To Whom It May Concern: 

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

(the Reform Act) and 14 C.F.R Part 11, Whitewater Imagery Inc. 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. 

• 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: Whitewater Imagery. Attn: David Coppola: 845-656-1777

Email: whitewaterimagery@gmail.com Address: 19 Leo Ct. Poughquag 

N.Y. 12570 . Whitewater Imagery Inc. 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 Whitewater Imagery Inc. 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. The PIC is U.S. Citizen with zero 

criminal back ground and zero FAA violations and is greatly concerned 

in ensuring the public maintains their right to privacy. 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. Also the DJI Phantom 3 is sophisticated 

equipment with a built in program that does not even allow the drone to 

operate within 15 miles of the white house are other high security areas. 

Pilot In Command (PIC) 

Name: David Coppola FAA Certificate #: FA3E933YYL

Ø Prior to any UAS flight, the PIC shall be trained in all aspects of 

flight operations. Training will include, but is not limited to; Personal 

Computer Flight Simulation that is similar to the flight characteristics 

and control of the UAS to be used; actual flight training with the UAS to 
be used in a designated flight area. 

Ø  Prior to any commercial flight operations, the PIC shall have 

accrued at least 25 hours of documented flight time with the UAS being 

operated by Whitewater Imagery Inc. 

Ø  Prior to any commercial flight operations, demonstration of 

complete control of the UAS shall be maintained. Proficiency flights 

shall include all normal flight maneuvers such as takeoff; a figure "8" 

coordinated turn flight pattern; and landings. 

 Ø  The PIC shall not 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. 

Ø  The PIC 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 

Whitewater Imagery Inc. and the customer prior to any flights in order to 

avoid unnecessary distractions. Every effort shall be made to prevent 

non-essential personnel from interfering with the PIC in any way during 

flight operations. 

Ø  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 

Ø  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. 
 Ø  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 person 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) call the DJI 

Phantom 3 Professional, which consist of: 4k UHD video recording with 

fully stabilized 3-axis gimbal; Vision Positioning system allows stable 

flight.

 Ø  Flight battery and rechargeable remote controller. 

Ø  DJI Pilot app for IOS and Android allows live viewing and 

complete camera control. 

Ø  The Phantom 3 Professional carries a fully stabilized 3-axis 4k 

UHD video camera for smooth, crisp videos and still photos. 

Ø  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. 

Ø  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. 

Ø  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. 

Ø  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. 

Ø  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. (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/sMAX. Descent 

Speed: 3m/sMAX. Flight Altitude 6000mMAX. 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: 

Ø  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. 

Ø  Any required permits will be obtained from local and state 

government before flights. 

Ø  The Aircraft will not operate directly above human beings at any 

time or within 150 feet of human beings. 

Ø  Maximum flight time will be 18 minutes. Battery allows 23 

minutes of flight time. Batteries are inspected and always fully charged 

before use. 

Ø  The Aircraft will not operate within 5 miles of an airport/heliport 

without prior approval from said airport/heliport. 

Ø  All operations will be during the daytime and in ideal weather 

conditions of less than 15 mph winds and clear skies. 
Ø  Aircraft will remain in visual line of site at all times not to exceed 

1/4 miles from PIC. 

Ø  Visual observer will serve as additional eyes on the aircraft and be 

within voice reach to communicate with PIC 

Ø  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. 

Ø  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. 

Ø  UAS will never be used as an invasion of privacy and only be used 

for purposes listed above. 

Ø  The UAS will never be flown near, in or over stadiums; or over 

large gathering of persons. 

Ø  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 “Whitewater Imagery Inc.” 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 25 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. The quadcopter is also equipped with 
propeller guards to help prevent injury to any persons, animals, power lines, 

etc as well.

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, 

David Coppola

President 

Whitewater Imagery Inc.