Petition for Exemption 14 CFR § 11.81 

Exemption petition under SEC 333

Your name and mailing address. You may include other contact information such as a 

fax number, telephone number, or email address;

Name: John Bianco

Address: 47 Blair Road, Blandford, MA 01008

Phone: 413-561-3496

Email: john@janerohman.com

The specific section or sections of 14 CFR from which you seek an 

exemption; Petition for Exemption under Sec 333

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

Sec 333 prohibits the use of a UAS for commercial purposes on private property. I am a

member of the Academy of Model Aeronautics and am simply petitioning for an exemption to 

provide a commercial service to private land owners and companies who wish to obtain and 

capture Aerial photos and videos of said property for purposes including real estate listings, 

insurance property claims, land survey, farming and for use as a marketing tool for businesses. I 

would like to be able to accept payment for these services therefore making this a commercial 

use of a UAS.

How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for small business 

owners, real estate agents, farmers and others who wish to document their land or 

property to take advantage of the technology that now exists in the form of UAS’s and 

allows them to do so using an experienced RC Pilot in Command that understands how to 

safely operate such technology.
Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

I am an AMA RC Pilot and therefore understand the importance of different uses and safety 

concerns regarding FAA regulated airspace, I would be a good candidate for exemption of Sec 

333 while not putting Air Safety in any accelerated risk. The specific UAS’s (Blade 350qx and DJI

Phantom 2 whose Operating Manuals are Included in my petition) that I’ am seeking exemption 

for come with many safety programs, including SAFE technology, return home and GPS 

navigating. When flying for this commercial purpose I would be flying line-of-sight at a 

maximum altitude of 40 meters and flying mostly vertically for the purposes of taking photos, 

decreasing the risk of any interference. My general knowledge of the FAA rules would be used 

to ensure that safety and would not be affected by my operations. I would not be flying near 

disaster areas, sporting events, or high traffic areas including airports, and I would pay attention 

to NOTAMS alerts via my cell phone.

I intend to fly my aircrafts under these safe modes:

BLADE 350 QX

Flight Mode 0– Smart Mode (Default)

(Solid Green Indicator LED)

Stick Relativity– While in Smart Mode, the path of the aircraft will always follow the control 

stick input direction relative to the SAFE Circle, regardless of the direction the nose of the 

aircraft is pointing.

SAFE CircleTM– In most scenarios, the quad will not 

enter the SAFE Circle.

 Position Hold– The aircraft will hold its position when elevator and aileron inputs are at 

neutral.

 Self-Leveling– Brings the 350 QX to a level attitude when the elevator and aileron inputs 

are at neutral.

 Altitude Command– Altitude is relative to throttle stick position.

Flight Mode 1– AP Mode

(Solid Purple Indicator LED)

AP Mode This flight mode keeps the 350 QX in a steady hover and locked into position while 

the controls are held at neutral, making it ideal for image/video capture. 

 Control Input– While in AP Mode, the 350 QX follows the control stick input direction 

relative to the position and orientation of the aircraft rather than the position of the 

pilot. 

 Position Hold– The aircraft will hold its position when elevator and aileron inputs are at 

neutral. 

 Self-Leveling– Brings the 350 QX AP to a level attitude when the elevator and aileron 

inputs are at neutral. 
DJI PHANTOM 2

Failsafe Function The aircraft will enter Failsafe mode when the connection from the 

remote controller is lost. The flight control system will automatically control the aircraft to 

return to home and land to reduce injuries or damage. The following situations would make 

the aircraft fail to receive a signal from the remote controller and enter Failsafe mode: 

(1) The remote controller is powered off. 

(2) The remote controller is powered on but the S1 is toggled in the position triggering 

the Failsafe (this must have been configured in the PHANTOM 2 Assistant). 

(3) The aircraft has flown out of the effective communication range of the remote 

controller. 

(4) There is an obstacle obstructing the signal between the remote controller and the 

aircraft, essentially reducing the distance the signal can travel. 

(5) There is interference causing a signal problem with the remote controller. 

Failsafe works differently depending on the mode the aircraft is in when Failsafe mode is 

initiated whether it is in the Ready to Fly or Ready to Fly (non-GPS) mode. 

Ready to Fly (non-GPS) ---- Automatic landing The flight control system will try to keep the 

aircraft level during descent and landing. Note that the aircraft may be drifting during the 

descent and landing process. 

Ready to Fly ---- Automatic go home and land The flight control system will automatically 

control the aircraft to fly back to the home point and land.

I Intend to follow these suggested safety regulations

 Always keep aircraft in sight and under control.

 Always keep people and pets at least 35 feet (10 meters) away when 

the battery is connected.

 Keep children out of the vicinity of this product at all times.

 Always use fully charged batteries.

 Always keep transmitter powered on while aircraft is powered.

 Always remove batteries before disassembly.

 Always keep moving parts clean.

 Always keep parts dry.

 Always let parts cool after use before touching.

 Always remove batteries after use.

 Always have a first aid kit with you.

