Petition for Exemption 14 CFR §11.81

Exemption petition under §333

Name: Mark D. Zinn

Address: 5001 W. 70th Street, Prairie Village, KS 66208

Phone: (913) 963-0201

Email: mark@zinnlawfirm.com

Petition for Exemption under §333

Section 333 prohibits the use of a UAS for commercial purposes on private property. I petition for an 

exemption to provide 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, either directly or indirectly, for these services, thereby making this a commercial use of a UAS.

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 a third-party who 

understands how to safely operate such technology.

I have a thorough understanding of the importance of different uses and safety concerns regarding FAA 

regulated airspace, and would be a good candidate for exemption of §333 while not putting Air Safety in 

any accelerated risk. When flying for this commercial purpose, I would be flying at a maximum altitude 

of 200 feet and flying mostly vertically for the purposes of taking photos and videos, 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 

sporting events or high traffic areas including airports, and I would pay attention to NOTAMS.

For safety reasons, all flights are limited by default. And, I intend to fly in the following safe mode:

P-Mode: height limits, distance limits, and No-Fly Zones function concurrently to manage flight safety. 

When in a No-Fly Zone, the motors will not start. When in a Restricted Altitude Flight Zone, the aircraft 

will not exceed an appropriate altitude, although I don’t intend to ever exceed 200 feet in altitude for 

my commercial purpose. 

I intend to 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 with me

 Always have an appropriate fire extinguisher with me

 Never operate aircraft with damaged wiring

 Never touch moving parts

The following is a summary to be published in the Federal Register –

I, Mark D. Zinn, am seeking an exemption of the FAA’s §333 rules that do 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. 

The specific UAS for which I am seeking exemption is one with many safety programs, including a liveview flight controller, three Return-to-Home (RTH) modes, and both GPS and Vision Positioning Systems. 

When flying for this commercial purpose, I would be flying at a maximum altitude of 200 feet and flying 

mostly vertically for purposes of taking photos, thereby 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 sporting events or high-traffic 

areas, including airports, and I would pay attention to NOTAMS. I appreciate the FAA’s consideration of 

this petition for exemption.

Additional information:

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

the DJI Phantom 3 Professional and intend to implement all pre-flight safety checks, and utilize the 

safety technology provided with this unit. I intend to only fly in unpopulated, residential or rural 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 (VFR) Conditions.

I understand and will comply with all the health and safety regulations for PIC’s and will be the only 

operator under this exemption.

Operations of the DJI Phantom 3 Professional include the following information:

Diagonal Size 590mm 

Flying Weight 2.82 lbs (1280g)

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy Vertical: +/- 0.1m (when Vision Positioning is active) or +/-0.5m

 Horizontal: +/-1.5m

Max Speed 16 m/s

Max Service Ceiling Above Sea Level 6000m (Software altitude limit: 120m above takeoff point)
GPS Mode GPS/GLONASS

Battery DJI LiPo 4S Intelligent Flight Battery has a capacity of 4480 mAh and a voltage of 15.2

Charger 17.4V/100W

Remote Controller 2.400 GHz-2.483 GHz; up to 5 km/3.1 miles when FCC compliant and 3.5 km/2.1 

miles when CE compliant; 1.2A@7.4V; EIRP FCC 20dBm/CE 16 dBm

App/Live View DJI Go; EIRP 100mW; Power Spectral Density 6.9mW/MHz; Live View Working 

Freqency 2.4GHz ISM; Live View Quality 720P @ 30fps; Latency 220ms

 

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