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### Petition for Exemption 14 CFR **§ 11.81**  **Exemption under**  **SEC TION**  **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 ai rspace system . I am Airman Single Engine Land with a Pilot License # 3538511. I currently have 1 20 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 who le 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 inspections2

Wit hout 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 usi ng 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 saf** **ety 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.3

**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 candida te 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 technolo gy 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 avia tion 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 NOTA MS. 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 preflig ht safety checks and4

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 t he 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 dBm6

**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 P Mode. 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 fo r 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 -**  **mod e all the times. ** *7



### 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.8

 Maximum airspeed of 100 mph (87 knots).  Maximum altitude of 400 feet above ground level.  Minimum weather visibi lity 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.  Require s 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 com municate 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 interference9

from many sources outside your control . • Always opera te your model in open spaces away from full - size vehicles, traffic and people. • Always carefully follow the directions and warnings for this and any o ptional support equipment (chargers, rechargeable battery packs, etc.). • Al ways keep all chemicals, small parts and anything electrical out of the reach of children. • Always avoid water exposu re to all equipment not specifi cally 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. • Alwa ys 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 States10

**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 Init ial pre -flight 1. Whet h er, 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.11

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 section al 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 o n 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 

## Climb12

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 damage13

**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:

 Operatin g 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** 14

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**15

All No- Fly Zones are listed on the DJI official website at http://flysafe.dji.com/no -fly. No Fly Zones are divided into Airports and Restricted Areas. Airports include major airports and flying fields where manned aircraft operate at low altitudes. Restricted Areas i nclude 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 limi ted 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.16

(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.17

**Visibility** As a Pilot in Command I Intent to fly only VFR condition below 400 feet AGL and 3 Statu te 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 c lose of these airport. I could be on the path of any aircraft in Final approach to land . A lso 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 h azard 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 cause18

interference with the radio cont rol 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 medica l certificate (see copy)19

**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 t echnology 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.20

Edilberto Yalan Quinatan Operator