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Petition for Exemption 14 CFR § 11.81

Exemption under SECTION 333

Name: Edilberto Yalan Quintana

Address: 7932 Jewelwood Dr. Boynton Beach Florida, 33437

Phone: 954-553-9826

Fax: 954 -530-3697

Email: eddyyalan@comcast.net

FAA Modernization and Reform Act of 2012 (Public Law 112-95). Section 333 of Public Law 112-95 

directs the Secretary of Transportation1 to determine whether “certain unmanned aircraft systems may

operate safely in the national airspace system . I am Airman Single Engine Land with a Pilot License # 

3538511. I currently have 120 Hours of flight time, also I am an experienced scale Model pilot who 

understand and practice a safety way to use this technology.I am simply petitioning for an exemption to 

provide a commercial service to private land owners and companies who wish to obtain and capture 

Aerial photos and videos of said property for purposes including real estate listings, Construction,

insurance property claims, and for use as a marketing tool for businesses. I would like to be able to 

accept 

payment for these services therefore making this a commercial use of a UAS.

Benefit to the Public

My services will benefits the public as a whole by providing Aerial Data Collection for Real Estate 

companies, Construction companies, Insurance companies and agents, and others who wish to 

Document their land or property. Construction companies will obtain Aerial view of roof for inspections 
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Without compromising the safety of any worker small business owners, can take advantage of these 

new

technology that now exists in the form of UAS’s. Video has become a juggernaut in the media field as it 

has empirically proven to be the most effective way to market a product. I the real estate industry 

Studies

have shown listings that have videos get 400% more traffic than those that don't! These video's get 

shared 

around the internet and allow for a wider pool of people to engage. Another benefits of using an 

unmanned aircraft would be:

Buyer’s point of view

• Make a decision based on the exterior or landscape of the property

• General overview of most busy street and intersection to avoid any incident 

• General overview of the neighborhood 

Seller’s point of view

• Showcase their property and making it more likely to sell faster.

• Marketing their property with the most advance technology

Reasons why the exemption would not adversely affect safety, or how the exemption would

Provide a level of safety at least equal to the existing rule

The Reason why the exemption will not adversely affect safety is because the education that I have in 

my 

airman career will guide me through always keep safety first. The experience obtain during the practice 

of many years in the operation and knowledge of safety precaution to avoid any potential unsafe

operation 

of the UAS. The exception will provide a level of safety with continue education of the safety operations 

for pilot or any other qualified operator to exercise safety to the general public and private property.
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Summary 

I, Edilberto Yalan Quintana am seeking an exemption of the FAA’s under Section 333 .

I am simply petitioning for an exemption to provide a commercial service to private landowners and 

companies who wish to obtain and capture Aerial photos and videos of said property for purposes 

including real estate listings, insurance property claims, and for use as a marketing tool for businesses. 

Being an FAA licensed Private Pilot, and certified AMA RC Pilot and therefore understanding the 

importance of different uses and safety concerns regarding FAA regulated airspace, I would be a good 

candidate for exemption of Sec 333 while not putting Air Safety in any accelerated risk. The specific 

UAS (Phantom 3 Advance whose Operating Manual is Included in my petition) I am seeking exemption 

with is one with many safety programs, including SAFE technology and GPS navigating. When flying for 

this commercial purpose I would be flying at a maximum altitude of 40 meters and flying mostly 

vertically for the purposes of taking photos, decreasing the risk of any interference. My general 

knowledge of the aviation safety systems implemented by the FAA would be used to ensure that safety 

would not be affected by my operations. I would not be flying near disaster areas, sporting events, or 

high 

traffic areas including airports, and I would pay attention to NOTAMS. I appreciate the FAA’s 

consideration of this petition for exemption.

