July 7, 2015

Attention: United States Secretary of Transportation

Mr. Anthony R Foxx

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Petition for Exemption, requesting relief from the FAA Modernization and Reform Act of 

2012, Public Law 112-95 FEB. 14, 2012, Section 333

Dear Mr. Secretary,

Whereas, Dennis Carvajal, P.A. (CARVAJAL) currently, under individual ownership by

Dennis Carvajal, seeks relief from airworthiness certification requirements from the above 

mentioned regulations.

CARVAJAL have acquired DJI Phantom 3 for the express purpose of providing aerial 

videography for Realtors and private homeowners.

CARVAJAL is represented by Dennis Carvajal, Realtor, and a 13 year member of the 

Florida Association of Realtors. 

Personal Information of Applicant: Dennis V. Carvajal

1430 S. Dixie Hwy, Suite 110

Coral Gables, Florida 33146

dcarvajal@onesothebysrealty.com

License # SL3034699

Since 9/3/2002 member in good standing

CARVAJAL seeks this exemption under the guidelines of Section333 specifically as it 

relates to the Real Estate Industry in the greater Florida area under the small UAS rule. We 

believe that we have put together a program as responsible operators of an UAS that will stand as 

an exemplary model on whom many others entering the market will emulate.

Under the terms of this exemption, it is our intention to safely fly an UAS, specifically a

DJI Phantom 3 with a Sony EXMOR 12 Megapixels camera. Additionally the drone vehicle 

maintains a FPV connectivity utilizing an Immersion 5.8 GHz 600mW antenna linked with a 

Lilliput 7 inch HD field monitor, allowing the pilot to see exactly what the camera sees. 

Additionally, our pilot wears a camera mounted pair of glasses in order to record the actual drone 

flight, ensuring a recording of safe and responsible flight.

As air safety is of paramount importance, CARVAJAL has developed a highly structured 

safety flight manual for our pilot as well as observer. As recent as the new proposed FAA 

regulation released as of February of 2015, CARVAJAL intends to operate well within the most 

stringent proposal required to operate an unmanned aircraft in the National Airspace System 

(NAS). We are prepared to attend any required course of study, participate in flight evaluation 
and pay any required fee(s) that may be instituted. We have hundreds of hours of safe flying in 

the recreational mode.

Petition for Exemption, requesting relief from the FAA Modernization and Reform Act of 

2012, Public Law 112-95 FEB. 14, 2012, Section 333.

The specific section or sections of 14CFR from which I seek relief are Title 14 Chapter 

1 Subchapter D parts 60 thru 67, specifically 61.1 to 61.429 regarding pilot certification. In

addition, I respectfully request the FAA grant exemptions from regulations that address general 

flight rules, pilot certificate requirements, manuals, maintenance and equipment mandates.

I believe that these requirements are unnecessary and tangential to the issue of pilot 

controlled drone flight. Additionally, current FAA proposals have omitted this as a future 

requirement for small UAV's. I request the use of an unmanned aircraft system (UAS) within the 

National Airspace System (NAS) until such time as final rules and regulations become effective, 

at which time, I will then comply with the aforementioned rules and regulations.

As to ensuring my security clearance, I voluntarily submit my name and all relevant 

information for clearance with any governing board having jurisdiction over this issue. I was 

vetted by the FBI when I became a US citizen and again was fingerprinted along with my

application as a Realtor with the State of Florida. I have never been charged with or convicted of 

any crime. I submit this information as true and accurate under penalty of perjury.

Re: Public Interest

I firmly believe that granting this exemption will allow for expanded access to the global 

real estate market. In many cases, homes/properties may have restricted or limited access due to 

numerous factors.

Many properties are “hidden” behind walls and landscaping, resulting in diminished 

“curb appeal”. Providing this relief would eliminate these problems and lead to increased 

commerce for both buyers, sellers, government taxation agencies, real estate affiliated 

companies, (title, escrow, notary), construction industry and home improvement businesses who 

rely on a thriving real estate market. Additionally UAV's provide for property inspections 

including roof and chimney that can assist in identifying hard to observe defects in 

manufacturing and installation. Camera mounted drones help mitigate accidents and death 

occurring from slips and falls which often result in liability claims and damages to all 

participants. Invariably, a reduction in risk to life and limb is a general benefit to the public 

interest. Lastly, aerial videography provides the viewer with safe access to the property vicinity,

eliminating needless driving to determine how close a property is to a freeway, school, and beach

or nearby unsightly development. This in turn reduces exhaust emissions and air pollution. Our 

UAV's utilize battery power and have no negative impact on the environment. When fully rolled 

out, these emission reductions will be measurable and significant.
In Conclusion:

I would like to add that we are committed to promoting the safe use of UAV's in general and 

specifically in regard to real estate and related services. We believe that by allowing “role

models”, the FAA can begin to establish responsible examples for the numerous flying devotees 

to come.

Sincerely,

Dennis V. Carvajal

1430 S. Dixie Hwy, Suite 110

Coral Gables, Florida 33146

Direct: 786.255.3334

dcarvajal@onesothebysrealty.com

License # SL3034699