Submitted by: 

Peter Aviles 

21 NW 1st Avenue, #1212 

Dania Beach, FL 33004 

(786) 546-6653 

rinconol@yahoo.com 

Scope 

; _ _.i.} -· ) 

Enhance and augment real estate listing videos by using the Phantom 3 

Professional Unmanned Aircraft System to conduct aerial photography and 

videography of real property for marketing and inspection purposes. 

UA V Phantom 3 Professional 

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

weighing less than 3 pounds. The Phantom 3 UAS that Peter Aviles 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 a phone or tablet, 

and a 720p HD view of everything the camera sees as one flies is 

displayed live. This immersive view streams to the screen 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. 

Request 

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

91.407(a)(l), 91.409(a)(2) and 91.417(a) and (b) ofTitle 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 Peter Aviles Seeks 

1. Extent ofReliefthat Peter Aviles 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 holding a current Private Pilots Certificate to operate Peter 

Aviles' 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 Peter 

Aviles' business. The Phantom 3 is not able to carry passengers. 

2. Extent ofReliefthat Peter Aviles seeks in regards to Section 91.7(a): 

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

Peter Aviles 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. Peter Aviles will follow the DTIPhantom 3 's aircraft/component, 

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

c. Peter Aviles will comply with all DTI manufacturer Safety Bulletins. 

3. Extent ofReliefthat Peter Aviles seeks in regards to Section 91.119: 

Minimum Safe Altitudes General relief from 91.119 is requested to allow 

Peter Aviles to operate the Phantom 3 at altitudes not to exceed 400' AGL 

over private property at a distance at or greater than SNM from the nearest 

airport as depicted on current Aeronautical Charts. Peter Aviles also wishes to 

be granted exemption to operate at an altitude not greater than 50' AGL 

(below tree level) between 1NM and SNM from the nearest airport as depicted 

on current Aeronautical Charts. 

Peter Aviles will adhere to the following in order to maintain an 

acceptable level of safety associated with operations over private 

property: 

(a) Peter Aviles will display signs in the immediate vicinity of 

operations stating: "Aerial Photography In Progress. Use Caution." 

(b) Peter Aviles will not allow the Phantom 3 to operate at a speed greater 

thanlOkts. 

(c) Peter Aviles 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) Peter Aviles 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 Peter Aviles operates. 
(e) Peter Aviles 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. 

( t) Peter Aviles will not operate over private property without first finding a 

suitable alternate landing spot on the property. 

(g) Peter Aviles will abort the flight in the event of unpredicted obstacles 

or emergencies in accordance with the operating documents. 

(h) Peter Aviles 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) Peter Aviles will not permit flight around vessels, vehicles and 

structures without permission from the owner. 

4. Extent of Relief that Peter Aviles 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 Peter Aviles' UAS will abort the flight in the events that the UA loses 

communications with the GPS signal. 

5. Extent ofReliefthat Peter Aviles 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 Peter Aviles 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 Peter Aviles 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)(l), and (a)(2), And 91.417(a) and (b) is 

requested to the extent that allows Peter Aviles 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. Peter Aviles 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 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, Peter Aviles 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 markets. The Administrator will be 

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

FAA Modernization and Reform Act of 20 12, Peter Aviles 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). 

Signed: 

-------E+~~ :::::3>s2's------

Peter Aviles 

July 16, 2015