Petition for Exemption 14 CFR § 11.81

From:

Mark Barber

22 N Lake Street

Crescent City, FL 32112

(352) 553-8637

MarkAlanB@hotmail.com

To:

Federal Aviation Administration

I hereby submit a petition to receive an exemption or waiver from 14CFR § 11.81 Section 333 UAS.

I am the current owner and operator of a DJI Phantom 3 Advanced quadcopter photography drone.

I am seeking relief from section 333 in order to operate a UAV on a commercial level. The reason for 

this request is to take professional aerial photography for Real Estate agents, home builders, property 

development companies, and property owners. Since I specifically provide these entities with 

professional photography, it is imperative to provide my clients with the property tools necessary to 

show each property they have for sale. These professional pictures can also be beneficial in defining 

property value. In the sale of Real Estate prospective buyers are requiring more and more information 

in order to make an informed decision about the property they are considering. As property values go 

up, it is necessary for prospective buyers to see what they are buying, and adequately assess the value 

of the property. In years past, in order to get good aerial photos of a property, it required someone with 

a manned aircraft to fly above the property. The use of a UAV to do that job will increase the safety of 

the public by reducing the risk of a large aircraft crash, creating a safer environment by not adding toxins 

to the air, reducing the amount of large aircraft in our airspace, doesn’t insight unintentional fear into 

animals on the ground, and allows closer to the ground flights without disturbing the land or plant life. 

The use of a UAV will also allow prospective buyers of the property views of lower elevation terrain that 

wasn’t possible with larger aircraft.

The following are the specifications of the UAV to be used:

Hardware

 Diagonal size is 1.935 ft (590 mm)

 Weight 4.51 lbs (1,280 grams)

 Transmitter operating frequency 2.400 GHz – 2.483 GHz

 Travel speed 34 mph max

 Flight time at full charge is 23 minutes

 Communication distance of 1.2 miles (2 km) away

Installed Software

 DJI Lightbridge
 GPS Mode is GPS/GLONASS

 GPS auto-pilot for position holding, provides altitude lock along with stable hovering

 GPS return to take off if communication is broke or low battery is detected

 No Fly Zone feature turns GPS off in no fly zones using the geo fence feature (updated upon 

connection to internet)

Based on an article published on operational limitation at the address 

http://www.faa.gov/regulations_policies/rulemaking/media/021515_sUAS_Summary.pdf I will meet or 

exceed those limitations with the following specifications at which I will be flying the UAV.

 Based on the equipment listed above we will operate a UAV that weighs less than 5 lbs

 The VLOS (Visual Line of Sight) rule is limited to an up and down motion no more than 400 feet 

of controller and operator

 Due to the close proximity of the flights the UAV will be able to be seen at all times without any 

additional monitoring equipment other than standard human eye vision

 Flight of the UAV will be done with the permission of all parties associated with the property 

that will be filmed and at no time will I fly the UAV directly over a person without prior 

knowledge and permission

 The flight of the UAV will not be performed during non-daylight hours and will only be flown in 

conditions that allow the UAV to be seen by the operator at all times

 Although a First Person view camera will be used in the aid of taking pictures, it will not be used 

to guide the flight

 The limitation of the UAV to be flown at no more than 35 mph, I find that is not necessary to fly 

it more than 15-20 mph

 The UAV will not be flown any higher than 400 ft above the surface it is being flown over or 

Class G operations

 The UAV will be inspected prior to every flight for safe operation including but not limited to 

battery condition, operations of electric motors, GPS system, IR controller, propellers, and WiFi 

connection between UAV and Controller

 Based on Software installed the UAV will not be flown within a 5 mile radius of any commercial 

airstrip

 Safety will be priority over pictures, if any flight will pose a safety hazard to anyone, animals, or 

the environment, the flight will be immediately cancelled until such time can be deemed safe

 Operator will maintain a GPS signal with the UAV at all times during the flight, if connection is 

broken, the equipment’s built-in GPS system will return the UAV to the initial take-off point and 

land it safely, if that system is broken for any reason, an emergency land will take place lowering 

the Micro-UAS to the ground

Furthermore, by following the above operational limitation that I have imposed on flights, I will not be 

posing any kind of harm to the public, environment, or wildlife.

Since I will meet or exceed the operational limitations that are set forth to be enforced, I hereby request 

that I be granted an exemption. Please contact me at 352-553-8637 or MarkAlanB@hotmail.com if you 

need any further documentation.