James J. Guidici

19 Sugar Maple Ct.

Lake in the Hills, IL 60156

 224.678.9466 (Home)

 847.951.5448 (Cell)

jim.guidici@comcast.net

20 May 2015

Hon. Michael Huerta 

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from certain parts of the FARs. 

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, James J. Guidici (or the “Petitioner”), hereby applies for a summary 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow him to operate small 

Unmanned Aircraft Systems (“UAS”) for aerial data collection, under the conditions and 

limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively 

inexpensive UAS under controlled conditions in airspace that is (1) limited, (2) predetermined, 

and (3) would provide safety enhancements to the already safe news gathering operations 

presently using manned helicopters and airplanes. Approval of this exemption would thereby 

enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish requirements 

for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) 

of the Reform Act.

The name and address of the applicant and his Counsel:

James J. Guidici

19 Sugar Maple Ct.

Lake in the Hills, IL 60156

847-951-5448

jguidici@me.com
Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 3 

The Appendix describes the FARs from which an exemption is requested and summarizes the 

justification for each requested exemption.

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Administrator must determine which types of UASs do not create a hazard 

to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Adminstrator determines that such vehicles “may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. § 333(c) (emphasis added). The Secretary has delegated his 

aviation authority to the Administrator of the FAA. The Federal Aviation Act expressly grants 

the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a 

term defined under §40101 of the Act, which includes sUASs. The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this 

section or any sections 44702-44716 of the Federal Aviation Act if Administrator finds the 

exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 

44704; 14 CFR §91.203 (a) (1). 
Summary of Request:

As a long time radio control pilot, I am requesting an exception, and permission to use my UAS, 

DJI Phantom 2 Vision+ (further in this report are the detailed specifications of the UAS), for the 

purpose of taking aerial photos and videos for the home real estate business, and for commercial 

businesses real estate property in the suburbs of the greater Chicago area. This is a technology that 

is perfect for realtors to help the potential home buyer get a better perspective of the home and 

neighborhood they are considering. This is important in the rural and suburban areas, where the 

homes typically have a larger piece of real estate, with mature landscaping, large trees, and perhaps 

heavily wooded. Their view of the property will be greatly enhanced, providing for a perspective 

never before seen. For the commercial business owner, it helps them show a complete view of 

perhaps acres of their property for TV/Internet commercials, and /or on their websites, ie: auto 

dealers, enhancing their growth opportunities. I am also planning to purchase a DJI Inspire 1 this 

summer. This UAS is similar in many ways to the DJI Phantom Vision 2+. The differences are 

that is has an enhanced camera with 4K filming capability, it has landing gear that retracts, and its 

weight is 6.5 lbs. (the specs for this UAS are also included).

Why the exemption would not adversely affect safety:

This can be done very safely in a controlled environment, on private property, with limited airtime 

required, extremely low noise, in uncongested areas. The UAS will always be operated in a Visual 

Line of Sight (VLOS) environment, with an observer, and always under 400 feet.

Prior to flight, I go through a “pre-flight” checklist:

1. verify	propellers	are	properly	secured	and	not	damaged.

2. ensure	all	batteries	are	fully	charged	

a. UAS	battery

b. Transmitter/controller	battery

c. Wi-Fi	range	extender	battery

3. turn	on	transmitter	&	range	extender

4. turn	on	UAS	battery

5. initiate	a	“calibration”	procedure	for	the	Compass

6. place	UAS	in	a	safe	position	on	the	ground	for	takeoff	

7. turn	motors	on

8. verify	there	are	6	or	more	satellites	acquired

9. initiate	takeoff

10. hover	at	10	– 15	feet	and	verify	all	controls	are	operating	properly

11. initiate	flight	plan

12. upon completion	of	flight	plan,	ensure	a	safe	environment	exists	for	a	safe	landing,	and	

inspect	UAS	prior	to	another	flight	for	air	worthiness
Description of UAS:

The DJI Phantom Vision 2+ (UAS) operates on 5.8 GHz, and weighs 2.7 pounds. Serial # 

BF1613340486263. It has a very sophisticated flight control system (DJI NAZA–M V2), and 

includes a Gyro, Compass, GPS, and camera that is on a three axis gimbal. The flight system 

includes a “Failsafe” function, where if signal is lost, or interference occurs with the controller, or 

it fly’s out of range, the UAS will automatically return to its “home” position. It also provides 

altitude & radius flight adjustment settings, for maximum height and distance. 

It will also “altitude hold- auto hover” if radio control sticks are released. And, in order to increase 

flight safety and prevent accidental flights in restricted areas, the new firmware for the Phantom 2 

series includes a “No Fly Zone” feature. These zones have been divided into two categories: A -

large international airports and, B - small local airports. http://www.dji.com/fly-safe/category

Exceeding the control range of the remote control will trigger ‘Return-to-Home’, meaning the 

Phantom 2 Vision+ will automatically fly back to its takeoff point and land safely. 

Using Wi-Fi and a Wi-Fi Range Extender, the camera transmits live video to my Apple iPhone 6 or 

iPad Mini 2, all of which comply with FCC requirements. The DJI Vision App shows, altitude, 

direction of flight, distance from home, speed, location, number of satellites acquired, and battery

level. 

