Heartland Aerial Photography

9246 Helena Road

Harbor Beach, MI 48441

October 19, 2015

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 and Part 11 of the 

Federal 

 Aviation Regulations

Dear Sir or Madam,

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

“Reform Act”), Heartland Aerial Photography (“Heartland”) seeks exemption from the 

Federal Aviation Regulations (“FARs”) detailed below to allow an Unmanned Aerial 

Systems (“UAS”) operations for aerial photography and videography services.

Application Information:

Heartland Aerial Photography

Contact: Debora Pawlowski

9246 Helena Road

Harbor Beach, MI 48441

Telephone: (989) 479-3145

Email: jdkpawlowski@yahoo.com
Aircraft and Equipment

Heartland will use the following unmanned aircraft (“UA”) for aerial photography and 

videography services. The UAs are widely used in the aerial photography and 

videography industry and have previously been approved in past FAA Section 333 

exemptions.

DJI Phantom 3Standard (http://www.dji.com/product/phantom-3-standard)

Regulations from which Exemption is Requested

14 C.F.R. 45.23 (b) Aircraft markings

14 C.F.R. 21; Subpart H Certification procedures, Airworthiness Certificates

14 C.F.R. 61.113 (a) & (b) Pilots, Flight Instructors, and Ground Instructors

91.7 (a) Airworthiness certificate

91.9 (b) (2) Aircraft flight manual

91.103 (b) (2) Preflight action

91.109 Flight instruction

91.119 Minimum safe altitudes

91.121 Altimeter settings

91.151 (a) Fuel requirements for flights in VFR conditions

91.203 (a) & (b) Aircraft certifications and registrations

91.405 (a) Maintenance required

91.407 (a) (1) Operation after maintenance

91.409 (a) (1) & (2) Inspections

91.417 (a) & (b) Maintenance records

Heartland understands the “Conditions and Limitations” that are likely to be included in 

the approved request for exemption and we are prepared to fully comply with them.

Safety

Heartland is committed to operating the UA safely. Flight operations will be conducted 

in accordance with the approved “conditions and limitations” from the FAA. 

Specifically, flight operations will be performed in the line-of-sight with a pilot in 

command (PIC). Flight operations will take place well below 400’ AGL. Safety and 

operation guidelines from DJI will be followed for each flight. The proposed DJI system 

has safety mechanisms to return to home via GPS if the control signal is lost. The UA 

will be landed prior to the manufacturer’s recommended minimum level of power. All 

flights will be conducted in rural areas and away from airports. The PIC has no criminal 

record and is in excellent health.
Public Interest

Currently, aerial photography is obtained by the use of manned aircraft. The use of UAS 

technology benefits the public by reducing the risk to human life due to manned aircraft 

accidents. Additionally, UAS reduces the environmental impact such as the absence of 

combustible fuels and the reduction of exhaust emissions and noise.

Conclusion

Thank you for considering Heartlands exemption request. Please contact me if you have 

any questions or need additional information.

Sincerely,

Debora Pawlowski

Debora Pawlowski, Owner

Heartland Aerial Photography