Jennifer Dobson

Photographer

443­420­7550

jenny@mdbusinessview.com

June 7, 2014

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12­140

1200 New Jersey Avenue, SE

Washington, DC 20590

To Whom It May Concern:

Summary:

I am applying for Section 333 Exemption of the FAA Modernization and Reform Act of 2012

(the Reform Act), Jennifer Dobson (the operator and PIC) hereby applies for an exemption

from Federal Aviation Regulations (FARs) detailed below to allow for commercial operations

of a DJI Phantom 3 four rotor UAS with an attached DJI H3­3D Gimbal Mount holding a

GoPro Hero 4 (Phantom 3) for the purpose of aerial photography and video for a variety of

industries. I also wish to exercise these privileges outside of the United States for the

purposes of providing travel photography and aerial imagery to tourist attractions in other

countries.

1. Personal information; Jennifer Dobson, 1315 McCurley Ave Catonsville MD

21228

2. Sections from which I seek relief

a. Part 21 Airworthiness Certification 21, Subpart H Certification

procedures for products and parts, Airworthiness Certificates,

b. Part 61 Certification: Pilots, Flight Instructors, and Ground

Instructors,

c. 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

3. I seek relief because these sections cannot be applied to the operation of

Unmanned aircraft. My operation/mission will be to perform aerial photography

and videography for a variety of industries including but not limited to real estate,

small business and tourist attractions inside and outside of the United States.
4. Granting of this request would be in the public interest because it allows access

to aerial imaging services to businesses and individuals that were previously

unaffordable and obtainable only by renting full size aircraft

5. Granting the exemption would not adversely affect safety because I would

comply with current safety standards including flying below 200 feet, flying a UAS

weighing under 55 pounds, operating during daytime visual flight rules, operating

within a visual line of sight of the pilots, staying 5 nautical miles (NM) from an

airport having an operational control tower; 3 NM from an airport with a published

instrument flight procedure, but not an operational tower; 2 NM from an airport

without a published instrument flight procedure or an operational tower; and 2

NM from a heliport with a published instrument flight procedure in addition to

following the protocols outlines below

1. The Phantom 3 has a maximum takeoff weight of less than 3 pounds and thus offers

a lightweight, small and compact video platform compared to manned aircraft.

2. Jennifer Dobson has trained on a computer with the aid of a simulator and has flown legally

within model aircraft parameters.

3. The Phantom 3 offers significant safety, noise, emission, security and environmental

benefits not available to larger manned aircraft.

4. The Phantom 3 has numerous safety features such as Failsafe mode, automatic

landing should signal between PIC and UAS be interrupted, GPS based altitude and

distance locks, Flight Limits function and low battery warnings. I feel that these

features addressed in more detail below and in the Phantom 3 User Manual provide

an equivalent level of safety.

5. Jennifer Dobson is an experience and responsible photographer operating in a safe

manner without any history of incident

6. Operations utilizing the Phantom 3 will provide a benefit to the general public and

serve the public interest by providing the service of aerial photographic images and

video to numerous businesses and individuals for considerably less than the previously

only available option of utilizing manned aircraft at an equivalent level of safety.

The Aircraft, Operations and an Equivalent Level of Safety

1. The safe operation of the UAS will be the first priority before, during and after every

operation.

2. The DJI Phantom 3 has a maximum takeoff weight of 1300 grams or approximately

2.9 pounds. It has a diagonal length of 350mm and a maximum speed of 15 meters

per second.

3. The UAS utilizes GPS location and is controlled by a 2.4 GHz transmitter.

4. All UAS operations will be conducted at Visual Line Of Sight (VLOS) at no more

than 200 feet AGL.

5. No UAS operations will be conducted within 5 NM of an airport.

6. No UAS operations shall occur over densely populated areas, large assemblies of
people, stadiums, government buildings, power lines, or major roads.

7. All nonparticipating persons shall be a minimum of 500 feet from the UAS.

8. If a nonparticipating person comes within 500 feet of the UAS, flight operations will

cease immediately.

9. All UAS operations shall take place during daylight hours under conditions

equivalent to Visual Flight Rules (VFR) with the UAS no more than 3/4 NM from the

PIC.

10. All operations will be within line of sight of the operator

12. The UAS will yield to all manned aircraft at all times.

13. All required permits and permissions will be obtained from local and state

government should they be required.

14. A pre­flight inspection will be performed prior to each flight to assure that

the UAS is safe for flight. A post­flight inspection will also be performed as an added

level of safety. An aircraft check will also occur after every two hours of flight.

15. At no time shall the UAS be operated with missing or manufacturer unapproved parts,

or in any condition that could pose a hazard to any other aircraft or structure or

person on the ground.

16. Prior to all UAS operations a pre­flight meeting will be held by the PIC to determine

the parameters of flight in a given location, any hazards present, weather conditions,

safety procedures at the specific location and approximate duration and route of

flight.

18. The Phantom 3 UAS will utilize GPS location, auto return home and will never be

operated at below 20% battery capacity.

The DJI Phantom 3 UAS is a small and safe sub 3 pound plastic and composite aircraft

utilizing four propellers driven by a 5200mAh, 11.1V, LiPo smart battery with an average

flight time of 17­18 minutes. The remote control/transmitter operates at 2.4 GHz. The

aircraft’s software can be calibrated to limit both AGL and distance from the transmitter.

The aircraft will automatically return to point of origin or descend in place should signal

with the transmitter be lost. The UAS is unmanned, operates at low altitudes, does not

run on combustible fuel, has very low decibel level noise emissions and has a small

payload capacity and short flight time, thus significantly reducing current risk levels

involved with utilizing manned aircraft for aerial photography.

Additionally, past purchasers of aerial photography have had to contract with manned

aircraft operations at a significant expense.

Based on all of these factors it my my belief that my UAS can be operated safely and to the

benefit of the general public. Thank you for your consideration.

Sincerely,

Jennifer Dobson

1315 McCurley Ave

Catonsville MD 21228

jenny@mdbusinessview.com