Petition for Exemption 14 CFR § 11.81 

Exemption petition under SEC 333 

Name:

Jeffrey Brock

206 Oconee DR

Cohutta, GA 30710

Petition for Exemption under Sec 333

Sec 333 prohibits the use of a UAS for commercial purposes on private property. I have been flying 

remote control aircraft since April 2001 and am simply petitioning for an exemption to provide a 

commercial service to private land owners and companies who wish to obtain and capture Aerial 

photos and videos of said property for purposes including real estate listings, insurance property 

claims, and for use as a marketing tool for businesses. I would like to be able to accept payment for 

these services therefore making this a commercial use of a UAS.

Benefit to Public

My request benefits the public as a whole by providing an opportunity for small business owners, 

real estate agents, and others who wish to document their land or property to take advantage of 

the technology that now exists in the form of UAS’s and allows them to do so using an experienced 

and certified RC Pilot in Command that understands how to safely operate such technology.

Reasons why the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to the existing rule

As a previously licensed General Aviation Pilot (student) (non-current) with over 50 hours of flight 

instructions and 20 hours of solo flight and the ability to safely operate aircraft, therefore 

understanding the importance of different uses and safety concerns regarding FAA regulated 

airspace, I would be a good candidate for exemption of Sec 333 while not putting Air Safety in any 

advanced risk. The specific UAS (Phantom 2 whose Operating Manual is Included in my petition) I 

am seeking exemption with is one with many safety programs, including Return Home and GPS 

navigating. When flying for this commercial purpose I would be flying at a maximum altitude of 100 

feet and flying mostly vertically for the purposes of taking photos and video decreasing the risk of 

any interference. My general knowledge of the aviation safety systems implemented by the FAA 

would be used to ensure that safety would not be affected by my operations. I would not be flying 

near disaster areas, sporting events, or high traffic areas including airports, and I would pay 

attention to NOTAMS as posted online. http://notams.aim.faa.gov/notamSearch/nsapp.html#/

I intend to fly in these safe modes: 

Flight Mode 1 – Fail Safe (Default) 

Enhanced Fail-safe will be triggered when the MC loses the control signal, in these following 

situations.

 Signal lost between the transmitter and receiver, e.g. quad-rotor is out of the 

communication range, or transmitter is powered off, etc.
 One or more connections of A, E, T, R, U channels between main controller and receiver is 

lost. If this happens before take-off, the motors will not work if you push the throttle stick; if 

this happens during the flight, the LED will flash yellow to warn, in addition to the fail-safe 

method.

 The quad-rotor will automatically land if the fail-safe mode is active, or return home if in GPS 

mode.

 Before takeoff, the current position will be saved as the home point by the MC automatically 

when you push the throttle stick first time, after 6 or more GPS satellites are found for more 

than 8 seconds.

 Make sure to save the home location before takeoff and keep it in mind clearly for safety 

reasons.

 When you switch to ATTI. Mode, MC will disengage enhanced failed-safe mode, you can regain control of quad-rotor.

Flight Mode 2 – GPS (Dual Default Set)

The GPS & Compass is used to identify the position and direction.

GPS & Compass can be used to:

 in Control Mode can be switched to GPS Atti. Mode ( In GPS cruise mode, it is not only can 

keep the aircraft attitude stable and also can lock the aircraft position accurately. Flight 

speed control, the stick center position is for 0m/s, its endpoint is the maximum speed 

preset by the user. The GPS cruise mode helps the aircraft to have accurate and smooth 

flight movement that is specially fit for aerial photography)

 in Intelligent Orientation Control (IOC - Forward Direction: Multi-rotor will fly along this 

direction when you push the elevator stick.

 Usually, the forward direction of a flying multi-rotor is the same as the nose direction. By 

using Intelligent Orientation Control ( IOC-, wherever the nose points, the forward direction 

has nothing to do with nose direction) can use Home Lock to allow the aircraft according to 

the Home Point to tell direction

 provides for safer operation of aircraft and assist pilot when performing safe maneuvers

 Self-Leveling– Brings the Phantom 2 to a level attitude when the elevator and aileron inputs 

are at neutral.

 Position Hold– The 350 QX uses GPS to hold a given location when this function is activated 

If GPS is enabled and has a solid lock, the aircraft will hold its position when elevator or 

aileron inputs are at neutral.

