Submitted by: Peter Aviles 21 NW 1st Avenue, #1212 Dania Beach, FL 33004 (786) 546-6653 rinconol@yahoo.com

Scope ;

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Enhance and augmentreal estate listing videos by using the Phantom 3 ProfessionalUnmannedAircraft System to conduct aerial photography and videography ofreal property for marketing and inspection purposes.

UA V Phantom 3 Professional The DJI Phantom 3 is a quad-rotor UnmannedAircraft System (UAS) weighing less than 3 pounds. The Phantom 3 UAS that PeterAviles will be responsible for also utilizes a mobile ground station. The UAS features

a safety Returnto Home function that in the event ofa 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 ortablet, and a 720p HD view ofeverythingthe camera sees as one flies is displayed live. This immersive view streams to the screen in absolute clarity, enabling safe flying. Fromtakeoffto landing, the Phantom 3 responds to commands while automaticallyhandling the most complex aspects ofsafe, 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 OfReliefThat Peter Aviles Seeks

1. Extent ofReliefthatPeter Aviles seeks regarding Section 61.113 (a) and (b) Private PilotPrivileges and Limitations:Relieffrom Section 61.113 (a) and (b) is requested to allow a Pilot in Commandholding a currentPrivate Pilots Certificateto operate Peter Aviles' Phantom 3. The flight would be complimentedby a Visual Observer who, along with the pilot, will maintain Visual Line ofSight with the Phantom 3 at all times. All operations conductedwill be incidental to Peter Aviles' business. The Phantom 3 is not able to carry passengers.

2. Extent ofReliefthatPeter Aviles seeks inregards to Section 91.7(a): Civil AircraftAirworthiness Relieffrom Section 91.7(a) is requestedto allow Peter Aviles to determine airworthiness ofthe Phantom 3. As part ofthis determination, the following will be adhered to:

a. Priorto the Phantom 3's flight the PIC will inspect the UA to ensure it is in a conditionthat will be conducive for a safe flight. The ground control station will be included in the above inspection. b. PeterAviles 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 ofReliefthatPeter Aviles seeks in regards to Section 91.119: Minimum Safe Altitudes General relieffrom 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 greaterthan SNM from the nearest airport as depicted on currentAeronautical Charts. Peter Aviles also wishes to be granted exemptionto operate at an altitude not greaterthan 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 orderto maintain an acceptable level ofsafety associated with operations overprivate property: (a) Peter Aviles will display signs in the immediate vicinity of operations stating: "Aerial Photography InProgress. 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 onthe 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 of25 hours oftotal time

as a UAS rotorcraftpilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. In addition the operatorwill have logged a minimum of5 hours as a UAS pilot operatingthe make and model UAS thatPeter Aviles operates.(e) Peter Aviles will be familiar with and able to manually institute the Phantom 3's Returnto Home (RTH) feature. This feature aborts a flight operation and automaticallyreturns the UAS to a predetermined GPS safe point. (t) Peter Aviles will not operate overprivate property without first finding a suitable alternate landing spot onthe property. (g) Peter Aviles will abort the flight in the event ofunpredicted obstacles

or emergencies in accordance withthe operating documents. (h) Peter Aviles will utilize a two man flight team consisting ofthe Pilot in Command (PIC) and a Visual Observer (VO). This team will maintain visual line ofsight 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 withoutpermission from the owner.

4. Extent ofReliefthat Peter Aviles seeks in regards to Section 91.121 Altimeter Settings: Relieffrom 91.121 is requestedbecause the Phantom 3 utilizes electronic GPS with a barometric sensor. In orderto maintain an equal level ofsafety that 91.121 requires, the PIC of the Peter Aviles' UAS will abort the flight inthe events that the UA loses communicationswith the GPS signal.

5. Extent ofReliefthatPeter Aviles seeks in regards to Section 91.151(b) Fuel Requirements for Flight in VFRConditions: Relieffrom 91.151(b) is requestedto the extent that allows Peter Aviles to operate the Phantom 3 up to a point (considering wind and forecast weather conditions) thatthere is enoughpower to fly at normal cruising speed to the intended landing point and landthe UA with 30% battery powerremaining.

6. Extent ofReliefthat Peter Aviles seeks inregards 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. Relieffrom 91.405(a), 91.407(a)(l), and (a)(2), And 91.417(a) and (b) is requested to the extentthat allows Peter Aviles to operate the Phantom 3 Quad-Copteras necessary. These sections are all related to airworthiness certificates ofaircraft. There is not currently an airworthiness certificate for small UAS's. Peter Aviles would comply in full to any conditions and limitations that the Administratorwould place in order to receive an approved Grant ofExemption.

### 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 exemptionto

me would allow me to provide this service at a much lower cost. My UAS will pose no threatto the public given its small size and lack ofcombustible fuel when comparedto manned aircraft. The operation ofmy UAS will minimize ecological damage and promote economic growth by providing informationto companies inthe area.



### Conclusion As set forth herein, Peter Aviles seeks an exemptionpursuant to 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 3 UAS commerciallywithinthe Real Estate markets. The Administratorwill be assisting small business by granting this petition. In accordance with the FAAModernizationand Reform Act of20 12, Peter Aviles respectfully requests that the FAAAdministrator 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:



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Peter Aviles July 16, 2015