Mr. Austin Evans

145 S. Country Club Dr.

Kenansville, NC 28349

Dear Sir or Madam,

I am writing pursuant of an exemption to 14 CFR 61.113(a) and (b), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to request that 

New Heights Filmworks can operate its unmanned aerial system (UAS) commercially in airspace 

regulated by the FAA. New Heights Filmworks is the product of high-demand for aerial 

videography. Its owner and operator, Mr. Austin Evans, is a commercial videographer who 

purchased a UAS, a DJI Phantom 3 Advanced, in June 2015. It was originally purchased for 

recreational videography, but an increasing demand for aerial video from Mr. Evans’ client base 

has led him to pursue commercial exemption for his UAS. Mr. Evans has been safely operating 

his UAS for more than five months now, making sure to follow all guidelines of recreational 

flying set forth by the FAA.

REGARDING THE UNMANNED AIRCRAFT AND ITS OPERATION: 

When flying, Mr. Evans always makes use of various safety features to ensure he stays within 

the FAA’s guidelines and creates no adverse impact to the safety of others. Features used include 

setting a maximum altitude of 400 feet, so that the aircraft will stop itself from ascending to an 

altitude higher than the law permits. Mr. Evans always operates the aircraft within his line-ofsight, or with a designated spotter, and he makes use of the flight data on his remote’s display to 

constantly monitor altitude, distance from himself, speed, location, etc. The remote controller’s 

display also shows a high-definition live-feed from the UAS’s onboard camera, so that if visual 

line-of-sight was somehow lost, it can be regained quickly. If visual line-of-sight was lost, and 

the video feed was lost, Mr. Evans has set up the aircraft’s autonomous “Return to Home” 

feature so that the aircraft will ascend or descend to 120 feet, return to a designated home point 

as established by GPS coordinates, and descend straight down to a safe, controlled landing. The 

aircraft will not reach speeds higher than 35 miles per hour, but is mostly operated while 

hovering in place or moving between 1-20 miles per hour. Mr. Evans utilizes GPS at all times 

during flights, to ensure the safety of the aircraft, the safety of others, and to record flight data 

for observation. 

The UAS is powered solely by battery, and is never operated when battery power drops below 20 

percent. The remote controller’s display shows battery percentage of the aircraft and the remote 

controller at all times, and it shows a graphic of how much flight time remains before the 

battery’s charge falls to 30 percent. Before each flight, the aircraft’s firmware is updated, the 

aircraft is inspected and calibrated before it leaves the ground. While flying for clients of New 

Heights Filmworks, Mr. Evans will record video of live events such as weddings and street 

festivals, and he will also record video for promotional use, such as real estate, golf courses, and 

car dealerships. While filming such events and locations, the aforementioned safety procedures 

will be followed without exception, to ensure the safety of the aircraft, people, property, and the 

environment.
REGARDING PUBLIC INTEREST: 

Granting this exemption would be in the interest of the public in multiple ways. Mainly, it allows 

clients of New Heights Filmworks to receive high-quality aerial footage that could otherwise 

only be obtained by a helicopter. Making use of a UAS such as the DJI Phantom 3 Advanced, 

instead of a helicopter or airplane, is not only more cost-effective, but also minimizes carbon 

emissions by utilizing battery power instead of fuel. The use of a UAS is also less invasive of 

others’ space in terms of noise pollution. Overall, the small environmental impact of the DJI 

Phantom 3 Advanced relative to traditional aircraft systems will improve the quality of life of 

those in the area the aircraft will be flown, both short-term and long-term.