Dear FAA,

I am writing for an exemption to be able to operate an unmanned aircraft system, specifically a 

DJI Phantom 2 Quadcopter, in order to obtain aerial photography and videography of real estate 

and resort property.

The DJI Phantom 2 Quadcopter has many safety features built into it. It has a compass that is 

calibrated before each flight assuring that it stays in place or flies accurately where the pilot is 

controlling it to go. It also has a built in GPS system that allows the UAS to know where it took 

off from. The PIC always has the UAS take off from an open, spacious area to ensure nothing 

interferes with the ascent of the aircraft. The UAS uses its GPS system if there is ever a loss of 

communication with the controller to safely fly itself back above its take off point. It will then 

hover for 30 seconds to allow any person below it ample time to notice it. The UAS will then 

slowly descend until it touches down at its original departure point and its propellers will stop 

spinning. The UAS is inspected before each flight and if parts of the UAS are ever found to be 

damaged, they are replaced before the next flight takes place. There is also a first person 

viewer (FPV) system attached to the controller. This allows the PIC to see the view from the 

UAS in order to make sure it is not close to any object that may obstruct its open flight path. 

Lastly, the UAS has a built in “No Fly Zone” feature that prevents it from entering a 5 mile radius 

around airports.

The DJI Phantom 2 communicates with the controller at an operating frequency of 2.4GHz while 

the FPV system works on a frequency of 5.8GHz, ensuring the two frequencies will not interfere 

with each other and the UAS will fly smoothly.

The PIC has previously logged 6 hours flying the DJI Phantom 2 and would continue to log 

practice hours in open spaces once a certificate has been granted. Also, when in operation a 

visual observer would assist the PIC in order to have an additional set of eyes on the UAS. In 

case of an unlikely emergency involving a serious injury, the PIC is CPR certified. 

The UAS will be used to acquire aerial photography and videography of real estate and resort 

ground property for marketing purposes. Before flights take place, the PIC ensures there are no 

hazards in the flight area. The PIC also works with the staff at resorts so everyone is aware that 

the UAS will be flying overhead and where exactly it will fly.

DJI Phantom 2 Quadcopters can only reach a maximum speed of 33 miles per hour, and 

because this will be used for marketing purposes where the end viewer will need to be able to 

focus on what is in the shot, the UAS will not be flying faster than 10 miles per hour. In addition 

to this slow flight speed, the UAS needs to be fairly close to the subject it is filming due to the 

wide angle lens on the camera. This means the UAS will typically be flying at a height no 

greater than 100 feet. During flight, the UAS will always be in view of both the PIC and spotter. 

The UAS will never been hidden by clouds or affected by weather conditions because the shots 

that are needed require bright, sunny conditions. This means the UAS will only be flown on days 

with a completely clear sky. The DJI Phantom 2 is battery powered and carries no fuel so the 

risk of fire following an incident due to fuel spillage is eliminated. The aircraft also weighs under 

6 pounds and this limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident.
The UAS will be operated in resort communities in order to get aerial views of certain homes as 

well as the resort clubhouses and pools. These flights will be done during off-peak seasons or 

hours so there will be as few people under the UAS as possible. This ensures safety as well as 

providing a more desired composition in the footage. The places we need to operate the UAS 

are not within a 5 mile radius of any airport, and as stated earlier, the DJI Phantom 2 physically 

can not fly within a 5 mile radius of an airport. The UAS will always be operated within VLOS 

and before operation, will always be check to make sure propellers and parts are in working 

order.

By using the UAS to acquire stunning aerial shots of resorts in Central Florida, we can show 

people great places they would want to visit, thus encouraging tourism. According to the United 

Nations Environment Programme website, “Tourism can induce the local government to make 

infrastructure improvements such as better water and sewage systems, roads, electricity, 

telephone and public transport networks, all of which can improve the quality of life for residents 

as well as facilitate tourism.” Encouraging tourism would benefit the public, especially in an area 

like Orlando where a majority of jobs are dependent on high levels of tourism. The following 

statistics are taken directly from the official Visit Orlando website:

• Tourism spending generated $50 billion in total business sales including direct and induced 

impacts on the region

• Tourism in Orlando generated $1.7 billion in state taxes and $2.3 billion in local taxes in 2011

• Approximately 36% of all jobs in the region are sustained by visitor spending

By motivating people to visit Orlando with our aerial footage, we are directly helping to maintain 

a high level of tourism in Central Florida. In doing so, people can continue to have jobs and the 

government can continue to receive tax money to improve life for the local public.

I completely understand the need for safety when it comes to flying the DJI Phantom 2 

Quadcopter but with the built in safety functions in addition to the precautions the PIC will take, 

it will always fly in the safest environment possible.

Sincerely,

David Pavlina