Pilot in Command (PIC) Background and experience:

I have 30 years experience in flying radio control UAS aircraft, and have been flying radio 

control airplanes since the mid 80’s. My current inventory totals 30 electric aircraft, including 

fixed wing prop planes, mostly WWII war birds, EDF (electric ducted fan) jets, and multi-copters. 

I am a Viet Nam veteran, USAF, and I am currently retired from the technology industry. I have

always been intrigued with any new technology, and generally have always been an early adopter.

I am a member of the Academy of Model Aeronautics, with a very good understanding of 

aeronautics, and I have always been an extremely responsible UAS pilot. I am in great health. 

Being retired, and on a fixed income, I would like to take advantage of my hobby skills, in a 

commercial way, to help generate additional revenue for living expenses. I have been into video 

and photography, as a hobby, my entire life. This new technology ties together, both of my long 

time hobbies. I am currently in process of getting my Sport Pilot Certificate, and I hold a valid 

drivers license from the State of Illinois.

Why the public would be served by granting this exemption:

I believe this is a technology that can benefit realtors and commercial businesses, in a huge way. 

The industry is anxious to have this technology enhance their ability to market properties from a

totally new perspective, because the aerial perspective is very impressive. By increasing their 

marketing potential it can increase home sales, benefiting Realtor, buyer and seller. That is a win, 

win, win. For the commercial business owner, that new aerial perspective can increase market 

awareness and growth, with greater recognition of business message, physical presence, inventory

(in the case of an auto dealer) and location. 
The Petition to use a UAS for aerial data collection and its proposed limitations are similar in all 

material respects to those approved by the FAA in Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), 11213 to 

Aeryon Labs, Inc. (see Docket No. FAA−2014−0642) and 11310 to Colin Hinkle (see Docket No. 

FAA-2014-0608). In those grants the FAA found that the enhanced safety achieved using an 

unmanned aircraft (UA) with the specifications described by the Petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew 

in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by 

this exemption is in the public interest.

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, and 

11310 also apply to the situation presented by this Petition. 

Respectfully Submitted,

James J. Guidici
APPENDIX

FAR section Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on 

vehicle 

Insufficient space on 

vehicle 

14 CFR Part 21 Aircraft certification 

requirements and 

procedures 

Designed for manned 

aircraft; not suitable for offthe-shelf UAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements 

designed for manned 

aircraft, not UAS; petition 

describes training for UAS 

operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned 

aircraft; not suitable for offthe-shelf UAS 

14 CFR § 91.9 (b) (2) Requirement for manual to 

be available in the cockpit 

No one aboard to read 

manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for 

registration and 

airworthiness certificates to 

be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 

14 CFR § 91.215 Transponder requirement Vehicle has insufficient 

useful load; will be 

operated below ATC radar 

coverage 

14 CFR § 91.405 (a) Inspection requirements Designed for manned 
aircraft; not suitable for offthe-shelf UAS 

14 CFR § 91.407(a) (1) Inspection approval 

requirements 

Designed for manned 

aircraft; not suitable for offthe-shelf UAS 

14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned 

aircraft; not suitable for offthe-shelf UAS 

14 CFR § 91.417 (a) & (b) Maintenance records 

requirements 

Designed for 

manned aircraft; not 

suitable for off-the-shelf 

UAS
Further details of the DJI Phantom Vision 2+, and a PDF of the manual can be viewed 

and downloaded here:

http://www.dji.com/product/phantom-2-vision-plus

Buy Now

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 Operating Environment Temperature

0-40

Sensor Size

1/2.3"

Effective Pixels

14 Megapixels

Resolution

4384×3288

Hd Recording

1080p30 & 720p

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 Frequenc

y

2412-2462MHz

Communication Distance (Open Area)

500-700m

Transmitter Power

20dBm

Power Consumption

2W

DJI VISION App System Requirement Of Mobile Device

iOS version 6.1 or above/ Android system version 4.0 

Mobile Device Support • iOS recommended: iPhone 4s, iPhone 5, iPhone 6, • iPhone 6 Plus • iPod touch 5 (available but not recommended: • iPad 3, iPad 4, iPad mini) • Android recommended: Samsung Galaxy S3, S4, • Note 2, Note 3 or phones of similar configuration
These are the specifications for the DJI Inspire 1. 

http://www.dji.com/product/inspire-1

Aircraft Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (Gps Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm
Gimbal Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

Iso Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

Fov (Field Of View)

94°

Cmos

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes
Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed fram

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported Sd Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating requir

Operating Temperature Range

0° to 40° C

Remote Controller Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

Eirp

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C
Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0-40° C

Battery

6000 mAh LiPo 2S

Charger Model

A14-100P1A

Voltage

26.3V

Rated Power

100 W

Battery (Standard) Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range -10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional) Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type
LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Positioning Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

DJI Pilot App Mobile Device System Requirements

iOS 8.0 or later

Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus

iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad

mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi 

 Samsung S5, Note 3, Sony Xperia Z3, Google 

 Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 

 mini

*Support for additional Android devices available as t

testing and development continues