May 8, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, D.C. 20590

RE: Petition for Exemption

To Whom it may Concern,

My name is Joe Bulleit. I am writing today to request Exemption under Section 333 of the FAA 

Reform Act of the Federal Aviation Regulations from 14 CFR 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); 91.417(a)&(b).

I am a 48 year-old professional in the Real Estate Industry. I hold an Indiana Real Estate Broker 

License (Indiana License# RB14046318). Also, I am a long-time video production professional and a 

model and unmanned aircraft enthusiast. My intent is to legally and safely operate the DJI Phantom 3 

Advanced UAS to provide real estate photography and videography services in the Louisville KY and 

Southern Indiana metro area. The DJI Phantom 3 Advanced will be the only system operated. I have 

attached the operating and user documents for the system as additional supplements for this petition. No 

modification to the factory system is to be utilized. Please see attached supplemental documents.

My request is virtually identical to previously granted Exemption Numbers 11062, 11109, 11112, 

11138, and 11417, among others.

I have extensive experience in the safe operation of VLOS unmanned aircraft, having piloted several 

remote-controlled fixed wing planes, model helicopters, and multi-rotor unmanned aircraft, including 

The DJI Phantom Vision +, all without incident in hundreds of hours of flight. 

Public Interest

Like so many others who have been granted similar exemptions for the services to be provided, my 

position is that the operations to be carried out under this exemption are safer and more cost effective 

than using manned aircraft, and for those reasons are in the Public Interest. With regard to the RealEstate Industry specifically to which my commercial use will be limited, aerial photography and 

videography provides both the Seller and Buyer with vastly superior information as to the overall 

condition of the property being transferred. With the proposed UAS, these services which were once 

cost prohibitive with manned fixed wing aircraft can now be afforded by virtually any seller. This will 

help most of them find buyers more quickly and will also help sellers discover issues in need of repair

that could otherwise easily go undetected. These factors should considerably decrease Days on Market 

and result in happier buyers. This in turn leads to a more stable housing market, and greatly contributes 

to the overall economy.

The details of my request by Part and Subpart follow:

14 CFR 91.7(A) 

Prohibits the operation of an aircraft without an airworthiness certificate. I hereby request exemption 

based on previous Exemption No. 11138. The FAA has ruled that this make and model of aircraft 

(UAS) does not require an airworthiness certificate.
14 CFR 91.119(C)

States that no person may operate an aircraft below the following altitudes: over other than congested 

areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

I will never operate any UAS over an altitude of 200 AGL. The majority of the operations proposed will 

operate around 100 to 150 feet AGL as this usually provides the best angle of capture for the type of 

photography and videography operations proposed.

The UAS utilized for this exemption is of exceptionally light weight and is not capable of speeds over 

30 knots. The UAS is equipped with GPS guided auto pilot with a return home function in case loss of 

control by the operator and is powered by sealed batteries thereby reducing the chance of post impact 

fire to nearly zero.

14 CFR 91.121 

Altimeter Settings. 

I am requesting relief from 91.121 for the following reason. The UAS is equipped with GPS derived 

altitude capability, however due to the limited altitude requested in this exemption, the FAA has 

previously granted Exemption for these types of operations. Reference Exemption No. 11138 and 

11417

14 CFR 91.151(a)

No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast 

weather conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruise speeds

(a)(1)During the day to fly for at least 30 minutes.

I request relief from 91.151(a) due to the fact that the UAS is equipped with a battery and percentage 

indicator system. The UAS has a flight capability on full charge of approximately 20 to 25 minutes 

depending on camera usage and other variables. The maximum flight in my operations will be 10 

minutes on a fully charged battery. This constitutes landing with approximately 50 percent fuel 

remaining. This allows operation well within the parameters of the rule with a great margin of safety.

No UAS operations will be conducted at night, as defined by Federal Aviation Regulations.

14 CFR 91.405(a) 

Maintenance required; 

I request relief in part from 91.405(a)(1) based on the Protocols and Procedures Section on 

Maintenance and Maintenance Records. Also reference Exemption No. 11138 and 11417

14 CFR 91.407(a)(1) 

Operation after maintenance, preventive maintenance, rebuilding, or alteration; 

I request relief from 91.407(a)(1) based on the Protocols and Procedures Section on Maintenance, 

Return to service after maintenance, and Maintenance records. Reference Exemption No. 11138 and 

11417.
14 CFR 91.409(a)(1)(2) 

Inspections; 

I request relief from 91.409(a)(1)(2) based on the Protocols and Procedures Section on Inspections. 

Reference Exemption No. 11138 and 11417.

14 CFR 91.417(a)(b) 

Maintenance records; 

I request relief from 91.417(a)(b) based on the Protocols and Procedures Section on Maintenance 

records.

Protocols and Procedures for UAS Operations

Preflight Inspection of UAS

(1). Preflight of Unmanned Aerial System will follow the instructions on in the DJI Phantom 3 

instruction and User Manual. The Pilot in Command will certify that a preflight inspection has 

been accomplished with the date and time and signature in UAS logbook. The preflight shall 

include:

• The Aircraft

• The Transmitter

• Batteries

• Motors

• Rotors

• Landing gear

• Camera

• Gimbal Mount. 

As a part of the preflight the I will assure that weather conditions, batteries, area security, and 

any other information essential to safe operation has been obtained.

