Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Name and mailing address. You may include other contact information such as a 

fax number, telephone number, or email address;

Name: Robert Baines

Address: 253 Post Road El Dorado, KS 67042

Phone: 316-841-3931

Email: rbaines1@cox.net

The specific section or sections of 14 CFR from which you seek an exemption;

Petition for Exemption under Sec 333

The extent of relief you seek and the reason you seek the relief;

Sec 333 prohibits the use of a UAS for commercial purposes on private property. I am an

experienced UAS pilot and a Commercial FAA Licensed Pilot and I’m 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 but not 

limited to real estate listings, 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.

How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for small business

owners, real estate agents, and others who wish to document their land or property to take

advantage of the technology that now exists in the form of UAS’s and allows them to do so

using an experienced UAS Pilot that understands how to safely operate such 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;

Being an experienced UAS pilot, Commercial FAA licensed pilot with over 2500 total hours, with 

over 1000 of those hours flying aerial pipeline patrol, I have an understanding and appreciation 

for potential risk to the safety of the public, therefore, I would be a good candidate for 

exemption of Sec 333 while not putting Air Safety in any accelerated risk.

The specific UAS (DJI Phantom 3 Professional) I am seeking exemption for have many safety 

features, including SAFE technology and GPS navigating. When flying for this commercial 

purpose I would be flying at a maximum altitude of40 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 intend to fly in primarily GPS Safe Flight:

Flight Mode – GPS Attitude Mode (Default) I

This mode allows the UAS to lock on a home GPS position as a failsafe to prevent loss of radio

control of the UAS due to unwanted interference or loss of power. Also includes built in no-fly

zones to restrict flight over airports, and other sensitive locations.

I intend to follow these suggested safety regulations

• Always keep aircraft in sight and under control.

• Always keep people and pets at least 35 feet (10 meters) away when the battery is connected.

• Keep children out of the vicinity of this product at all times.

• 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.

• Always have a first aid kit with you.

• Always have an appropriate fire extinguisher with you.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.
A summary we can publish in the Federal Register Federal Register —

I, Robert Baines am seeking an exemption of the FAA’s Sec 333 rules that does not allow the 

use of an Unmanned Aircraft to be used for Commercial purposes in regards to National 

Airspace Safety. 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, insurance property claims, and for use 

as a marketing tool for businesses. Being an experienced UAS pilot, Commercial FAA Licensed 

Pilot, I have an understanding and appreciation for potential risk to the safety of the public, 

Therefore, I would be a good candidate for exemption of Sec 333 while not putting Air Safety in 

any accelerated risk.

The specific UAS (including DJI Inspire and Phantom series products) I am seeking exemption for

have many safety features, 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.

Robert Baines
Any additional information, views, or arguments available to support your 

request;

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

manual for the above mentioned UAS and intend to implement preflight safety checks and

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.

UAS Specifications:

DJI Phantom 3 Professional: http://www.dji.com/product/phantom-3/spec

Exemption Requests:

The Title 14 CFRs exemptions that this request entails are 61.113(a) & (b); 91.7(a);

91.119; 91.121; 91.151(a); 91.405; 91.407(a); 91.409(a)(l) & (2); 91.417(a) & (b).
General Safety Precautions and Warnings I intend to Follow

• Always keep a safe distance in all directions around your model to avoid collisions

or injury. This model is controlled by a radio signal subject to interference

from many sources outside your control. Interference can cause momentary

loss of 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.

• Never touch moving parts.

If you want to exercise the privileges of your exemption outside the United States, 

you must state the reason.

I have no intention on using this exemption outside the United States