Phantom 3 UAS, the basic operating parameters outlined above, the specific exemptions 

discussed below, the fully trained, certified and vetted crew and the equivalent level of safety provided at a much lower cost to the general public 

will allow the FAA to grant an exemption to Shawn Straight for commercial UAS aerial photography operations under the Reform Act of 2012.

The DJI Phantom 3 User’s Manuals links are as follows: 

Quick Start Guide:

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en_V1.2_1214.pdf

User Manual:

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.pdf

Conclusion

As I have only been flying the UAS for recreational /hobby purposes, I am excited that the opportunities that it will create for my 

business as well as my clients.’ My main goal in my business is to use my talents and skill to create opportunities for kindess and good. 

In that spirit, I always encourage my clients to do the same. This has helped me grow as a person and as a buiness owner, and, I hope, 

others as well.

I would like thank you for your consideration.

Sincerely,

Shawn Straight

Owner

StraightEdge Creative

4533 Seils Way

Orlando, FL 32812

407-380-1601

shawn@secreative.com