Area Security

1. I will ensure that the operational area for the purposes of UAS flight shall be cleared of all 

nonessential persons at all times the UAS is in flight. Additionally all nonessential persons shall 

be required to remain clear of the operations area by a minimum distance of 150 feet during 

operations. Clearly marked signs will be posted at all ingress\egress points to the operations 

areas. These signs will be of white background with red lettering stating the following: 

“Unmanned aircraft operations underway. Please remain clear of this area during 

operations.”

2. In the event of a breach of nonessential persons into the operations area during flight of UAS, the 

I shall immediately terminate flight operations until such time as the area can be cleared of such 

persons. 

3. The UAS area of operation is defined as the Horizontal flight path(s) of the UAS as well as the 

Vertical flight path and Maximum altitude to be reached. Additionally the area between the 

UAS’s current position and its Home location is also considered operational area as it will 

proceed direct to its home location in the eventual of loss of ground control. All nonessential 

persons will not be allowed within 150 feet of any part of the operational area during flight 

operations.
Limitation of Operations

I hereby warrant and represent that all of the following limitations will be strictly enforced and 

maintained at all times.

1. The UAS shall be operated in Daytime only, as defined by 14 CFR – All nighttime operations 

are prohibited.

2. The UAS shall be operated by Visual Line of Sight (VLOS) at all times

3. The UAS shall remain within 1000ft horizontal distance of the controller at all times.

4. The UAS to be utilized is the DJI Phantom 3 Advanced Unmanned Aircraft System. No other 

systems will be operated.

5. The total weight, including payload of this UAS is just under 3 lbs.

6. The UAS will have an altitude restriction of 200ft AGL.

7. The UAS will not be operated at a speed exceeding 30 Knots.

8. Operations Documents will be accessible at all times and must be accessible during UAS 

operations.

9. I will inspect and ensure that UAS and ground control station is in airworthy condition prior to 

each operation; if determined un-airworthy, all operations will be suspended until such time as 

necessary maintenance has been performed and UAS is determined to be in a safe condition for 

flight.

10. An operational flight test will be performed after any maintenance or alterations that may affect 

UAS operation or flight.

11. UAS maintenance must follow Manufactures aircraft/component, maintenance, overhaul, and 

replacement, inspection, and life limit requirements.

12. The maintenance, inspections, and record keeping requirements, will be meticulously carried out 

in accordance with the operating documents. Maintenance and inspection, and alterations must 

be noted in the aircraft records, including total flight hours, description of work performed, and 

the signature of the authorized person returning UAS to service.

13. UAS must comply with all Manufacturers’ Safety Bulletins.

14. An authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

15. Prior to operations for which exemption is requested the I will have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours of UAS multi-rotor.

16. Prior to operations I will have accumulated and logged a minimum of 5 hours as a UAS pilot in 

make and model listed in exemption (The DJI Phantom 3 Advanced). This will include at a 

minimum 3 takeoffs and landings in the preceding 90 days to meet currency requirements.

17. I will only operate the UAS with appropriate distances in accordance with 14 CFR 91.119.

18. No operations will be allowed if the return home function and\or autopilot are, or are suspected 

to be malfunctioning.

19. UAS shall not be operated from a moving platform of any type.
20. Should I detect that a manned aircraft is being operated in close proximity to the operations area, 

the UAS shall give right of way to the manned aircraft, and I shall cease operations and land 

until such time as the manned aircraft has cleared the area.

21. The UAS will not be operated any closer than 500 ft to any structure without the express 

permission of the structure owner.

UAS Airworthiness

1. I shall ensure that the UAS is in an airworthy condition before each flight. Airworthiness shall be 

determined by a preflight inspection in accordance with DJI operating documents and any and all 

applicable Federal Aviation Regulations.

2. I shall document each preflight inspection by date, Aircraft total Flight time to date, any 

discrepancies noted. Any discrepancy noted shall be addressed before UAS operation.

UAS Maintenance and Records

1. I will maintain aircraft maintenance logbooks, and keep them together with DJI documents, 

handbooks, user manuals, supplements, Safety Bulletins, etc., and these shall be the only 

approved documents for performing repairs, maintenance, inspections, overhauls, or replacement 

of life limited components. A record of each preflight inspection will additionally be recorded in 

these logbooks. 

2. Any required maintenance, inspection, alteration or repair must be completed by an authorized 

person / facility. At the completion of this work the authorized repair/maintenance person must 

make an entry in the aircraft log book that at least includes: Date, Aircraft serial or operating 

number, brief description of the discrepancy, inspection, alteration or repair, the reference 

material used as guidance for the repair, statement approving the aircraft for return to service, 

and signature of person who completed the work.

3. Maintenance records shall be kept with the UAS at all times and shall be made available to any 

authorized agency upon request.

Visual Observers

1. A Visual Observer shall be used during any and all operations of the UAS System.

2. The Visual Observer shall maintain communication with me at all times during UAS operation.

3. The Visual Observer shall maintain Visual Contact with the UAS at all times. In the event that 

Visual Contact is lost, operations will be immediately ceased and the aircraft will be landed.

4. The Visual Observer shall also help maintain area of operations security and ensure that all 

nonessential persons remain clear of the area of operations. In the event of a breach by 

unauthorized person(s), the operations will cease immediately.

5. The Visual Observer shall also assist in looking for manned aircraft traffic near the operations 

area. If manned aircraft traffic is observed near the operations area, operations will be 

immediately ceased and the aircraft will be landed.

Thank you for your consideration in this matter.

Sincerely,
Joe Bulleit