Additional Information 

I am fully aware of the preflight safety checks and procedures implicated in the operation

Manual for the Phantom 3 Advanced and intend to implement preflight safety checks and 
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Utilize the Safety technology provided with this unit. I intend to only fly in non-populated, 

Residential Or rural areas and stay clear of all utility lines etc. I intend to be fully aware of

my Surroundings at all times and to only fly the unmanned aircraft within a visual line of 

Sight and only in Visual Flight Conditions (VFR rules) . I understand the and will comply with 

all the health and safety regulations for PIC’s and will be the only operator under this 

exemption.Operations of the DJI Phantom 3 Advance include the following information and 

operations 

DGI Phantom 3 Advance 

The Aircraft Specification Sheet 

Weight (Including Battery and Propellers)

1280 g (2.82 Lb. or 1.28 Kg)

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

 Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

 Horizontal: +/- 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude above Sea Level
5

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

DGI Phantom 3 Advance 

Remote controller 

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

Video Output Port

USB

Operating Temperature

0°C- 40°C

Battery

6000 mAh LiPo 2S

Mobile Device Holder

For tablet or phone

Receiver Sensitivity (1%PER)

-101 dBm ±2 dBm
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Transmitter Power (EIRP)

FCC: 20 dBm

CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Flight Mode

P- Mode (Positioning) P-mode works best when GPS signal is strong there are 3 different states of PMode. Which will be automatically selected by the aircraft depending of the signal strength 

P-GPS: GPS and vision positioning both are available. The Aircraft is using the GPS for positioning 

P-OPTI: Vision positioning is available but the GPS signal strength is not sufficient. The aircraft is using 

only the vision positioning system for positioning 

P-ATTI: Neither GPS and Vision Positioning System are used for stabilization. The Aircraft only uses its 

barometer. The Aircraft can still automatically return to the home point if the control signal is lost and 

The Home point was recorded successfully.

A-Mode (Attitudes) GPS and vision Positioning System are not used for stabilization. The aircraft only 

uses its barometer. The aircraft can still automatically return to the home point if the home point was 

recorded successfully.

*I intend to flight under P-mode all the times. *
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Regarding the UAS 

OPERATION LIMITATION 

 Unmanned aircraft must weigh less than 55 lbs. (25 kg).

 Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the 

operator or visual observer. 

 At all times the small unmanned aircraft must remain close enough to the operator for the 

operator to be capable of seeing the aircraft with vision unaided by any device other than 

corrective lenses. 

 Small unmanned aircraft may not operate over any persons not directly involved in the 

operation.

 Daylight-only operations (official sunrise to official sunset local time)

 Must yield right-of-way to other aircraft, manned or unmanned

.  May use visual observer (VO) but not required.

 First-person view camera cannot satisfy “see-and avoid” requirement but can be used as long 

as requirement is satisfied in other ways. 
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 Maximum airspeed of 100 mph (87 knots). 

 Maximum altitude of 400 feet above ground level.

 Minimum weather visibility of 3 miles from control station.

 No operations are allowed in Class A (18,000 feet & above) airspace.

 Operations in Class B, C, D and E airspace are allowed with the required ATC permission.

 Operations in Class G airspace are allowed without ATC permission

 No person may act as an operator or VO for more than one unmanned aircraft operation at 

one time.

 No operations from a moving vehicle or aircraft, except from a watercraft on the water

.  No careless or reckless operations.

 Requires preflight inspection by the operator.

 A person may not operate a small unmanned aircraft if he or she knows or has reason to 

know of any physical or mental condition that would interfere with the safe operation of a 

small UAS. 

 Proposes a micro UAS category that would allow operations in Class G airspace, over people 

not involved in the operation, and would require airman to self-certify that they are familiar 

with the aeronautical knowledge testing areas. Operator Certification and Responsibilities 

General Safety Precautions and Warnings I intend to follow

All operations will have the assistant of a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times.

• Always keep a safe distance in all directions around the aircraft to avoid collisions

 Or injury. This model is controlled by a radio signal subject to interference
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 from many sources outside your control.

• Always operate your model in open spaces away from full-size vehicles, traffic and people.