 Always have an appropriate fire extinguisher with you.

 Never operate aircraft with damaged wiring.

 Never touch moving parts.
A summary we can publish in the Federal Register—I, John Bianco am seeking an exemption 

of the FAA’s Sec 333 rules that does not allow the use of an Unmanned Aircraft to be used for 

Commercial purposes in regards to National Airspace Safety. I am simply petitioning for an

exemption to provide a commercial service to private land owners and companies who wish to 

obtain and capture Aerial photos and videos of said property for purposes including real estate 

listings, insurance property claims, land survey, farming and for use as a marketing tool for 

businesses. Being a member of the AMA, I therefore understanding the importance of different 

uses and safety concerns regarding FAA regulated airspace, I would be a good candidate for 

exemption of Sec 333 while not putting Air Safety in any accelerated risk. The specific UAS 

(Blade 350qx and DJI Phantom 2 whose Operating Manuals are Included in my petition) that

I’m seeking exemption for, come with many safety programs, including SAFE technology, return 

home and GPS navigating. When flying for this commercial purpose I would be flying at a 

maximum altitude of 40 meters and flying mostly vertically for the purposes of taking photos, 

decreasing the risk of any interference. My knowledge of the UAS safety guidelines

implemented by the FAA would be used to ensure that safety would not be affected by my 

operations. I would not be flying near disaster areas, sporting events, or high traffic areas 

including airports, and I would pay attention to NOTAMS. I appreciate the FAA’s consideration 

of this petition for exemption.

Any additional information, views, or arguments available to support your request;

I am fully aware of the pre- flight safety checks and procedures implicated in the operation 

manual for the Blade 350qx and DJI Phantom 2and intend to implement pre-flight safety 

checks and utilize the safety technology provided with this unit. I intend to only fly in nonpopulated, residential or rural areas and stay clear of all utility lines etc. I intend to be fully 

aware of my surroundings at all times and to only fly the unmanned aircraft within a visual 

line of sight and only in Visual Flight Conditions.

My Membership Number in the Academy of Model Aeronautics is 452467 for 2015

I understand that I will be the only operator under this exemption.

Operations of the Blade 350qx and DJI Phantom 2 include the following information and 

operations manual:

BLADE 350QX

Length 18.30 in (465mm)

Height 5.43 in (138mm)

Main Rotor Diameter 22.80 in (580mm)

Flying Weight 24 oz (680 g)

Airframe Blade 350 QX Quadcopter

Motors 4x Brushless Outrunner Motor, 1100Kv

ESCs 4x 10-Amp Brushless ESC

Battery 3S 11.1V 2200mAh 30C Li-Po

Charger 2–3S Li-Po Balancing DC Charger, 0.5–3A
Transmitter DSM2®/DSMX® compatible transmitter

DJI PHAMTOM 2

Aircraft 

Operating environment temperature -10°C to 50°C

Power consumption 5.6W 

Supported Battery DJI Intelligent battery 

Weight (including the battery) 1000g Take-off Weight ≤1300g 

Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity 200°/s 

Max Tilt Angle 35° 

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

Max Flight Speed 15m/s (Not Recommended) 

Wheelbase 350mm 

2.4GHz Remote Controller 

Operating Frequency 2.4GHz ISM 

Communication Distance (open area) 1000m 

Receiver Sensitivity (1%PER) -97dBm 

Working Current/Voltage 120 mA@3.7V

Built-in LiPo Battery Working Current/Capacity 3.7V, 2000mAh 

DJI Intelligent Battery 

Type 3S LiPo 

Battery Capacity 5200mAh, 11.1V 

Charging Environment Range 0°C to 40°C

Discharging Environment Range -20°C to 50°C

General Safety Precautions and Warnings I intend to Follow:

 Always keep a safe distance in all directions around your model to avoid collisions

or injury. This model is controlled by a radio signal subject to interference

from many sources outside your control. Interference can cause momentary

loss of control.

 Always operate your model in open spaces away from full-size vehicles, 

traffic and people.

 Always carefully follow the directions and warnings for this and any 

optional support equipment (chargers, rechargeable battery packs, etc.).

 Always keep all chemicals, small parts and anything electrical out of the 

reach of children.

 Always avoid water exposure to all equipment not specifi cally designed 

and protected for this purpose. Moisture causes damage to electronics.

 Never place any portion of the model in your mouth as it could cause 

serious injury or even death.
 Never operate your model with low transmitter batteries.

 Always keep aircraft in sight and under control.

 Always move the throttle fully down at rotor strike.

 Always use fully charged batteries.

 Always keep transmitter powered on while aircraft is powered.

 Always remove batteries before disassembly

 Always keep moving parts clean.

 Always keep parts dry.

 Always let parts cool after use before touching.

 Always remove batteries after use.

 Never operate aircraft with damaged wiring.

 Never touch moving parts.

If you want to exercise the privileges of your exemption outside the United States, you 

must state the reason.

I have no intention on using this exemption outside the United States