# Petition for Exemption 14 CFR § 11.81 **Exemption petition under SEC 333**

David Michael Greenlee 820 Capitol Street Spencer, We st Virginia, 25276 Email: mike@callgreenlee.com Cell Phone 304

- 377

- 3758

**The specific section or sections of 14 CFR from w hich**  **yo u 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 es tate 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 listi ngs, 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 y** **our request would benefit the public as a whole:** My request benefits the p ublic 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 ex perienced RC Pilot in Command that understands how to safely operate such technology.

**Reasons w hy** 

**the exemption w ould 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 UA S:**  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. Wh en 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 theaviation 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 t o 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 w**  **e can publish in the Federal Register** Federal Register

— I, David Michael Greenlee am seeking an exemption of t he 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 compan ies 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 t he 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. Wh en 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 b e 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.

**An y additional**  **information, view s, 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 withall the health and safety regulations for PIC’s and will be the only operator under this

exemption.

**The specifications of the DJI**  **Pha ntom ll**  **UAS and transmitter signal is as follo** **ws: Ai**  **rcraft Supported Battery**  DJI 5200mAh LiPo Battery **Weight (Battery**

**& Propellers included)** 1242g **Hover A ccuracy** 

**(Ready to Fly)**  Vertical: 0.8m; Horizontal: 2.5m **Max Yaw A ngular Velocity**  200°/s **Max Tiltable An**  **gle** 35° **Max A scent / 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 Ac**  **curacy** ±0.03° **Controllable Range** Pitch :

- 90°

- 0° **Maximum A ngular 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: 100m W **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 A** **dv anced**  **UA S and transmitter signal is**  **as follows: Ai**  **rcraft Supported Battery**  DJI 4480 mAh LiPo Battery **Weight (Battery**

**& Propellers included)** 12 80 g **Hover A ccuracy** 

**(Ready to Fly)**  Vertical: 0.1m; Horizontal: 1 .5m **Max Yaw A ngular Velocity**  200°/s **Max Tiltable A ngle**  35° **Max A scent / Descent Speed**  Ascent: 5 m/s; Descent: 3 m/s **Max Flight Speed** 15m/s (Not Recommended) **Diagonal Size Including Propellers**  **distance** 590 mm **Gimbal Working Current**  Static : 750mA; Dynamic : 900mA**Control Ac**  **curacy**

±0.03° **Controllable Range** Pitch :

- 90°

- +30 ° **Maximum A ngular 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)**

- 101 dBm +/

- 2 dBm **Transmitter Power** CE Compliance: 16 mW ; FCC Compliance: 20 mW **Working Voltage** 1

. 20 mA@ 7.4 V **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 o perate 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 transmitte r 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 di sassembly • 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 w ant to exercise**  **the privileges of y our exemption outside the United**  **States, y ou 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, W V. 25276

304

- 377

- 3758

mike@callgreenlee.com