October 30, 2015

Dear Sir or Madam,

This letter is in response to your request to provide a more specific reason why, granting the 

request for exemption would be in the public interest. I apologize for not being enough specific 

in my first request. I have also included some additional information and views to support my 

request. 

At integration of my initial exemption request dated July 7th 2015 filed in Docket No. 

FAA-2015-2943 I’d like to submit what follows:

1. The Public will benefit From Real Estate Aerial Photography performed with a UAS, both in 

relation to safety and to the economy. I will provide safe, efficient, and economical aerial 

Photography. 

2. The Public will benefit form the fact that The DJI Phantom 3 is electric powered rather than 

having an internal combustion engine. This drastically reduces the levels of air and noise 

pollution compared to a traditional aircraft. the absence of fuel on board makes it even safer 

in the extremely unlikely event of a crash. 

3. The DJI Phantom 3 his a very small UAS and does not require a runway or an airport, 

decreasing therefore congestion of the NAS. The normal height for the type of operations 

that I intend to conduct would be around 100 ft, further reducing the conflict of interest with 

real aircrafts in the NAS. The very limited airborne time further reduces the risk. 

4. The Public will benefit from the safety of UAS operations. The DJI Phantom 3 Advanced, 

has many fail safe features that makes a crash highly improbable, but also weights only 

2,82 lb. and with no fuel on board has less potential for harm to life or property compared to 

a traditional airplane. 

5. Performing aerial photography with a UAS will benefit the local and national economy. 

Although aerial photography is not a new activity, the advent of UAS technology makes it 

safer and more affordable than ever before. New creative ideas can really open the door to 

new business, contributing to the overall economy of the United States of America. (Local, 

State, and Federal Taxes). The new UAS industries in general will create thousand of jobs 

and many investments. This will definitely benefit the public. 

6. The UAS industry, with research and development, and the continuous push for better 

products, will positively contribute to technology advancement and will become an essential 

part of commercial aviation. New systems, software, technologies will be implemented not 

only by other sectors of military and commercial aviation but possibly by also other type of 

industries. 

7. In the specific field of real estate photography, an aerial view of a property benefits the 

public because it would help buyers to make a better, more informative decisions. It would 

help builders in assessing locations or the progress of projects. It would benefit real estate 

agents in selling properties, insurers, developers, assessors and the whole real estate 

sector in general. There is a high demand for this service in the area where I live, and I will 

be ready to fulfill a lot of those requests if the exemption will be granted. 
Additional Information, Views and arguments to support my request

In addition to my views and arguments submitted with my initial request I’d like to add or 

reiterate what follows: 

1. The DJI Phantom 3 is one of the most advanced and safest small UAS on the market today.

2. Aerial photography performed with a small UAS, with no crew, passengers or fuel on board, 

inherently permits safer operation compared to those performed with a small airplane or 

helicopter. 

3. Exemptions have been granted for the same type of activity and for the same UAS in many 

cases. 

4. I’m a professional Airplane and Helicopter pilot and instructor with an impeccable safety 

record. I have been flying for more than 27 years and have more than 6000 flight hours. I 

know the FARs and I’m a daily user of Airspace. Safety is both essential and necessary to 

what I do everyday.

5. My DJI Phantom 3 Advanced is registered.

6. I will fully comply with any restriction or instruction seth forth by the exemption and with any 

other Federal, State or Local applicable regulation. 

In Summery I believe that the enhanced safety features of the DJI Phantom 3, a UAS system of 

very limited weight, speed and size, combined with the knowledge and experience of the 

operator (myself) and the safety practices listed in the ops manual (attached to my initial 

request) in conjunction with instructions and limitations seth forth by your authority, would make 

aerial photography, a very safe and efficient type of flight operation. It would be a much safer 

operation compared to a manned aircraft one. I believe that the granting of section 333 

exemption would benefit the local and national public interest at many different levels as 

explained above. 

Sincerely 

Pierluigi Lanciotti

Docket No. FAA-2015-2943