Submitted by:

Philip Iavarone

Iavarone Land LLC

1400 Dill Park Road

North East, PA 16428 (814) 823-5846

Iavarone123@gmail.com

Scope:

Enhance and edit real estate listing videos and accurately survey property lines in 

Oil and Gas Title Research by using the Phantom 3 Professional Unmanned

Aircraft System to conduct aerial photography, videography and surveying of real

property.

UAV Phantom 3 Professional:

The DJI Phantom 3 is a quad-rotor Unmanned Aircraft System (UAS) weighing

1280 Grams or 2.82192 Pounds. The Phantom 3 UAS that Philip Iavarone will be 

responsible for also utilizes a mobile ground station. The UAS features a safety

Return to Home function that in the event of a signal loss, the UAS will return to a

preset position and land. The Return to Home feature can also be triggered

manually. The remote connects to your mobile phone or tablet, and a 720p HD

view of everything your camera sees as you fly is displayed live. This high 

resolution view streams to you in absolute clarity, enabling safe flying. From

takeoff to landing, the Phantom 3 responds to commands while automatically

handling the most complex aspects of safe, stable flight. Each of the four legs of 

the Phantom 3 contains a high-powered antenna, all constantly broadcasting the 

live video feed and receiving control commands from any direction.

Request:

An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a),

91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) of Title 14, Code of

Federal Regulations (14 CFR) as was granted to Ralph J. Apel in Exemption

No. 11410

Petition:

I request an exemption from TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c);

91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417

(a) and (b)
The Extent Of Relief that Philip Iavarone seeks

1. Extent of Relief that Philip Iavarone seeks regarding Section 61.113 (a) and (b) 

Private Pilot Privileges and Limitations

Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in

Command to operate the Philip Iavarone’s Phantom 3. The flight would be

complimented by a Visual Observer who, along with the pilot, will maintain Visual

Line of Sight with the Phantom 3 at all times. All operations conducted will be

incidental to Philip Iavarone’s business, Iavarone Land, LLC. The Phantom 3 is

not able to carry passengers.

2. Extent of Relief that Philip Iavarone seeks in regards to Section 91.7(a) Civil

Aircraft Airworthiness

Relief from Section 91.7(a) is requested to allow Philip Iavarone to determine 

airworthiness of the Phantom 3. As part of this determination the following

will be adhered to:

a. Prior to the Phantom 3's flight the PIC will inspect the UA to ensure it is in a 

condition that will be conducive for a safe flight. The ground control

station will be included in the above inspection.

b. Philip Iavarone will follow the DJI Phantom 3’s aircraft/component, 

maintenance, overhaul, replacement, inspection and life limit requirements.

c. Philip Iavarone will comply with all DJI manufacturer Safety Bulletins.

3. Extent of Relief that Philip Iavarone seeks in regards to Section 91.119

Minimum Safe Altitudes General relief from 91.119 is requested to allow Philip 

Iavarone to operate the Phantom 3 at altitudes not to exceed 400’ AGL over

private property at a distance at or greater than 5NM from the nearest airport as

depicted on current Aeronautical Charts. Philip Iavarone also wishes to be granted

exemption to operate at an altitude not greater than 50’ AGL (below tree level)

between 1NM and 5NM from the nearest airport as depicted on current

Aeronautical Charts.

Philip Iavarone will adhere to the following in order to maintain an acceptable 

level of safety associated with operations over private property:

(a) Philip Iavarone will display signs in the immediate vicinity of operations 

stating: “Aerial Photography In Progress. Use Caution.”

(b) Philip Iavarone will not allow the Phantom 3 to operate at a speed greater than

10kts.

(c) Philip Iavarone will require the UAS operator (PIC) to be fully trained on the
Phantom 3 by adhering to the recommendations contained within the

Phantom 3’s operating manual.

(d) Philip Iavarone 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 logged as a UAS pilot with a

multi-rotor UAS. In addition the operator will have logged a minimum of 5 hours

as a UAS pilot operating the make and model UAS that Philip Iavarone operates.

(e) Philip Iavarone will be familiar with and able to manually institute the

Phantom 3’s Return to Home (RTH) feature. This feature aborts a flight 

operation and automatically returns the UAS to a predetermined GPS safe

point.

(f) Philip Iavarone will not operate over private property without first finding a 

suitable alternate landing spot on the property.

(g) Philip Iavarone will abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

(h) Philip Iavarone will utilize a two man flight team consisting of the Pilot in

Command (PIC) and a Visual Observer (VO). This team will maintain visual line

of sight with the Phantom 3 at all times and remain within hearing of

one another.

(i) Philip Iavarone will not permit flight around vessels, vehicles and structures 

without permission from the owner.

4. Extent of Relief that Philip Iavarone seeks in regards to Section 91.121

Altimeter Settings

Relief from 91.121 is requested because the Phantom 3 utilizes electronic

GPS with a barometric sensor.

In order to maintain an equal level of safety that 91.121 requires, the PIC of the

Philip Iavarone’s UAS will abort the flight in the events that the UA loses 

communications with the GPS signal.

5. Extent of Relief that Philip Iavarone seeks in regards to Section 91.151(b) Fuel

Requirements for Flight in VFR Conditions

Relief from 91.151(b) is requested to the extent that allows Philip Iavarone to 

operate the Phantom 3 up to a point (considering wind and forecast weather

conditions) that there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 30% battery power remaining.
6. Extent of Relief that Philip Iavarone seeks in regards to Sections 91.405(a),

91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) These are all 

associated a with Airworthiness certificate

Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is

requested to the extent that allows Philip Iavarone to operate the Phantom 3

Quad-Copter as necessary. These sections are all related to airworthiness 

certificates of aircraft. There is not currently an airworthiness certificate for small

UAS’s. Philip Iavarone would comply in full to any conditions and limitations

that the Administrator would place in order to receive an approved Grant of

Exemption.

Public Interest:

Aerial videography and surveying for real estate marketing and/or oil and gas title 

research has been around for a long time through manned fixed wing aircraft and

helicopters, but for small business owners, its expense has been cost-prohibitive.

Granting this exemption to me would allow me to provide this service and much 

needed information at a much lower cost. My UAS will pose no threat to the public

given its small size and lack of combustible fuel when compared to manned

aircraft. The operation of my UAS will minimize ecological damage and promote

economic growth by providing information to companies and residents looking to

relocate or build in the Erie area.

Conclusion:

As set forth herein, Philip Iavarone seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the DJI Phantom 3 UAS

commercially within the Real Estate and Oil and Gas markets. The Administrator

will be assisting small business by granting this petition. In accordance with the

FAA Modernization and Reform Act of 2012, Philip Iavarone respectfully requests

that the FAA Administrator grants this petition for exemption from TITLE 14 OF

THE CODE OF FEDERAL REGULATIONS SECTIONS

61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a);

91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)