Petition for Exemption 14 CFR § 11.81 

Exemption petition under SEC 333 Your name and mailing address. You may include other contact 

information such as a fax number, telephone number, or email address;

Name: Carlos A Franklin

Address: 3900 S Ware Road

Phone: 956-802-5686

Email: cfrankling@gmail.com

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. I am a member of the Academy of Model 

Aeronautics and 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, weddings, special events 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 private sector to take advantage of the technology that now exists in the form of 

UAS’s and allows them to do so using an experienced and certified 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 a certified AMA RC Pilot (30+ years of experience) 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. The specific UAS (DJI Phantom 

2 Vision whose Operating Manual is Included in my petition) I am seeking exemption with is one with 

many safety programs, including SAFE technology and GPS navigating. 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 and videos, 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

.
A summary we can publish in the Federal Register Federal Register 

I, Carlos Franklin 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 to private sector who 

wish to obtain and capture Aerial photos including real estate listings, Weddings, special events, 

insurance property claims, and for use as a marketing tool for businesses. I’m a certified AMA 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. The specific UAS (DJI Phantom 2 vision whose Operating Manual is Included in my 

petition) I am seeking exemption with is one with many safety programs, including SAFE technology and 

GPS navigating. 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 and videos decreasing the risk of any 

interference. I would not be flying near disaster areas, or high traffic areas including airports.

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 2 Vision and intend to implement pre-flight safety checks and utilize the safety 

technology provided with this unit. 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.

My Membership Number in the Academy of Model Aeronautics is 86663 for 2015 I understand and will 

comply with all the health and safety regulations for PIC’s and will be the only operator under this 

exemption.

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.

• 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 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 of using this exemption outside the United States and will be flying within the Rio 

Grande Valley, Texas area.

Thank you for reconsidering my petition; I’m a citizen trying to further provide for my family by taking 

advantage of technology with safety in mind.

Carlos A Franklin.