• Always carefully follow the directions and warnings for this and any optional support 

equipment (chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach

of children.

• Always avoid water exposure to all equipment not specifically designed and

 protected for this purpose. Moisture causes damage to electronics.

• Never place any portion of the model in your mouth as it could cause serious

 injury or even death.

• Never operate your model with low transmitter batteries.

• Always keep aircraft in sight and under control.

• Always move the throttle fully down at rotor strike.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Never operate aircraft with damaged wiring.

I have no intention of using this exemption outside the United States
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I Will Implement this new Procedures to ensure safety before and after flight

The DJI Phantom 3 Advanced comes with their own checklist (page 44 of Aircraft manual) but as 

a pilot in command I will implement my own.

DJI Phantom 3 Advanced 

Check List

Initial pre-flight 

1. Whether, wind speed, wing direction 

2. Check and revise a sectional chart ( controlled and uncontrolled airport or any other 

information)

3. Place Aircraft on the ground to use a GPS landmark for a takeoff and landing point. 
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4. Flight Plan ( What would be the best video and photo regarding the aircraft position)

5. Check Battery Levels on aircraft and remote control

6. Check propellers 

7. Transmitter ON 

8. Protection camera device OFF

9. Obstacle awareness 

10. RC Calibration for GPS Location before flight 

11. Check and revise a sectional chart ( controlled and uncontrolled airport or any other 

information)

12. The DJI digital controls are successfully connected to the aircraft

Start 

1. Clear Area

2. Remote Control ON 

3. Aircraft batteries ON

4. Camera is ready 

5. Beacon ON

6. Light ON 

7. Sticks on center position 

Takeoff

1. Slowly full throttle

2. Wind correction 

3. Slowly climb to 10 feet above ground

4. Run video 

5. Maneuver the aircraft 

6. Check for traffic and Obstacle awareness 

Climb
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1. Slowly climb to 50 feet above ground 

2. Check for obstacles

3. Maintain aircraft 10 feet away from object

Cruise

1. 50 feet above ground level 

2. 1 foot x /second 

3. GPS and compass

4. 10 feet away from any object

Landing

1. Reduce speed

2. Clear are to land 

3. Touch ground 

4. Propellers full stop 

5. Battery off

Aircraft Maintenance and Repairs

The Phantom 3 Advanced 

 I will have the Aircraft (UA) inspected every year (annual inspection by a 

qualified technician)

 Regular inspection (every month)

 Download any upgrade version for this model

 Check batteries

 Used only propellers without damage 
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Radio Control and Frequency (RF) (see pages 23 Manual)

The Phantom 3 Advance remote controller is a multi-function wireless communication 

device that integrates the video downlink system and an aircraft remote control system. 

The video downlink and aircraft remote control system operate at:

 Operating Frequency: 2.400 GHz-2.483 GH

 Max Distance (open area): 2km (1.2 miles)

 Transmitter Power: 20 dBm

 Working Voltage: 1.2 A @7.4 V

 Battery: Rechargeable 2S LiPo, 6000mAh

FCC Compliance (more information page 3 on the manual label Safety Guidelines)

This devise complies with part 15 of FCC rules. Operation is subject to the fallowing two 

conditions (1) device may not cause harmful interference, and (2) this device must 

accept any interference received, including interference that may cause undesirable 

operation.

Flight Limits and No-Fly zones 
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All unmanned aerial vehicle (UAV) operators should abide by all regulations set forth by 

government and regulatory agencies including the ICAO and the FAA. For safety 

reasons, flights are limited by default, which helps users operate this product safely and 

legally. Flight limitations include height limits, distance limits, and No-Fly Zones.

When operating in P-mode, height limits, distance limits, and No-Fly Zones function 

concurrently to manage flight safety. In A-mode, only height limits are in effect, which 

by default prevent the aircraft altitude from exceeding 1640 feet (500 m) .

