February 26, 2016

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 C.F.R. 21 Subpart H; 14 C.F.R 61.23 (a) and (c), 61.101 (e) (4) and (5), 

61.113 (a), 61.315 (a), 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), 91.417 (a) and (b)

Dear Sir or Madam, 

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

contained within 14 C.F.R. Part 11, I, Jason Lee, operator of an Unmanned Aircraft System (sUAS), 

hereby apply, on behalf of Vector Life LLC, for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of my SUAS, so long as all operations are conducted within and 

under the conditions outlined or as may be given by the Federal Aviation Administration (FAA) as

required in Section 333. 

I, Jason Lee, am experienced in flying multi-rotor helicopters as I use the DJI Phantom 3 Professional, DJI 

Inspire Pro, DJI Spreading Wings S1000 octocopter, and X8 Octocopter for recreational purposes at the 

present time. In order to operate my Phantom 3 Professional, Inspire Pro, S1000 Spreading Wings and 

X8 Octocopter for use in aerial videography and photography sales, real estate marketing, advertising, 

marketing, event promotions and closed-set filming. I, Jason Lee on behalf of Vector Life LLC, would like 

to formally request exemptions from: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 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). 

If granted these exemptions, I, Jason Lee, will comply by the regulations and restrictions set by the FAA’s 

grant. 

I request these exemptions in order to provide a cheaper alternative for real estate agents and 

homeowners compared to video or photo captured by manned aircraft. Vector Life, LLC would like to 

also provide aerial videography and photography to raise tourism to the Central Coast of California and 

benefit the marketing of the Pismo Beach Chamber of Commerce as well as San Luis Obispo County as 

hired. Special events would also be available for filming or photography, providing a unique view for 

special events in the area such as weddings and city events. Public safety will be affected positively by 

getting the same quality of footage for clients as previously taken with helicopters, but without the use 

of fuel based manned aircraft, saving energy, less released pollutants, and less possibility for a 

hazardous accident due to combustible fuel. 
Applicant: 

Jason Lee

Owner

Vector Life LLC

695 Price Street

Suite 102 

Pismo Beach, California 93449

jasonlee@vectorlife.com

805-295-6306

The requested exemption would permit the operation of a DJI Inspire Pro, DJI Phantom 3 Professional, 

DJI Spreading Wings S1000, X8 1000 Octocopter SUAS only under controlled conditions in the NAS that 

would be a) limited, b) controlled, c) predetermined and d) will provide safety improvements to the 

industry.

THE SUAS

1. DJI S1000 Octocopter

a. Dimensions: 41.14 in diagonal

b. Weight: 13 lbs

c. Max Speed: 20 m/s

d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI A2

2. DJI Inspire 1 Pro Quadcopter

a. Dimensions: 17.24in x 17.75 in x 11.85 in 

b. Weight: 7.5 lbs

c. Maximum Speed: 18 m/s

d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI Inspire 1

3. DJI Phantom 3 Pro Quadcopter

a. Dimensions: 23 in diagonal 

b. Weight: 2.8 lbs

c. Max Speed: 16 m/s

d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI Phantom 3

4. X8 Octocopter

a. Dimensions: 41.14 in diagonal

b. Weight:13 lbs

c. Max Speed: 20 m/s

d. Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC Compliant

e. Flight Controller: DJI A2

Similar operations for the DJI Phantom 3 Professional have been granted for exemptions by the FAA 

such as Exemption No. 13958 (Strickland) and Exemption No. 13961 (McCartney). Similar operations for 
the DJI Inspire 1 have been granted for exemptions by the FAA such as Exemption No. 14118 (Gowdy)

and Exemption No. 13678 (Coffman) amongst more. The DJI Spreading Wings s1000 has also been given 

exemptions for similar operations as seen again in Exemption No. 13678 (Coffman) and Exemption No. 

14224 (Caccamo). The sUAS consists of their unmanned aircraft and attached cameras. 

