July 17th, 2015 

Peter J Closi Jr. 

8 Dolphin Rd. Key West, FL 33040

airadventuresllc@gmail.com

844-246-3594

Federal Aviation Administration: 

I, Peter J Closi Jr., holding a valid private pilot certificate and current medical 

certificate, am writing pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, to request that I, Peter J Closi 

Jr., an owner and operator of small unmanned aircraft, be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I may operate a small 

ultra light weight unmanned aircraft system (“UAS”) commercially in airspace 

regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA 

UAS Regulations & Policies. 

I would like to formally submit for an exemption from the following Section 333 

regulations: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b) to operate DJI’s following UAS: 

Phantom 2 and Phantom 3, along the guidelines of the accompanying DJI 

Phantom 2 and DJI Phantom 3 Operator’s manuals. These UAS will be equipped 

with detachable cameras and will be transported in proper storage. This 

proposed exemption would allow me operation of unmanned aircraft systems 

(UAS) for the purpose of aerial videography/photography and surveying as a 

service to the public/ business interests. They are similar in all material respects 

to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, 

and 11213.

These devices were selected because they have proven reliable flying 

capabilities managed by gyro stabilized flight, ground detection (phantom 3),

GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning 

home and prop guards. This will act to further safety protocols exclusive to 

lightweight UAS’s specific to video and photography usage as I, Peter J Closi Jr., 

record flight data and other information gained through permitted flight operations 

to share with the FAA through any required FAA reports to assists with future 

protocol and safety regulations. 

Specific section or sections of 14 CFR which I seek relief and the reason I 

seek relief: 
14 CFR 61.23(a) & (c): Operations requiring a medical certificate

14 CFR 61.101(e) (4) & (5): Recreational pilot privileges and limitations.

14 C.F.R. 61.113(a): Private pilot privileges and limitations: Pilot in command 

14 C.F.R 61.315(a) Privileges and limits of my sport pilot certificate

14 C.F.R 91.7 (a): Civil aircraft airworthiness 

14 C.F.R. 91.119(c): Minimum safe altitudes 

14 C.F.R. 91.121: Altimeter settings 

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

14 C.F.R. 91.405(a): Maintenance Required

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, 

rebuilding, or alteration

14 C.F.R. 91.409(a)(1) and (2): Inspections

14 C.F.R. 91.417 (a) and (b): Maintenance records 

Public Interest 

Aerial photography/videography and surveying using UAS as an available 

service to the public allows for a more cost-effective method to capturing imagery 

than its current alternative of utilizing larger aircraft. Additionally, I, Peter J Closi 

Jr., would gladly offer my services upon request and with proper coordination to 

any official search and rescue or emergency services organization to benefit the 

public. 

Also as mentioned in the Trudeau exemption, exemption No.11138: 

“Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. 

or more, are operated by an onboard pilot and may carry other onboard 

crewmembers, as well as 100 gallons or more of fuel. The petitioner’s [sUAS] 

weighs less than 3 lbs. The pilot and crew will be remotely located from the 

aircraft. The limited weight reduces the potential for harm to persons or damage 

to property in the event of an incident or accident. The risk of an onboard pilot 

and crew during an incident or accident is eliminated with the use of a [sUAS] for 

the proposed operation.” 

Summary

I, Peter J Closi Jr., am seeking exemption from the following rules: 
14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

and 91.417(a) and (b) 

With the exemptions of the mentioned rules I, Peter J Closi Jr., will be seeking to 

make my drone photography/videography & surveying services available to the 

public. 

These include but are not limited to: 

● Flying the DJI Phantom 2 and DJI Phantom 3 safely

● Flying below 400 feet 

● Proper visual inspection of UAS before flights 

● Keeping mentioned UAS in visual sight at all times when in operation 

● Using an observer to assist if needed 

● Remain well clear of and do not interfere with manned aircraft 

operations, and avoid other aircraft and obstacles at all times 

● Not intentionally fly over unprotected persons or moving vehicles 

● Contact the airport or control tower before flying within 5 miles of 

controlled airspace

● Not flying in adverse weather conditions such as high winds or reduced 

visibility 

● Not flying under the influence of alcohol or drugs 

● Ensure the operating environment is safe 

● Not flying over sensitive infrastructure or property such as power 

stations, water treatment facilities, correctional facilities, etc. 

● Check and follow all local laws and ordinances before flying over 

private property 

● Do not conduct surveillance or photograph persons in areas where 

there is an expectation of privacy without the individual's permission. 

Respectfully, 

Peter J Closi Jr. 

8 Dolphin Rd. Key West, FL 33040 

airadventuresllc@gmail.com

844-246-3594