Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

David Michael Greenlee

820 Capitol Street

Spencer, West Virginia, 25276

Email: mike@callgreenlee.com

Cell Phone 304-377-3758

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 do

marketing for real estate agents, Real Estate Sellers, Companies and private 

individuals. 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, 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 RC Pilot in Command 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 informed and aware of the FAA rules regarding UAS flights, safety and privacy

issues I can and will operate with an understanding of 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:

The UAS I use is a DJI Phantom II. The UAS is always flown according to safety 

standards and is linked to 6 satellites that determine its location at all times. The

software is updated and maintained at all times, which in turn keeps a safety net on the

UAS at all times limiting it from airspace near airports and off limits to UAS. I also have 

a working knowledge of these laws and take great care in abiding by all regulations in

regards to altitude, location etc. When flying for this commercial purpose I would be 

flying at a maximum altitude of 200 feet 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 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.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

A summary we can publish in the Federal Register

Federal Register — I, David Michael Greenlee 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 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. When flying for this commercial purpose I would be flying at a 

maximum altitude of 200 feet 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.

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

request;

I am fully aware of the pre flight safety checks and procedures implicated in the 

operation manual for the DJI Phantom II, DJI Phantom lll Advanced and intend to 

implement pre flight 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. I understand and will comply with 
all the health and safety regulations for PIC’s and will be the only operator under this 

exemption.

The specifications of the DJI Phantom ll UAS and transmitter signal is as follows:

Aircraft

Supported Battery

DJI 5200mAh LiPo Battery

Weight (Battery & Propellers included)

1242g

Hover Accuracy (Ready to Fly)

Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity

200°/s

Max Tiltable Angle

35°

Max Ascent / Descent Speed

Ascent: 6m/s; Descent: 2m/s

Max Flight Speed

15m/s (Not Recommended)

Diagonal motor-motor distance

350mm

Gimbal

Working Current

Static : 750mA; Dynamic : 900mA

Control Accuracy

±0.03°

Controllable Range

Pitch : -90°-0°

Maximum Angular Speed

Pitch : 90°/s

Camera

GoPro Hero 4 Black

Operating Environment Temperature

0 Deg C - 40 Deg C

Sensor size

1/2.3"

Effective Pixels

12 Megapixels

Resolution

3840×2160

HD Recording

4K fps 30

Recording FOV

110° / 85°
Remote Control

Operating Frequency

5.728 GHz-5.85 GHz

Communication Distance (open area)

CE Compliance: 400m; FCC Compliance: 800m

Receiver Sensitivity (1%PER)

-93dBm

Transmitter Power

CE Compliance: 25mW; FCC Compliance: 100mW

Working Voltage

120 mA@3.7V

Built-in LiPo Battery Working Current/Capacity

3.7V, 2000mAh

Range Extender

Operating Frequency

2412-2462MHz

Communication Distance (open area)

500-700m

Transmitter Power

20dBm

Power Consumption

2W

The specifications of the DJI Phantom lll Advanced UAS and transmitter signal is 

as follows:

Aircraft

Supported Battery

DJI 4480mAh LiPo Battery

Weight (Battery & Propellers included)

1280g

Hover Accuracy (Ready to Fly)

Vertical: 0.1m; Horizontal: 1.5m

Max Yaw Angular Velocity

200°/s

Max Tiltable Angle

35°

Max Ascent / Descent Speed

Ascent: 5m/s; Descent: 3m/s

Max Flight Speed

15m/s (Not Recommended)

Diagonal Size Including Propellers distance

590mm

Gimbal

Working Current

Static : 750mA; Dynamic : 900mA
Control Accuracy

±0.03°

Controllable Range

Pitch : -90°- +30°

Maximum Angular Speed

Pitch : 90°/s

Camera

Operating Environment Temperature

0 Deg C - 40 Deg C

Sensor size

1/2.3"

Effective Pixels

12 Megapixels

Resolution

2704×1520

HD Recording

2.7K fps 30

Recording FOV

110° / 85°

Remote Control

Operating Frequency

2.400 GHz-2.483 GHz

Communication Distance (open area)

CE Compliance: 400m; FCC Compliance: 800m

Receiver Sensitivity (1%PER)

-101dBm +/- 2 dBm

Transmitter Power

CE Compliance: 16mW; FCC Compliance: 20mW

Working Voltage

1.20 mA@7.4V

Built-in LiPo Battery Working Current/Capacity

3.7V, 2000mAh

Range Extender

Operating Frequency

2412-2462MHz

Communication Distance (open area)

500-700m

Transmitter Power

20dBm

Power Consumption

2W

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 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.

Respectfully Submitted,

David Michael Greenlee

820 Capitol Street

Specer, WV. 25276

304-377-3758

mike@callgreenlee.com