The Inspire 1 Pro only differs from the Inspire 1 by having an upgradeable camera, dual pilot operation 

and a 360 degree unobstructed view for your shots, thus not affecting safety negatively. Dual pilot 

operation in fact may make operation of the sUAS safer with two people in control of the copter rather 

than just one. 

sUAS OPERATIONS 

The drone will be safely operated by operating the sUAS only as described in their respective manuals. 

Pre-flight inspections would take place before every flight and will consist of the following: 

1. Make sure flight plan is in line with local regulations for sUAS flight. 

2. Check the environment for adverse weather, people or animals, hazardous objects, and 

magnetic interference. 

3. Inspect the sUAS

- Install propeller guards

- Confirm that all batteries are fully charged and free of damage. This includes 

batteries for the sUAS, remote controller and mobile device. 

- Inspect the propellers, gimbal, camera and remote controller for damage 

A post-flight inspection will also take place which includes looking over the sUAS after every flight to 

check for damage. The sUAS will be maintained and checked for safety in this way before and after 

every flight. It will be repaired properly through the manufacturer were it to be dysfunctional and 

logged in aircraft records that it underwent maintenance. 

I, Jason Lee, am qualified to fly the drone with over 100 hours of experience flying remote controlled 

mulit-rotor helicopters. I have been flying and building multirotor aircraft since March 2012. I received a

B.S. in Electrical Engineering from Cal Poly University. I have extensive knowledge of how to build, 

repair, & maintain an air worthy RC multi-rotor helicopter. My experience building and flying multirotor 

RC helicopters ranges from small pocket size quadcopters to large heavy lifters suitable for carrying 

payloads of 30 lbs. With this experience, I am able to make decisions ensuring the safest flight possible 

for the UAV. I have extensive knowledge of weather and how it affects RC flight and consider weather 

one of the most important factors when deciding the safety of the flight.

I have hosted two free DJI New Pilot Experience classes to help introduce multi rotor RC to the 

community. The New Pilot Experience not only covered the mechanical and software operations of the 

Phantom 3 but we focused a lot on flying safe in accordance with the safety training and guidelines from 

www.knowbeforeyoufly.org.

The sUAS will be used to capture aerial videography and photography for the use of sales, marketing, 

advertising, & promotions for the Central Coast. It would also be used upon hire for real estate 
marketing, special event filming, advertising and closed-set motion picture and television filming. The 

sUAS would not affect safety due to always being at the minimum distance of 500 feet from 

unparticipating persons and potentially hazardous objects such as vessels, vehicles, structures, magnetic 

interference and power lines etc. The sUAS will not fly within 500 feet of anyone’s property or person 

without their express permission. During the pre-flight check list the area will always be checked for 

people and animals before takeoff. These potential hazards will be avoided by utilizing the pre-flight 

checklist and keeping the sUAS within line of sight. 

The sUAS will not be flown in dangerous weather conditions such as: rain, snow or wind. It will be flown 

at a minimum of 20 ft. and a maximum of 400 ft. The sUAS will always be within a minimum of 500 feet 

below or less than 2,000 feet horizontally from clouds. 

There are some built in safety features for the DJI Phantom and Inspire sUAS that include: GPS Assisted 

Hover (a minimum of 12 satellites available at all times), a Vision Positioning System that assists in safe 

flights, the Return To Home feature allowing the sUAS to return home with the press of a button, and 

the Inertial Measurement System keeps the sUAS stable. The DJI Spreading Wings S1000 & X8 1000 have

an A2 flight controller which keeps it stable even in the case of losing a rotor.

Operations will take place over rural and private land in the state of California, mostly limited to the 

Central Coast. Property will not be flown over without the consent of the owners. The sUAS will not be 

operated within 5 miles of any airports without first advising them of estimated flight time and duration, 

elevation of flight and other need information. 

The sUAS will only be operated within line of sight of the visual observer (VO) and pilot in command 

(PIC). This will be ensured by not flying the drone further than 1,000 feet from the operator and VO. 

