Petition for Exemption 14 CFR § 11.81 

Exemption petition under SECTION 333 

Your name and mailing address. You may include other contact information such as a fax number, 

telephone number, or email address:

Name: Eric Demmers

Address: 4 Ridge Trial – Kinnelon – NJ 07405

Phone: 862.221.0672

Email: eric.demmers@gmail.com

The specific section or sections of 14 CFR from which you seek an exemption:

Petition for Exemption under Section 333

The extent of relief you seek and the reason you seek the relief:

Sec 333 restricts the use of an Unmanned Aerial Vehicle(s) (UAV), AKA quadcopter or drone, for 

commercial purposes on privately owned property. I am petitioning for an exemption to provide a service 

to property & land owners and companies who wish to capture Aerial photos and videos of their property(s)

for purposes including real estate listings, building and site inspections and for use as a marketing tool for 

my commercial real estate business. I would like to be able to accept payment for these services, therefore 

making this a commercial use of UAV. All of my proposed services will be, of course, with the consent of 

the property owner.

How your request would benefit the public as a whole:

My request will provide added benefits to the public by granting an opportunity for, real estate owners, real 

estate investors, real estate marketing companies, construction companies, entrepreneurs, small business 

owners, real estate agents, and others who wish to document their land, property, assist in inspections, 

track construction progress, all offered to them by the means of a technology that now exists in the form of 

a UAV. This will allow them to do so using an experienced operator 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:

With increasing technologies and our ever growing population, it is imperative to not only be extremely 

aware of our surroundings, but to incorporate strict safety practices into our operating procedures. With the

importance of different uses and safety concerns, regarding FAA regulated airspace, I would be a good 

candidate for exemption of Section 333 while not putting Air Safety in any accelerated risk. The specific 

UAV (DJI Phantom 3 Advanced - whose Operating Manual is included in my petition), I am seeking 

exemption with, is equipped with many safety features. Safety features such as: No-Fly Zone Restrictions, 

Restricted Altitude Flight Zones, Warning Zones, GPS Navigating, Auto Takeoff & Auto Landing, Aircraft 

status lights, Barometer, and a Sonar enhanced Vision Positioning System. The Phantom 3 Advanced’s 

flight controller implements several important safety features, including flight modes safety modes offering

Failsafe’s and Return-to-Home operations. These features ensure the safe return of the UAV if the control 

signal is lost. The flight controller can also save critical flight data from each flight to the on-board storage 

device. The flight controller also provides increased stability and an air braking feature. As an Industrial 

Commercial Real Estate Broker, 99% of the business I engage in is located in industrial parks, outside of 

densely populated cities. When flying for this commercial purpose I would be flying at a maximum altitude 

of 250 feet and mostly flying vertically around the properties perimeter, solely for the purposes of taking 

videos & photos of the subject property, ultimately encountering very minimal risk of any interference. 
I would not be flying near power lines, disaster areas, sporting events, or high traffic, airports, and I would 

pay attention to NOTAMS. I will not fly in in-climate weather conditions, including wind speeds exceeding 

10m/s and will abide by all regulations set forth by government and regulatory agencies including the ICAO 

and the FAA.

When operating the UAV, I intend to fly in the following safe mode, P-Mode – (Default, Positioning Mode)

which Aircraft lights flash slowly in green indicating safe to fly (P-mode with GPS and Vision Positioning). 

When operating in P-Mode, the GPS signal and Vision Positioning are strong (P-GPS), the UAV will utilize 

GPS for positioning and stability. 

I intend to follow these suggested safety regulations:

• Always keep aircraft in line of sight and under control. 

• Always keep people and pets at a safe distance.

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

• Always use fully charged batteries on both the remote controller and Intelligent Flight Battery.

• Always keep transmitter powered on while aircraft is powered. 

• Always remove batteries before disassembly. 

• Always ensure propellers are mounted correctly and firmly.

• Ensure motors can start and are functioning normally.

• Always keep moving parts clean. 

• Always keep parts dry. 

• Ensure Compass is correctly calibrated.

• Always let parts cool after use before touching. 

• Always remove batteries after use. 

