Mr. David Greitzer, of David Greitzer Photography, 8701 Winding Way, Fair Oaks, CA 95628 is 

petitioning the Federal Aviation Administration (FAA) for an exemption from part 21, subpart 

H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and 

(b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption would allow 

David Greitzer to operate the PHANTOM 3 Standard quad-copter unmanned aircraft system 

(UAS) to conduct aerial videography and cinematography to enhance academic community 

awareness for those individuals and companies unfamiliar with the geographical layout of the 

metro Sacramento area and augment real estate listing videos.

The petitioner supports his request with the following information:

The petitioner has provided the following information – contained in his petition and supporting 

documentation including: 1) Phantom3 Safety Guidelines

The FAA has organized the petitioner’s information into four sections: 1) the unmanned aircraft 

system (UAS), 2) the UAS Pilot In Command (PIC), 3) the UAS operating parameters and 4) 

Public Interest.

Unmanned Aircraft System

The petitioner states he plans to operate a UAS, the PHANTOM 3 Standard, which is comprised 

of an unmanned aircraft (UA or PHANTOM) and a transportable ground station.

The PHANTOM is referred to as a quad-copter with a maximum gross weight of about 3 pounds. 

It is equipped with four rotors that are driven by electric motors powered by batteries. The UA 

has a maximum airspeed of 30 knots. A small lightweight camera is attached to his UA and 

petitioner plans to operate the UA over various areas near Sacramento, California to enhance 

academic community awareness and augment real estate listing videos.

Petitioner makes the following representations of operational enhancements which he proposes 

to abide by to ensure this exemption will provide a level of safety at least equal to existing rules:

• He will only operate in reasonably safe environments that are strictly controlled, are away 

from power lines, elevated lights, airports and actively populated areas; and

• He will conduct extensive preflight inspections and protocols, during which safety carries 

primary importance.

The petitioner states that given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized by him, an exemption from 14 CFR part 21, Subpart 

H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject 

to certain conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333).
Petitioner requests an exemption from § 45.23 Marking of the aircraft because his UA will not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he 

states that two-inch lettering is difficult to place on such a small aircraft with dimensions smaller 

than the minimal lettering requirement. Regardless of this, petitioner states that he will mark his 

UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as 

required by § 45.29(f) so that he or anyone assisting him as a spotter will see the markings.

The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2)

and 91.417(a) and (b) Maintenance inspections may be required and should be granted since 

they only apply to aircraft with an airworthiness certificate. However, the petitioner states as 

a safety precaution he will perform a preflight inspection of his UAS before each flight 

as outlined in his operating documents.

UAS Pilot in Command (PIC)

The petitioner asserts that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however he can achieve an equivalent level of safety as achieved 

by current regulations because his UAS does not carry any pilots or passengers. Further, 

he states that, while helpful, a pilot license will not ensure remote control piloting skills. 

He further indicates that the risks of operating a UAS are far less than the risk levels inherent 

in the commercial activities outlined in 14 CFR part 61, et seq., thus he requests an 

exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.

Regarding UAS operational training, the petitioner states he has flown numerous practice flights 

in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization 

with the characteristics of his UAS’ performance under different temperature and weather 

conditions. He further states that he practices computerized simulated flights to maintain 

adequate skills and response reflex time.

In a supplemental request to the FAA, the petitioner requests consideration of a 120 

day temporary airman certificate in accordance with § 63.13, to allow him time to obtain a 

private pilot certificate or to allow the FAA time to establish minimum UAS airman 

certification standards.