Exemptions Requested 

An exemption from 61.23 (a) and (c) has been requested because the sUAS will not be carrying 

passengers therefore there is little reason the PIC should need a medical certificate. A medical 

certificate wouldn’t be needed for the operation of a sUAS since it operates in controlled environments 

away from people and doesn’t carry passengers or the pilot. In this form of aircraft no one is at a large 

risk for needing medical attention the way one might on a civil aircraft such as a private or commercial 

flight. 

An exemption from 61.101 (e) (4) and (5), 61.113 (a), and 61.315 (a) has been requested because while 

normally a commercial license would be needed to further a business or to gain compensation, in this 

case getting a commercial license would be excessive as the sUAS does not carry property or passengers, 

instead only an attached camera. Compensation and the furthering of a business isn’t done through 

risky transportation means, but instead through capturing images. It’s in fact safer to gain aerial images 

through the sUAS rather than a manned aircraft given the sUAS’s small size and slow speed in 

comparison. A private license, recreational license or sport pilot certificate will already be a huge gain in 

safety as operating a manned aircraft is much more involved than a sUAS which would operate more

similarly to a remote controlled helicopter than a civil aircraft. A recreational license or sport pilot 
certificate is more than enough to ensure the sUAS is operated safely. Since the sUAS isn’t carrying 

passengers or property a recreational license should be in this case exempt from not being able to use 

the craft for business. The PIC will hold a private, recreational or sport pilot certificate along with a valid 

U.S. driver’s license. 

An exemption from 91.7 (a) has been requested because a certificate of airworthiness is not applicable 

as no certificate will be issued for the sUAS. Following requirements in the sUAS’s respective operating 

manuals and implementing pre and post flight checks however will give the same amount of safety as 

gaining a certificate of airworthiness. 

An exemption from 91.119 (c) has been requested because it would be unsafe for a sUAS to fly at the 

same altitude as civil aircraft. The sUAS is much smaller and not capable of such altitudes. Section (d) of 

91.119 allows for helicopters to operate at lower altitudes under specific conditions. An exemption for a 

sUAS would act similarly. The sUAS will never operate higher than 400 feet above ground level as has 

been the limit for other sUAS 333 exemptions such as Exemption No. 14003, 13910, 14005 and more. An 

equivalent level of safety will be reached as the sUAS will be operating at a safer altitude below 400 feet 

than it would at the approved altitude of civil aircraft.

An exemption from 91.121 has been requested because the sUAS will not have a barometric altimeter 

to set the “elevation of the departure airport or an appropriate altimeter setting available before 

departure.” An exemption would still allow for an equivalent level of safety as the sUAS is equipped with 

GPS and uses the system to navigate safely. Altitude can be checked before and during flight with the 

GPS. 

An exemption from 91.151 (a) (1) has been requested because the section prohibits flight unless there is 

enough fuel to operate from departure point to take off point with 30 minutes of fuel to spare during 

the day and 45 minutes of fuel to spare at night. The sUAS itself can only operate around 23 minutes on 

battery power. It is impossible to meet the amount of reserved fuel time currently set. An exemption 

would still allow for an equivalent level of safety as before every flight the sUAS battery will be checked 

to assure it is fully charged, as well as the battery on the remote and mobile device that acts as a screen. 

If any batteries are too low of power to successfully and safely land the sUAS back at its home point, the 

flight will be cancelled. This procedure must take place before every flight. If the battery reserve 

becomes less than 25% during a flight the sUAS must land. The size and speed of the sUAS also pose a 

much lesser risk than that of a civil aircraft not having a 30 minute or greater reserve of fuel. 

An exemption from 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), 91.417 (a) and (b) has been 

requested because the section only applies to aircraft with an airworthiness certificate which as 

explained earlier, the sUAS will not have. An equivalent level of safety will be achieved with pre-flight 

inspections before every flight. The operator will take care of needed maintenance by following the 

sUAS operating manuals. 
Public Interest 

While briefly mentioned earlier, granting these exemptions is best for the public because it will allow for 

small businesses to have better access to aerial photography and videography to promote and sell their 

own product and compete with larger businesses who could afford the high prices from the past. Aerial 

photography and videography can be done for much cheaper now when using a sUAS rather than a civil 

aircraft. 

