Andrew	J.	Pond

Dock	House	Digital,	LLC

1548	Maple	Grove	Dr.

Johns	Island,	SC	29455

Phone:	(843)	743-3555

E-mail:	drew@dockhousedigital.com

Dear Sir or Madam:

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

“Reform Act”) and 14 C.F.R. Part 11, Dock House Digital, LLC (“DHD”) seeks an 

exemption from Federal Aviation Regulations (“FARs”) detailed below for the following 

described Unmanned Aerial System called in this application the DHD System, which 

includes an Unmanned Aircraft (UA) and ground station-based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

• €A lightweight (6.4 lb gross weight with all on-board equipment and no 

payload), battery operated fixed-wing UA in the form of a quadcopter that takes 

off and lands vertically, manufactured by DJI, Model T600, with a maximum 

speed of 50mph and dimensions of 17in. x 17in x 12in. modified by the applicant 

to carry the following equipment in flight; 

• €An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

• €An on-board camera capable of capturing imagery in the form of full color, 

high definition still photos and video; 

• €An on-board telemetry system that delivers flight data from the on-board 

flight computer to the on-board radio transmitter including altitude AGL, 

horizontal and vertical speed, compass direction of flight and direction back to its 

launch site; 

• €A 600mW, 5.8GHz on-board radio transmitter that transmits live video from 

the on-board camera plus all the flight data from the telemetry system described 

above; THE GROUND STATION-BASED PART OF THE SYSTEM:

• €A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UA while in the air; 

• €A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control 

the UA while in flight; 

• €A radio receiver receiving live video and flight data from the on-board camera 

and computer projects it all together onto a screen for the PIC to view during 
flight; 

• €A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA while in flight. The requested exemption would support an 

application for a commercial Certificate of Authorization to use the above 

described DHD System to support aerial photography and video primarily of real 

property, specifically individual properties of no more than two acres in size. We 

are a video production company who uses these aerial images solely to enhance 

our end product, giving our clients a view of their property, which cannot be 

established from any ground-based equipment. We do not seek any type of 

additional compensation from our clients to use this technology. This technology 

is used solely for professional-quality video production purposes. Our use of the 

UA is very minimal as we simply elevate the UA (to no more than 100 ft.), get a 

360 degree shot of the property, and then land the UA; a process of no more than 

8 minutes. The UA, for our purposes, is only used vertically, and never travels 

horizontally, minimizing any danger or threat to an individual.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

flight time of only 18 minutes, this offers little to no risk to national security as the 

maximum altitude intended for our use is less than 100 ft. Our use of the UA will never 

be closer than 30 miles to the nearest airport.

Low-level oblique photos and video from several angles are far more effective than 

ground- based imagery for displaying the characteristics of large, complex properties 

with several buildings and large trees. The applicant in the past has chartered 2-seat fullsized helicopters for this purpose, which has proven more costly than our business has 

been able to afford. The benefits of reduced cost and improved quality of presentation 

from the UA will be valuable to our business as a whole.

Additionally, we request that we be allowed to use our system to benefit first responders 

nearby who might require assistance, including fire fighters, the police, the sheriff, et al., 

while remaining subject to all limitations cited in this application as we do so.

The DHD System will be operated in the field with both a PIC and a VO in accordance 

with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with 

the following Restrictions:

. (a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

. (b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at 

an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; 

. (c) All operations must utilize a visual observer (VO). The VO and PIC must be able 

to communicate by voice at all times during a flight operation; 
. (d) Operations will be restricted to flights over private property with the permission of 

the property owner; 

. (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

§ 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA 

rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; 

. (f) All required permits will be obtained from state and local government prior to 

operation; 

. (g) The DHD System will not be operated over densely populated areas; 

. (h) The DHD System will not be operated at air shows; 

. (i) The DHD System will not be operated over any open-air assembly of people; 

. (j) The DHD System will not be operated over heavily trafficked roads; 

. (k) The DHD System will not be operated within 5 NM of an airport or heliport; 

. (l) The DHD System will not be operated over properties smaller than two acres in 

size; 

. (m) Operations will be restricted to day only and weather conditions equivalent to 

VFR; 

. (n) The PIC will brief the VO and property owner about the operation and risk before 

the first flight at each new location; 

. (o) No flight may be made without a Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight (see Appendix 

A). 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 

16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on 

the system and will complete a course of maintenance instruction as part of their initial 

training.

We submit that the combination of the UA's light weight, flight performance and ability, 

fully qualified flight crew and strict operation under the guidelines established in 

8900.227, and under all of the Restrictions (a) through (o) listed above, the FAA can have 

full confidence that the operation will have an equivalent or greater level of safety than 

manned aircraft performing the same mission.

The name and contact information of the applicant are:

Dock House Digital, LLC Attn: Andrew J. Pond Ph: 843-743-3555
The regulations from which the exemption is requested are listed below. Beside each 

regulation number is the page of the attached Addendum upon which each may be found 

together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21.................................Addendum Page 1 - 14 CFR 

91.203.................................Addendum Page 1 - 14 CFR 45.23, 

45.29..........................Addendum Page 2 - 14 CFR 91.9....................................Addendum 

Page 2 - 14 CFR 61.113, 61.133.......................Addendum Page 2 - 14 CFR 91.109, 

91.119, 91.121..............Addendum Page 3 - 14 CFR 

91.151.................................Addendum Page 4 - 14 CFR Subpart E (91.401 - 91.417) 

......Addendum Page 4 - FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) 

...Addendum Page 4

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional 

information or clarification. We look forward to working with your office.

Sincerely,

_______________________________________________________

Andrew	J.	Pond,	Owner	– Dock	House	Digital,	LLC