• Always have a first aid kit with you. 

• Always have an appropriate fire extinguisher with you. 

• Never operate aircraft with damaged wiring. 

• Never touch moving parts. 

A summary we can publish in the Federal Register Federal Register:

I, Eric Demmers am seeking an exemption of the FAA’s Section 333 rules that does not allow the use of an 

Unmanned Aerial Vehicle (UAV) to be used for commercial purposes in regards to National Airspace Safety. 

I am petitioning for an exemption to provide a commercial service to private land & property owners and 

companies who wish to obtain and capture aerial photos and videos of their properties for purposes 

including real estate listings, site inspections and for use as a marketing tool for my commercial real estate 

businesses. I would like to be able to invoice and collect payment for providing these services, therefore 

making this a commercial use of UAV. With increasing technologies and our ever growing population, it is 

imperative to not only be extremely aware of our surroundings, but to incorporate strict safety practices into 

our operating procedures. With 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 UAV (DJI Phantom 3 Advanced, whose Operating Manual is Included in 
my petition) I am seeking exemption with, is equipped with many safety features, No - Fly Zone Restrictions, 

Restricted Altitude Flight Zones, Warning Zones, GPS navigating, Auto Takeoff & Auto Landing, Aircraft 

status lights, and a Sonar enhanced Vision Positioning System. As an Industrial Commercial Real Estate 

Broker, 99% of the business I engage in is located in industrial parks, outside of densely populated cities. 

When flying for this commercial purpose I would be flying at a maximum altitude of 150 feet and mostly 

flying vertically for the purposes of taking videos & photos of the subject property, ultimately encountering 

very minimal risk of any interference. I would not be flying near power lines, disaster areas, sporting events, 

or high traffic, airports. I will not fly in in-climate weather conditions, including wind speeds exceeding 10m/s 

and will abide by all regulations set forth by government and regulatory agencies. I appreciate the FAA’s 

consideration of this petition for exemption. 

Any additional information, views, or arguments available to support your request:

I am fully aware of the pre-flight safety checks and procedures associated with the operation manual for 

the DJI Phantom 3 Advanced and intend to implement pre-flight safety checks and utilize the safety 

technology provided with this unit. I intend to only fly in non-populated, industrial parks or dedicated 

warehouse areas and stay clear of all utility lines etc. I intend to be fully aware of my surroundings at all 

times and to only fly the unmanned aircraft within a visual line of sight and only in visual flight conditions, 

weather permitting.

Operations of the DJI Phantom 3 Advanced include the following information and operations manual: 

Weight: 1280 g

Max. Flight Time: Apx. 23 Minutes

GPS Mode: GPS/GLONASS

Operating Frequency: 2.4 – 2.483 GHx

Max. Ascent Speed: 5 m/s

Max. Decent Speed: 3 m/s

Max. Speed: 16 m/s (ATTI mode, no wind)

Max. Flight Altitude: 6000 m

Operating Temperature Range: 0-40 Degrees Celsius

Transmitter Power (EIRP): FCC: 20dbm; CE: 16dbm

Intelligent Flight Battery (PH3-4480 mAh-15.2 B)

General Safety Precautions and Warnings I intend to follow:

• Keep a safe distance in all directions and operate in open spaces away from vehicles, traffic and 

pedestrians to avoid collisions or injury. 

• Follow the directions and warnings for this and any optional support equipment.

• Ensure all system checks including GPS are operating in good working order prior to flight.

• Keep UAV out of the reach of children and inexperienced operators. 

• Always keep parts dry as water exposure to equipment not specifically designed and protected for this 

purpose may causes damage or malfunction to electronics. 
• Only use manufacturer approved (or equivalent) batteries and replacement parts.

• Keep aircraft in line of sight and under control. 

• Always move the throttle fully down at rotor strike. 

• Always use fully charged batteries. 

• Keep transmitter powered on while aircraft is powered. 

• Remove batteries after use, before disassembly and storage.

• Keep moving parts and sensors clean and free from dirt and debris. 

• Inspect UAV for damaged wiring and 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 currently have no intention using this exemption outside the United States.