Drone videography and photography benefits many industries including: construction, real estate, event 

planning, marketing, advertising, event promotions and more. 

Aerial photography and videography is also done at a safer capacity with drones as they are smaller in 

size, weigh less, and no one is on board the craft if something goes wrong. The sUAS doesn’t consume 

flammable fuel allowing for safer landing and safer accidents were they to occur. Less pollutants are 

released into the atmosphere as well since the sUAS do not use fuel. 

Summary for Federal Register

Pursuant to 14 C.F.R Part 11 Subpart A §11.81, a summary is provided for publication purposes: Jason 

Lee seeks an exemption from the following limitations: 

1) 61.23 (a) and (c)

2) 61.101 (e) (4) and (5)

3) 61.113 (a)

4) 61.315 (a) 

5) 91.7 (a)

6) 91.119 (c)

7) 91.121

8) 91.151 (a) (1)

9) 91.405 (a)

10) 91.407 (a) (1)

11) 91.409 (a) (1) and (2)

12) 91.417 (a) and (b)

An exemption would allow for Vector Life, LLC to use drones to benefit both the private and public 

sector in the following industries: 

- Real Estate

- Construction and Land development

- Event Promotions 

- Marketing 
- Advertising

- Aerial Videography and Photography

- Closed-Set Filming for Motion Pictures and Television

We will comply with the following limitations should this exemption be granted: 

1) Commercial operations will be limited to the aircraft specifically mentioned in this document: 

DJI Phantom 3 Professional Quadcopter, DJI Inspire 1 Pro Quadcopter, DJI Spreading Wings 1000 

Octocopter and X8 Octoctoper.

2) The sUAS will not be flown at a speed exceeding 25 m/s. 

3) The sUAS will be operated no higher than 400 feet above ground level. 

4) The sUAS will be operated in the visual line of sight of the PIC at all times. 

5) All operations will utilize a visual observer and the sUAS will be in his and the PIC’s line of sight 

at all times. The visual observer will be within talking or radio distance of the PIC and will keep 

his duties the entire flight time. 

6) The sUAS pilot will have a private, recreational, or sport pilot’s license and a valid U.S. driver’s 

license or FAA airman medical certificate. 

7) Operating documents will be available at all times the sUAS is operational and made available to 

the Administrator upon request. 

8) The sUAS will not fly before the PIC goes through the pre-flight check list. Post-flight the sUAS 

will always be checked for damage. 

9) We will follow the sUAS manufacturer’s manual in regards to maintenance, inspection and life 

limit of the craft. The manual will be followed in all other aspects. 

10) The sUAS will be operated during the day for safety precautions. 

11) The sUAS will not operate within 5 miles of the geographic center of an airport without first 

requesting permission the nearest control tower of estimated flight time and duration, elevation 

of flight and other need information. 

12) The sUAS will not be operated less than 500 feet below or 2,000 feet horizontally from a cloud. 

13) If the sUAS loses communication with GPS it will return home and land immediately. 

14) A flight will be cancelled if hazards come to light. 

15) The sUAS will not fly without sufficient battery power in the batteries of itself, the remote and 

the monitor. 

16) The radio frequencies used by the sUAS will be FCC compliant. 

17) The PIC of the sUAS will have required documents available when operating the sUAS and make 

them available to the administrator and law enforcement upon request. 

18) The sUAS will be clear of manned aircraft and give them the right away. 

19) The sUAS will not be operated in heavily populated areas. 

20) The sUAS will be operated at a minimum of 500 feet from nonparticipating persons, and 

property or vessels whose owners did not give permission to be flown over. 

21) All flights will operate only under Visual Meteorological Conditions. 

22) A Motion Picture and Television Operations Manual will be followed for all closed-set motion 

picture and television filming. 
Please feel free to contact me if you need additional information, 

Thank you for your time and consideration, 

Jason Lee

Vector Life LLC

695 Price Street

Suite 102 

Pismo Beach, California 93449

jasonlee@vectorlife.com 

805-295-6306