 Throttle provides proportional thrust– The throttle responds directly to the throttle input, 

giving the pilot direct control over hovering as well as ascent and descent rates.

Flight Mode 3 – Return Home

The Dji Phantom 2 will return to take off point ( Home Point ) should the aircraft lose communication 

with main controller.
I will follow these suggested safety regulations

 Always keep aircraft in sight and under control.

 Always keep people and pets at least 35 feet (10 meters) away when the

battery is connected.

 Keep children out of the vicinity of this product at all times.

 Always use fully charged batteries.

 Always keep transmitter powered on while aircraft is powered.

 Always remove batteries before disassembly.

 Always keep moving parts clean.

 Always keep parts dry.

 Always let parts cool after use before touching.

 Always remove batteries after use.

 Always have a first aid kit on location.

 Always have an appropriate fire extinguisher on location.

 Never operate aircraft with damaged wiring.

 Never touch moving parts.

The Phantom 2 has many more features than other Blade quad copters thus providing an 

exceptional level of safety.

I, Jeffrey Brock am seeking an exemption of the FAA’s Sec 333 rules that does not allow the use of 

an Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safety. 

I am simply petitioning for an exemption to provide a commercial service to private land owners 

and companies who wish to obtain and capture Aerial photos and videos of said property for 

purposes including real estate listings, insurance property claims, and for use as a marketing tool for 

businesses. 

I fully understanding the importance of different uses and safety concerns regarding FAA regulated 

airspace, I would be a good candidate for exemption of Sec 333 while not putting Air Safety in any 

accelerated risk. The specific UAS (DJI Phantom 2 whose Operating Manual is Included in my 

petition) I am seeking exemption with is one with many safety programs, including IOC ( Intelligent 

Orientation Control ) technology and GPS navigating. When flying for this commercial purpose I 

would be flying at a maximum altitude of 100 feet and flying mostly vertically for the purposes of 

taking photos, decreasing the risk of any interference. My general knowledge of the aviation safety 

systems implemented by the FAA would be used to ensure that safety would not be affected by my 

operations. I would not be flying near disaster areas, sporting events, or high traffic areas including 

airports, and I would pay attention to NOTAMS. 

I understand and will comply with all the health and safety regulations for Pilot in Command and 

will be the only operator under this exemption.

I appreciate the FAA’s consideration of this petition for exemption.
The following are specifics of the DJI Phantom 2

Weight w/ battery - 2.2 pounds

Hoover Accuracy – Vertical +- 2.2 Feet | Horizontal 8.2 Feet

Max Yaw Angular Velocity - 200°/s

Max Tilt Angle - 35°

Max Ascent / Descent Speed – 19.6ft/s

Max Flight Speed – 49.2ft/s

Diagonal Length – 1.1ft

Power Consumption – 5.6W

Flight Time – 25 minutes (hover mode)

Take-off Weight – 2.8 lbs

Operating Temperature – 14° Minimum – Maximum 122°

Supported Battery – DJI Intelligent Battery

Previous aircraft authorized to fly solo during flight school 1993 | 1996-1997

Carpet Capital Aviation – Dalton Georgia 1993 Les Halmon CFII

Colledgedale Flight School – 1996-1997 Mike Warnock CFII

Beechcraft – Model 77 Skipper

Cessna - 150

Cessna – 172 Skyhawk

Cessna – 182 Skylane

General Safety Precautions and Warnings I intend to Maintain

• Always keep a safe distance in all directions around your model to avoid collisions or injury. This 

model is controlled by a radio signal subject to interference from many sources outside your 

control. Interference can cause momentary loss of control.

• Always operate your model in open spaces away from full-size vehicles, traffic and people.

• Always carefully follow the directions and warnings for this and any optional support equipment 

(chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach of children.

• Always avoid water exposure to all equipment not specifically designed and protected for this 

purpose. Moisture causes damage to electronics.

• Never place any portion of the model in your mouth as it could cause serious injury or even death.

• Never operate your model with low transmitter batteries.

• Always keep aircraft in sight and under control.

• Always move the throttle fully down at rotor strike.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.
• Always remove batteries after use.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

If you want to exercise the privileges of your exemption outside the United States, you must state 

the reason.

I have no intention of using this exemption outside the United States