Petition for Exemption 14CFR § 11.81

Exemption Petition under Section 333

Name & Mailing Address:

Name: Kevin Leiss

Address: 20 Orchard Rd. Hummelstown, PA 17036

Email: kleiss33@gmail.com

Specific Section of 14 CFR from which you seek exemption:

Petition for Exemption under Section 333

The extent of relief you seek and the reason you seek the relief:

Section 333 prohibits the use of unmanned aerial drones on private property that is being used for commercial purposes. As 

an owner of a computer design and repair company, and a pilot of these devices for approximately 2 years, I am seeking a 

petition for exemption to be able to capture aerial video and photographs for real estate, construction, and other business 

services and accept payment for the capture of this material and editing of this material.

How your request would benefit the public as a whole:

By allowing this service as an option for customers and businesses owners, I would be benefiting small businesses and large 

businesses in the local area and allow for their customers to be able to sell homes quicker, or even generate new customers 

by allowing them to view material that was provided by me and my device that was captured in a safe manner.

Reasons why exemption would not adversely affect safety or how the exemption would provide a level of safety at 

least equal to the existing rule:

In addition to owning a small business for computer design and repair in Pennsylvania, I also am a full time Police Officer. 

Safety is paramount in everything and especially needs to be noted when these devices are being used. I have also had 

experience in flying, maintaining, and researching these devices for the last two years. The safety of air space and the 

general public is extremely important. This is another reason why the specific devices that are to be used (The DJI Phantom 

2 Vision +, DJI Phantom 3 Professional, or the DJI Inspire 1), have many safety features as well as fail safe and flying 

features that increase safety for the user and the general public and decrease risks of crashes or catastrophic failures. Some 

of these features include GPS navigation and stability control, return to home with lost receiver connections or range 

problems, warnings and automatic stability at specific height limits that are pre-set by the pilot, and the ability for first 

person view to monitor the flight via cell phone or tablet. I intend to fly this device no higher than 90 meters. Specific 

customers that have requested these types of flights are those owning local farm land or real estate in the area that cover 

several acres. Prior to each and every customer requesting this type of service a check would be performed to ensure that 

the device would not be flying near airports, high population areas containing active events, emergency or disaster areas to 

include wildfires, military/police operations, etc., and ensuring that the unit is only being used during clear days with clear 

weather, so that the device can be viewed at all times by eye while in operation.

The devices are intended to ONLY be flown in the following mode: GPS Mode

-Solid red lights (2) in the front, slow blinking green lights (2) in the rear

– During the use of this mode, the device is paired with GPS satellites allowing for stability (placing the control 

sticks in their neutral position the device will hover in the exact position without drifting). It also allows for 

stability control while flying, lessening the chance for drift, and allowing the unit to return to the take-off position 

automatically if the connection is lost, or if it is manually initiated with the controller. While in GPS Mode the 

device is unable to flip, or become completely vertical, making the unit safe and level within the air during the 

entire flight.
General Suggested Safety Regulations:

-Always ensure the aircraft, controller, and the Wi-Fi receiver are completely charged

-Keep the device and its moving components clean, dry, and the props in good condition

-Never fly out of eye sight

-Never fly the aircraft in highly populated areas, or in disaster or emergency areas

-Never fly the aircraft with known damaged components

-Never touch the props or other moving parts of the aircraft

-When the aircraft is not in use, remove the batteries for safety and safe keeping

-Never fly directly over people, vehicles, boats, etc.

-Always ensure the latest software/firmware is installed on the aircraft and the controller/receiver

A summary for the Federal Register:

I, Kevin Leiss, am petitioning for an exemption of the FAA's Section 333 rules for the prohibited use of unmanned aircraft 

for commercial purposes. This petition was generated because in addition to being a Police Officer I am also an owner of a 

computer design and repair company in the local area. With the use of these specific and precise aircrafts, the DJI Phantom 

2 Vision+, the DJI Phantom 3 Professional, and the DJI Inspire 1, I would be able to capture aerial photographs and video 

footage on private land for real estate, construction, and other businesses. This would allow these companies to gain new 

customers in the local area, and also allow them to increase their marketing techniques to be able to sell their services 

quicker. For this service I am intending on making a profit for the capture of these photographs and video on private 

property, as well as the editing of these photographs and video on private property. The device would never be flown more 

than 90-meters high, to allow for real estate agents and the like to capture large amounts of farm land etc. that they would 

like to sell. I would be the only pilot for this aircraft in these circumstances. Concerns for safety are paramount and all 

precautions to include the general setting in which the aircraft would be flown, distances to local airports, overviews and 

pre-flight checks of the aircraft, and weather conditions would all be taken into account. The aircraft would never be flown 

in emergency areas or disaster areas. The aircraft would also never be flown out of sight, and would only be flown for a 

maximum of 20 minutes at a time. I thank the FAA for the consideration in this petition for an exemption in reference to 

Section 333.

Additional information, views, or arguments to support request:

I am aware of the safety risks and concerns involved in this type of situation, and would ensure that I follow the general 

suggested safety rules listed above, the proper use of the device per the manufacturer’s manual, and would abide by all local, 

state, and federal laws that are implemented or would be changed in the future. No other pilot of the aircraft would be used 

at any time, except for a secondary controller on rare occasions that may control only camera functions and not flight related 

controls of any device. I appreciate your time in looking into this petition for an exemption, and the specifications of the 

aircrafts are listed below within the manufacturer’s manuals, and can be directly accessed by visiting either link for each 

device. 

Phantom 2 Vision + Manual:

http://download.dji-innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.1.1_en.pdf

Phantom 3 Professional Manual:

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf

Inspire 1 Manual:

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

(Format of petition example used from http://dronelawsblog.com/wp-content/uploads/2015/01/Kade_Curry_-

_Exemption_Rulemaking.pdf)