February 11, 2016

Chris Dantonio

2502 Rockwood Dr.

Jeffersonville Pa, 19403

215-720-5251

Ch.dantonio@gmail.com

U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590-0001

RE: Exemption Request Section 333 of the FAA Reform Act of2012 and Part 11 of the 

Federal Aviation Regulations

Dear Sir or Madam;

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333,

Chris Dantonio requests exemption from the Federal Aviation Regulations to allow for ·j···

commercial UAS operations of a DJI Phantom 3 Standard, for the purpose of aerial 

photography, real estate marketing, surveying, agricultural mapping, 3D mapping and other 

flight operations that could be performed safely and more cost effectively than a traditional 

manned aircraft.

Applicant:

Chris Dantonio

2502 Rockwood Dr.

Jeffersonville Pa, 19403

215-720-5251

Attachments:

1. Phantom 3 Standard Manual

Regulations from which the exemption is requested:

14 CFR 21, Subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b)(2)

14 CFR 91.103 (b)(2)

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a)(l)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)
14 CFR 91.203 (a) & (b)- Given the size and configuration, the UAS has no ability to carry a 

flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately 

carry a flight manual. An equivalent level of safety will be maintained by keeping the flight 

manual at the ground station where the UAS pilot will have immediate access to it.

Given the following sections only apply to aircraft with an airworthiness certificate, these 

sections do not apply to this applicant. As a safety precaution, the operator will perform 

preflight inspections and ensure UAS is in working condition before initiating each flight:

14 CFR 91.405 (a)

14 CFR 91.407 (a)(1)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following 

additional guidelines:

1. The UAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic

Control has been established.

2. Flights will not exceed the an airspeed of 36 mph (31.3 knots)

3. Flights will be operated at or below an altitude never exceeding 400 feet AGL.

4. The PIC and VO will communicate verbally at all times.

5. UAS operations will not be conducted during night.

6. All operations will be conducted under visual meteorological conditions.

7. The UAS will land with a minimum 30 percent battery reserve remaining.

8. The UAS will only be piloted within visual line of sight.

9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed

position and land if communication with the remote control is lost.

10. Preflight inspections and protocol will be followed prior to all operations.

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies.

Public Interest

We believe the use of a UAS in lieu of a manned aircraft would enhance safety and reduce 

the environmental impact compared to similar operations conducted with a manned aircraft 

carrying a crew and flammable fuel.

My inspections of infrastructure units, Waste Water Plants, Bridges

similar structures and homes will eliminate the risks associated with persons attempting to 

climb these structures. The photographs and video collected will provide engineers with 

valuable information as to the safety of these structures.

The use of a UAS in the real estate industry provides both the buyer and seller with a higher

level of marketing and service. The UAS is able to provide a view which encompasses the 

entire property in a single photo or short video clip. When compared to similar operations, 

utilizing a UAS poses much less of a safety concern for the general public with less fuel, 

time, noise and other resources.

Privacy

All flights will occur over private or controlled areas with the owner's consent. Capturing 

people in images will rarely occur. If a person is captured in a collected image they will have 

consented prior to filming or otherwise have agreed to being in the area prior to the filming 

taking place.

Chris Dantonio