April 22, 2015

Federal Aviation Administration:

I would like to formally submit for an exemption from the following Section 333

regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a),  14 C.F.R. 91.7(a),

14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14

C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1)

and (2), 14 C.F.R. 91.417(a) and (b).  To operate DJI’s following UAS:  Phantom 2, Phantom

3, and Inspire 1 along the guidelines of the accompanying DJI Phantom 2, DJI Inspire 1, and

DJI Phantom 3 Operator’s manuals.  These UAS will be equipped with detachable cameras

and will be transported in proper storage.  This proposed exemption would allow me operation

of unmanned aircraft systems (UAS) for the purpose of aerial videography/ photography as a

service to the public/ business interests.  As found in exemption No. 11138 (Trudeau), the

FAA recently approved similar use of a Phantom 2 UAS.

Jean Marco De Luca Viglianti 

8609 Brookvale Dr, Windermere, Florida 34786

Mobile: (407) 569­8211

Email: jeanxlive@gmail.com

I, Jean Marco De Luca Viglianti, am writing pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, 

Jean Marco De Luca Viglianti, an owner and operator of small unmanned aircraft,

be exempted from the Federal  Aviation Regulations (“FARs”) listed below so that I, Jean 

Marco De Luca Viglianti, may operate a small ultra light weight unmanned aircraft system

(“UAS”) commercially in airspace regulated by the  Federal Aviation Administration

(“FAA”) in accordance with FAA UAS Regulations & Policies. 

These devices were selected because they have proven reliable flying capabilities 

managed by gyro stabilized flight, ground detection (phantom 3 and inspire 1) ,GPS aided 

navigation, a compass, blinking LEDs, failsafe mode for returning home and prop guards. 

This will act to further safety protocols exclusive to lightweight UAS’s specific to video and 

photography usage as I, Jean Marco De Luca Viglianti, record flight data and other

information gained through permitted flight operations to share with the FAA through any

required FAA reports to assists with future protocol and safety regulations.  
Specific section or sections of 14 CFR which I seek relief and the reason I seek relief:

14 C.F.R. Part 21:  Airworthiness Certificates

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to

mark certain words or phrases.  Further, the two­inch lettering is difficult to place on such a

small aircraft with dimensions smaller than the minimal lettering requirement.

14 C.F.R. 61.113(a) & (b):  Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a

commercially certified pilot would not correlate to the airmanship skills necessary for similarly

proposed operations in previously issued exemptions to this regulation through Exemption

Nos. 11062 and 11138.

14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the UAs in question, this regulation

is inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

Requires an aircraft flight manual in the aircraft, however there are no pilots or

passengers on board this aircraft and given its size, this regulation is inapplicable.  An

equivalent level of safety will be achieved by maintaining a safety/flight manual with the

operator.

Given the size and limited operating area associated with the aircrafts to be utilized by 

I, Jean Marco De Luca Viglianti, an exemption from Part 21 meets the requirements of an

equivalent level of safety under Part 11 and Section 333 of the reform Act. In all cases, an

analysis of these criteria demonstrates that the UA operated without an airworthiness

certificate, in the  restricted environment and under the conditions proposed will be at least as

safe, or safer, than conventional aircraft operating with an airworthiness certificate without

restrictions and conditions proposed. 

14 C.F.R. 45.23: Display of marks: general 
14 C.F.R. 91.119(c):  Minimum safe altitudes

The UAS utilize electronic GPS with a barometric sensor.  An equivalent level of safety

will be achieved by using this.

14 C.F.R. 91.151(a)(1):  Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries that

currently have a flight limit of approximately no more than 20 minutes.  Therefore, due to the

limitations of the batteries, it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b):  Civil aircraft: Certifications required

&

14 C.F.R. 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should be granted since they only apply

I, Jean Marco De Luca Viglianti will ensure that UAS do not operate any higher than

400 feet at ground level.  I will not fly over congested areas. I will plan operations before hand,

for proper flight safety, and proper height analysis as to avoid collisions.   

14 C.F.R. 91.121:  Altimeter settings 

Currently, there are no procedures for providing airworthiness certificates for the 

mentioned UAS.  I, Jean Marco De Luca Viglianti, however will always fly safely while having

the manuals of the DJI Phantom 2, DJI Inspire 1, and the DJI Phantom 3.   

14 C.F.R. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or 

alteration,

14 C.F.R. 91.409(a)(1) and (2):  Inspections 

to aircraft with an airworthiness certificate.  However I, Jean Marco De Luca  Viglianti, will

perform preflight inspections of the UAS before each flight as outlined in the operating

documents.  I, Jean Marco De Luca Viglianti, will also follow manufacturer recommendations

from said operating documents. 
Public Interest

Aerial photography and videography as an available service to the public allows for a

cheaper method to capturing imagery than its alternative.  Its alternative being aircraft and

helicopters.  They are expensive, create lots of noise, and are much more threatening due to

size and combustible fuel.

coordination to any official search and rescue or emergency services organization to benefit

the public.

Also as mentioned in the Trudeau exemption, exemption No.11138:

““Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or

more, are operated by an onboard pilot and may carry other onboard crewmembers, as well

as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and

crew will be remotely located from the aircraft. The limited weight reduces the potential for

harm to persons or damage to property in the event of an incident or accident. The risk of an

onboard pilot and crew during an incident or accident is eliminated with the use of a [sUAS]

for the proposed operation.”

Summary

● Flying the following UAS Safely

○ DJI Inspire 1

○ DJI Phantom 2

○ DJI Phantom 3

● Flying below 400 feet

 I, Jean Marco De Luca Viglianti, would gladly offer my services upon request and with proper 

I, Jean Marco De Luca Viglianti, am seeking exemption from the following rules: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a),  14 C.F.R. 91.7(a), 14 C.F.R. 

91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 

91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and 

(2), 14 C.F.R. 91.417(a) and (b) 

With the exemptions of the mentioned rules I, Jean Marco De 

Luca Viglianti, will be seeking to make my drone photography/videography services available

to the public.  Alternatively the public had seeked to use helicopters and aircraft to achieve

what I can offer in a safer, more cost efficient manner.  By not using combustible fuel,

flying at safe heights and strictly following the usage recommendations from DJI.   

These include but are not limited to:   
● Proper visual inspection of UAS before flights

● Keeping mentioned UAS in visual sight at all times when in operation

● Using an observer to assist if needed

● Remain well clear of and do not interfere with manned aircraft operations, and avoid

other aircraft and obstacles at all times

● Not intentionally fly over unprotected persons or moving vehicles

● Contact the airport or control tower before flying within 5 miles of an airport

● Not flying in adverse weather conditions such as high winds or reduced visibility

● Not flying under the influence of alcohol or drugs

● Ensure the operating environment is safe

● Not flying over sensitive infrastructure or property such as power stations, water

treatment facilities, correctional facilities, etc.

● Check and follow all local laws and ordinances before flying over private property

● Do not conduct surveillance or photograph persons in areas where there is an

expectation of privacy without the individual's permission. 

Respectfully, 

Jean Marco De Luca Viglianti

8609 Brookvale Dr

Windermere, Florida 34786

Mobile: (407) 569­8211

Email: jeanxlive@gmail.com