January	18,	2016

U.	S.	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	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:	

Part	45.23(b)	Display	of	Markings	

Part	21	SubH	Certification	procedures	for	products	and	parts,	Airworthiness	

Certificates	

Part	61	Certification:	Pilots,	Light	Instructors,	and	Ground	Instructors	

Part	91	General	Operating	and	Flight	Rules	

91.103(b)(2)	Preflight	action	

91.105	Flight	crewmembers	at	stations	

91.109	Flight	instruction	

91.119	Minimum	safe	altitudes	

91.121	Altimeter	settings	

91.151	Fuel	requirements	for	flights	in	VFR	conditions	91.405	Maintenance	

required	

91.407	Operation	after	maintenance	

91.409	Inspections	91.417	Maintenance	records	

Dear	Sir	or	Madam:	

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

and	 14	C.F.R.,	Northwest	Drone LLC	 (NWD),	an	operator	of	an	Unmanned	

Aircraft	System	for	aerial	photography/videography	for	the	marketing,	print	

and	sales	purposes	for	use	in	the	real	estate	industry,	hereby	applies	for	an	

exemption	 from	 the	 Federal	 Aviation	 Regulations	 to	 allow	 commercial	

operation	of	it’s	UAS.	NWD is	in	possession	of	a	DJI	Phantom	3	Professional.
The	 UAS	 operated	 by	 NWD weighs	 less	 than	 10	 pounds,	 including	 the	

payload	(i.e.	camera,	lens,	and	gimbal).	It	has	a	maximum	speed	of	34MPH,	

can	 hover,	and	 can	 simultaneously	move	 vertically	and	 horizontally.	NWD

will	 only	 operate	 its	 UAS	 in	 line	 of	 sight	 and	 has	 no	 use	 for	 real	 estate	

purposes	to	ever	fly	above	the	regulated	400ft.	Furthermore	NWD	keeps	a	

detailed	log	of	all	flights via	GPS and	tracking	data	that	will	verify	the	NWD	

is,	and	always	will	be,	 flying	 responsibly	and	under	current	FAA	guidelines	

and	 regulations.	 Operations	 of	 the	 UAS	 will	 be	 utilized	 for	 aerial	

photography	for	real	estate	purposes	in	localities	of	Pierce	and	South	King	

County	in	Washington	State.	The	majority	of	photos	taken	are comprised	of	

2	 story	 structures	 and	 residential	 homes which	 would	 not	 require the	

altitude	of	 the	UAS	 to	go	above	100	 feet.	Such	operations	will	insure	 that	

the	UAS	will	“not	create	a	hazard	to	users	of	the	national	airspace	system	

or	the	public.”	

The	Aircraft	and	it’s	operation:	DJI-Phantom	3	Professional

• This	UAS	has	flight	control	using	a	remote	control	operating	the	

5.728-5.85Ghz	frequency	in	compliance	with	FCC	regulations.	The	

range	extender	operates	within	a	frequency	of	2412-2462MHz	in	

accordance	with	FCC	regulations.	

• At	any	time	that	communication	is	lost	the	UAS	will	return	to	it’s	

take	off	location	at	a	height	of	approximately	60	feet.	

• The	UAS	locks	onto	multiple	GPS	satellites	to	establish	a	“home”	

position	prior	to	flight.	

• All	flights	will	be	operated	within	line	of	sight	by	the	pilot, (myself)

and	an	observer.	

• Maximum	flight	time	of	each	event	will	be	limited	to	15	minutes	or	

less,	this	will	leave	approximately	50%	of	reserve	time	on	the	UAS.	

• Flights	will	be	well	below	the	400	feet	AGL	requirement; NWD will	

never	operate	a	UAS	above	100	feet	AGL.	

• Flights	will	always	have	a	UAS	operator	and	a	camera	operator	who	

will	control	the	recording	via	the	DJI	application	on	either	a	smart	

phone.	

• UAS	operation	will	not	be	commenced	if	within	5	miles	of	an	airport,	

which	will	ensure	no	danger	to, manned	aircraft	traffic.	

• Preflight	procedure	will	be	as	follows:	
o Power	supply	test	of	UAS,	Controller,	Range	Extender	and	

DJI	application	device (tablet)	

o Calibration	of	compass	

o Weather	considerations	

o Flight	obstructions

o GPS	lock	of	no	less	than	6	satellites

o Link	between	controller	and	UAS

o Link	between	application	and	UAS

• All	maintenance	will	be	conducted	in	accordance	with	all	

manufacturer’s	specifications	

• All	maintenance	and	repair/modifications	will	be	logged	in	a	

permanent	file	for	future	reference.	

				• All	of	the	latest	firmware	will	be	updated	as	needed	via	the	DJI	software	

as	well	as	controller	calibrations.	

As	with	any	new	marketing	technology,	the use	of	the	UAS	would	benefit	

the	public	greatly	in	the	sales	and	marketing	of	new	homes allowing	the	

consumer	better	understanding	of	an	area	and	saving	them	time	and	

money	by	not	visiting	those	locations	that	are	not	conducive	to	their	needs.

With	20 years	in	film	production	and	photography	experience	under	my	

belt,	I	see	the	use	of	this	new	equipment	as	a great	addition	to	existing	

equipment	and	my	opinion	is revolutionizing my	industry.	In	addition	I,	

Dustin	J	Lowry,	personally	will	be	the	only	operator of	the	UAS	mentioned	

above	

If	you	have	any	further	questions	please	feel	free	to	contact	me at	253-973-

7663 or	email	to	dlowryaz@gmail.com

Thank	you	for	your	consideration,	Dustin	J	Lowry Owner	

Northwest	Drone	253-973-7663 dlowryaz@gmail.com

FAA	Small	UAS	Registration	Certificate	#:	FA3LLNLRY3

Dustin	J	Lowry

10515	47th St.	E.	

Edgewood	WA	98372