Submitted by:

Kevin Pflieger

4 Mclaughlin Ct

Richmond Hill, GA 31324

(912) 667-8490

kevinpflieger@icloud.com

Petition Request

Kevin Pflieger requests exemption from Title 14 Code of Federal Regulations 

61.113(a), 61.113(b) 

91.7(a)

91.119(c)

91.121

91.151(a)

91.405(a)

91.407(a)(1)

91.409(a)(1), 91.409(a)(2)

91.417(a), 91.417(b)

Scope

This exemption will permit Kevin Pflieger to operate the proposed DJI UAS for 

commercial purposes of conducting aerial photography and video in support of small 

business community and charitable non profit organizations in and around the state of 

Georgia.

Enhance and augment real estate listing videos by using the DJI Phantom 2 Vision 

Plus, DJI Inspire 1 Professional Unmanned Aircraft System to conduct aerial 

photography and videography of real property for marketing and inspection purposes.

Proposed Small UAS

The Small UAS proposed by Kevin Pflieger are the DJI Phantom 2 Vision Plus and DJI 

Inspire 1. These DJI UAS are Quadcopters weighing less than 6lbs and utilizing mobile 

ground stations. The DJI UAS features a safety Return to Home function that in the 

event of a signal loss, the UAV will return to a preset position and land. The Return 

Home feature can also be triggered manually. The remote connects to a smart phone or 

tablet, and a 720p HD view of everything the camera sees is displayed live. This 

immersive view streams to the screen in absolute clarity, enabling safe flying. From take 

off to landing the DJI UAV responds to commands while automatically handling the most 

complex aspects of safe and stable flight.
Extent of Relief Requested

1. Extent of Relief that Kevin Pflieger seeks regarding Section 61.113 (a) and (b) Private 

Pilot Privileges and Limitations:

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

holding a current Private Pilots or Sport Pilots certificate to operate the DJI UAS. The 

flight would be complimented by a Visual Observer who along with the pilot, will 

maintain Visual Line of Site with the DJI UAV at all times. All operations conducted will 

be incidental to Kevin Pfliegers business. The DJI UAS are not capable of carrying 

passengers.

2. Extent of Relief that Kevin Pflieger seeks in regards to Section 91.7 (a):

Civil Aircraft Airworthiness Relief from Section 91.7(a) is requested to allow 

KevinPflieger to determine airworthiness of the DJI UAS. As part of this determination, 

the following will be adhered to:

a. Prior to the DJI UAS flight the PIC will inspect the UAV to insure it is in a 

condition that will be conductive for a safe flight. The Ground Control Station will 

 be included in the above inspection.

b. Kevin Pflieger will follow the DJI’s aircraft/component,maintenance, overhaul, 

replacement, inspection and life limit requirements.

c. Kevin Pflieger will comply with all DJI manufacturer Safety Bulletins and 

Firmware upgrades.

3. Extent of Relief that Kevin Pflieger seeks in regards to Section 91.119: 

Minimum Safe Altitudes General relief from 91.119 is requested to allow Kevin Pflieger 

to operate the DJI UAV 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. Kevin Pflieger 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. 

Kevin Pflieger will adhere to the following in order to maintain an acceptable level of 

safety associated with operations over private property:

(a) Kevin Pflieger will display signs in the immediate vicinity of

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

(b) Kevin Pflieger will not allow the DJI UAV to operate at a speed greater than10kts. 

(c) Kevin Pflieger will require the UAS operator (PIC) to be fully trained on the DJI UAS 

by adhering to the recommendations contained within the manufactures operating 

manual.

(d) Kevin Pflieger 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 Kevin Pflieger operates.

(e) Kevin Pflieger will be familiar with and able to manually institute the DJI UAV Return 

to Home (RTH) feature. This feature aborts a flight operation and automatically returns 

the UAV to a predetermined GPS safe point. 

(f) Kevin Pflieger will not operate over private property without first finding a suitable 

alternate landing spot on the property.

(g) Kevin Pflieger will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

(h) Kevin Pflieger 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 

DJI UAV at all times and remain within hearing of one another. 

(i) Kevin Pflieger will not permit flight around vessels, vehicles and structures without 

permission from the owner. 

4. Extent of Relief that Kevin Pflieger seeks in regards to Section 91.121:

Relief from 91.121 is requested because the DJI UAS utilizes electronic GPS with a 

Barometric sensor.

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

will abort the flight in the event that the UA loses communications with the GPS signal.

5. Extent of Relief that Kevin Pflieger 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 the PIC of the DJI UAS to 

operate up to a point (considering wind and forecast weather conditions) that there is 

enough power to fly at normal safe cruising speed to the intended landing point and 

land the UAV with 30% battery power remaining.

6. Extent of Relief that Kevin Pflieger seeks in regards to Section 91.405(a), 91.407(a)

(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and 91.417(b).

These are all associated with an Airworthiness Certificate.

Relief from 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and 

91.417(b), is requested to the extent that allows Kevin Pflieger to operate the DJI UAS 

as necessary. These sections are all related to airworthiness certificates of aircraft. 

There is not currently an airworthiness certificate for small UAS’s. Kevin Pflieger and 

PIC would comply in full to any conditions and limitations that the FAA would place in 

order to receive an approved Grant of Exemption.
Public Interest

Aerial videography for real property has been around for a long time through manned 

fixed wing aircraft and helicopters, but for small business owners, it's expense has been 

cost-prohibitive. Granting this exemption to

me would allow me to provide this service 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 in the area.

Conclusion 

As set forth herein, Kevin Pflieger 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 2 Vision Plus and DJI Inspire 1 UAS 

commercially within the Real Estate markets. The Administrator will be assisting small 

business by granting this petition. In accordance with the FAA Modernization and 

Reform Act of 2012, Kevin Pflieger 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).