Maximum flight altitude & Radius Limits

Maximum flight altitude and radius limits may be changed in the DJI Pilot app. be aware 

that the maximum flight altitude cannot exceed 1640 feet (500 meters). In accordance 

with these settings, your Phantom 3 Advanced will fly in a restricted cylinder, as shown 

below:

No-Fly Zones
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All No-Fly Zones are listed on the DJI official website at http://flysafe.dji.com/no-fly. NoFly Zones are divided into Airports and Restricted Areas. Airports include major airports 

and flying fields where manned aircraft operate at low altitudes. Restricted Areas 

include border lines between countries or sensitive institute. The details of the No-Fly 

Zones are explained as follow:

Airport

(1) Airport No-Fly Zone are comprised of Take-off restricted zones and Restricted 

Altitude Zones. Each zone features circles of various sizes.

(2) R1 miles (value of the R1 depends on the size and shape of the airport) around the 

airport is a Takeoff restricted zone, inside of which take off is prevented.

(3) From R1 mile to R1 + 1 mile around the airport the flight altitude is limited to a 15 

degree inclination. Starting at 65 feet (20 meters) from the edge of airport and radiating 

outward. The flight altitude is limited to 1640 feet (500 meters) at R1+1 mile.

(4) When the aircraft enters within 320 feet (100 meters) of No-Fly Zones, a warning 

message will appear on the DJI Pilot app.

Restricted Area

(1) Restricted Areas does not have flight altitude restrictions.

(2) R miles around the designated restriction area is a Take-off restricted area. Aircraft cannot 

take off within this zone. The value of R varies based on the definition of the restricted areas.
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(3) A “warning zone” has been set around the Restricted Area. When the aircraft approaches 

within 0.6 miles (1 km) of this zone, a red indicator in the remote control will alert the operator.
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Visibility As a Pilot in Command I Intent to fly only VFR condition below 400 feet AGL and 3 

Statute miles and clear of clouds.

I intent to Flying in the area of South Florida .This include, Miami, Broward in West Palm Beach 

The 3 Mayor class B airport are: Miami International (MIA) Fort Lauderdale International (FLL) 

AND West Palm Beach International ( PBI) I will no flying within 3 Miles close of these airport. I 

could be on the path of any aircraft in Final approach to land. Also I will keep away from any 

airport class C and Class D. I will keep a safety distance from 2 miles and always below 400 feet. 

Also Palm trees can be a potential hazard for operation of the UAS I will keep a safety distance 

of 20 feet. Radio and TV Antenna no just represent a potential obstacle but it can be cause 
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interference with the radio control I will flight 50 feet away ( The Phantom 3 Advance have the 

ability to return to the take off point in the event of lost radio signal )

II. - Regarding the Unmanned Aircraft PIC

Qualification 

Airman Certificate: Private pilot certificate number 3538511 with a total flight time of 120 hours 

Radio control airplane Pilot in command Member of the American Model Association (AMA) 

since 2009 with more than 580 hours of airplane and helicopter pilot.

Phantom 3 Advance (UAS) Pilot in command with more than 42 hours of operation.

I currently hold a class III pilot medical certificate (see copy)
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Conclusion 

Being an FAA licensed Private Pilot, a certified AMA RC Pilot and therefore understanding the

Importance of different uses and safety concerns regarding FAA regulated airspace, I would be

A good candidate for exemption of Sec 333 while not putting Air Safety in any accelerated risk.

The specific UAS (Phantom 3 Advanced whose Operating Manual is Included in my petition) I 

am 

Seeking exemption with is one with many safety programs, including SAFE technology and GPS

Navigating. When flying for this commercial purpose I would be flying at a maximum altitude of

50 meters and flying mostly vertically for the purposes of taking photos, decreasing the risk of

Any interference. My general knowledge of the aviation safety systems implemented by the

FAA would be used to ensure that safety would not be affected by my operations. I would not

Be flying near disaster areas, sporting events, or high traffic areas including airports, and I

Would pay attention to NOTAMS before each flight.
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Edilberto Yalan Quinatan

Operator