To Whom It May Concern:

VillaDirect Management LLC, a real estate and vacation rental company and operator of a small 

DJI quadcopter (UAS) equipped for photos and videos of properties and the Orlando, FL area, 

applies for an exemption from the listed Federal Aviation Regulations. This exemption would 

allow for commercial operation of the UAS, so long as such operations are conducted within and 

under conditions outlined herein or as may be established by the FAA as required by Section 

333.

The purpose of proposed flights will be to provide photographs and videos of real estate listings 

offered both for rent and sale. The photos and videos will also be used to promote tourism in the 

area, resulting in potential tax receipts for Local, State, and US Government.

The name and address of the applicant is:

VillaDirect Management LLC

Attn: David Pavlina

1420 Celebration Blvd. Suite 109

Celebration, FL 34747

Email: David.Pavlina@villadirect.com

The UAS & Flights

The UAS is a 2.2 lb battery powered quadcopter, a handheld transmitter for control, associated 

control receivers on aircraft, and 3-axis camera gimbal with GoPro 3 camera transmitter (FPV). 

The camera transmitter sends the camera view to a screen attached to the controller. This view 

is for image composition only, the UAS is controlled ONLY by line of sight. The UAS features:

1. GPS Assisted Flight - Allows quadcopter to hover when no commands are sent.

2. Return to Home - Allows quadcopter to fly back to launch spot, hover for 30 seconds, 

then slowly descend and land. This provides safety in case the controller loses power or 

pilot becomes disoriented.

3. No Fly Zone - Restricts quadcopter from entering airspace within 5 miles of an airport.

4. LED Status Lights - Gives pilot aircraft status through different sequences of blinking 

lights.

The UAS communicates with the controller at an operating frequency of 2.4GHz while the FPV 

system works on a frequency of 5.8GHz, ensuring the two frequencies will not interfere with 

each other and the UAS will fly smoothly.

The UAS will be flown with a Pilot in Command (PIC) and a ground based Visual Observer (VO) 

in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with

the following additional restrictions: 

1. All operations will occur in Class G airspace at no more than 400’ AGL. The majority of 

flights will be well below this limit at an average of 150’ AGL.

2. Any required permits will be obtained from local and state governments before flights.

3. Maximum flight time will be 15 minutes. Battery allows for 25 minutes of flight time. Battery is 

always fully charged before use.
4. The UAS will not operate within 5 miles of an airport.

5. All operations will be during the daytime and in ideal weather conditions with calm winds and 

clear skies.

6. Aircraft will remain in visual line of sight at all times.

7. VO will serve as additional eyes on the aircraft and be within voice reach to communicate 

with the PIC.

8. UAS will not fly in the area of any full scale aircraft. If a full scale aircraft enters the airspace 

of the UAS, the UAS will be landed immediately to provide right of way to the other aircraft.

9. UAS will never be used as an invasion of privacy and only be used for the purposes listed 

above.

10. I believe a private pilots license for the PIC (David Pavlina) is not applicable because of the 

restrictions listed above and the flight controls on the UAS are different than on a traditional 

aircraft.

Exemptions

14 CFR 91.9 (b):

The is no cockpit for the manual to be stored in. The manual is kept with the PIC.

14 CFR 91.109:

UAS are controlled by a transmitter and do not have the capability for dual controls. It is my

understanding there have been other aircraft approved without dual controls. 

14 CFR 91.119:

Since flights will never be above 400' AGL and usually 150' AGL, I requested an

exemption as the altitudes cited in 14 CFR 91.119 would cause me to exceed said 400' AGL.

14 CFR 91.121 :

UAS does not have a traditional altimeter. It does however have a GPS system that offers an 

altitude lock, ensuring the UAS never goes above 400’ AGL.

14 CFR 91.151:

The UAS uses battery power rather than traditional fuel. The battery provides up to 25 minutes 

of flight time, however flights will not last longer than 15 minutes and all batteries are fully 

charged before use.

14 CFR 91.203:

There is no cockpit to include listed certificates or registration documents. Any certificates,

exemptions or registration documents will be in the possession of the PIC on the ground.
14 CFR 91.405, 91.407, 91.409, 91.417:

There is no airworthiness inspections available therefore I request an exemption. If my pre-flight 

inspection does not pass, I will cancel flight. Any items of concern will promptly be repaired 

using similar components.

I am prepared to modify or amend any part of this petition for exemption to meet or exceed 

concerns of safety. I do look forward to working with the FAA to provide a great service to our 

community and profession in a safe manner.

Sincerely,

David Pavlina

Photographer - VillaDirect®