U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE. Washington, DC 20590

Application/Petition for Section 333 Exemption

October 26, 2015

PETITIONER INFORMATION:

NAME: David Vaughan

COMPANY: Lens Fusion, LLC

ADDRESS: 808 E. Sherman Ave.

Nampa, ID 83686

CELL: 208­871­6262

EMAIL: lensfusion@gmail.com

Greetings,

Pursuant to Section 333; FAA Modernization and Reform Act of 2012, and 14 C.F.R. I request

this an exemption from the following Code of Federal Regulations (C.F.R.) in order to operate

my UAV, a DJI Phantom 3 Advanced Quadcopter Aircraft, in order to provide services for profit

to include aerial photography, aerial cinematography, aerial filming and photography for real

estate, construction firms, agricultural modeling, crop monitoring operations, aerial mapping,

other local businesses, special events included but not limited to weddings, private or public

parties/events, business advertising, promotional events, geological surveying, and

environmental studies. Safety will always be the primary concern regarding any flight at any

time.

The ability to provide these services to other local businesses and individuals in my community

will benefit them by opening up opportunities they otherwise did not have before. Traditional

methods of aerial photography/videography are simply not viable options for the average

consumer as they are costly and involve greater risks to everyone involved; such as the use of

larger aircraft carrying humans and flammable fuel. By utilizing the UAV the same results can be

achieved with much safer conditions.

I have flown my DJI Phantom 3 Advanced Quadcopter for the past three months, accumulating

over 100 hours of recreational flight time without incident. I seek this exemption to be allowed

legal commercial operation of my UAV, which will allow me to add aerial video and photography

services to the existing services I offer through my video production company, Lens Fusion LLC.

Upon being granted this exemption, I would be permitted commercial operation of my DJI

Phantom 3 Advanced quadcopter. The Phantom 3 is a quadcopter that can take off and land

vertically. It weighs approximately 3 lbs. and has a maximum airspeed of approximately 25

knots. This UAV uses batteries which have approximately 20­25 minutes of total charge time.
This gives this UAV approximately 12­15 minutes of flight time with sufficient remaining battery

charge to land safely. The particular model of Phantom 3 being utilized under this request for

exemption has First Person View (FPV) which allows the PIC to visually monitor certain

telemetry data on a ground station monitor including altitude (AGL), GPS signal strength, battery

charge information, etc. This FPV also gives the PIC video feed from the built in camera

showing what images are being captured. This is a significant safety feature as it visually

communicates the attitude of the UAV and its forward direction. However, this FPV feature will

never be used as a tool deviate from VLOS operation by the PIC.

Prior to each flight/operation of the UAV, I will conduct a pre­flight safety inspection. I will always

follow procedures outlined in the UAV operator's manual as to proper preflight inspection of all

hardware, software, environment and any other factors needed to ensure a safe flight. I will not

fly over densely populated areas or private property without the owner's' permission. I will only

operate my UAV within visual line of sight and will not fly it near airports or above 400 feet. I will

not fly in rain, high winds, or any weather conditions that will reduce visibility and compromise

my control of my UAV. I will yield right of way to all manned aviation activities at all time. I will

never operate my UAV while fatigued or under the influence of any type of mind altering

substance. Before and during every flight, I will be seeking to make my operation as safe as

possible.

The specific sections of 14 C.F.R from which I am seeking exemption are as follows:

14 C.F.R. Part 21, Subpart H; Certification procedures for products and parts, Airworthiness

Certificates

14 C.F.R. 91.103; Preflight action

14 C.F.R. 91.105; Flight crewmembers at stations

14 C.F.R. 91.109; Flight instruction

14 C.F.R. 91.119; Minimum safe altitudes: General.

14 C.F.R. 91.121; Altimeter settings

14 C.F.R. 91.151; Fuel requirements for flight in VFR conditions

14 C.F.R. 91.405; Maintenance required.

14 C.F.R. 91.407; Operation after maintenance

14 C.F.R. 91.409; Inspections.

14 C.F.R. 91.417; Maintenance records.

DJI Phantom 3 Advanced Specifications:

Gross weight (including propellers): 1280g

Diagonal Size (including propellers): 590mm

Maximum Ascent Speed: 5m/sec

Maximum Descent Speed: 3m/sec

Maximum Speed: 16 m/s

Radio Frequency (RF): 2.400 GHz­2.483 GHz

Camera: built­in 1080p video camera attached to underside of aircraft
Included with this petition are PDF files of the Phantom 3 Advanced Safety Guidelines, and

Battery Safety Guidelines. The full user manual for the Phantom 3 Advanced is available here :

http://www.dji.com/product/phantom­3/download. This manual contains additional detailed

information about the Phantom 3 Advanced. I have studied all parts of these documents as part

of my effort to operate my UAV as safely as possible.

I believe that exemption from the above listed Title 14 CFRs is warranted given the nature of the

UAV flights that will be undertaken, the size & weight of the UAV being deployed, the safety

precautions to the general public and the NAS I intend to adhere to, the positive environmental

impact the flight operations would have compared to manned fuel consuming missions and the

economic benefit my services would have in this new area of capturing videos and photos with

UAVs.

Thank you for your review of this matter. Please feel free to contact me at any time with

any questions regarding this matter.

Sincerely,

David Vaughan

Lens Fusion, LLC.