Submitted by: 

Jake Coon

4603 W Bull Moose Ct

West Jordan, UT 84088

(801) 674-0508

jakecoonmail@gmail.com

Scope:

Enhance and augment real estate listing videos by using the Phantom 3 

Professional Unmanned Aircraft System to conduct aerial photography and 

videography of real property. 

UAV Phantom 3 Professional:

The DJI Phantom 3 is a quad-rotor Unmanned Aircraft System (UAS) 

weighing less than 3 pounds. The Phantom 3 UAS that Jake Coon will be 

responsible for also utilizes a mobile ground station. The UAS features a 

safety Return to Home function that in the event of a signal loss, the UAS 

will return to a preset position and land. The Return to Home feature can 

also be triggered manually. The remote connects to your phone or tablet, and 

a 720p HD view of everything your camera sees as you fly is displayed live. 

This immersive view streams to you in absolute clarity, enabling safe flying. 

From takeoff to landing, the Phantom 3 responds to commands while 

automatically handling the most complex aspects of safe, stable flight.

Request:

An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 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) as was granted to Ralph J. Apel in Exemption 

No. 11410

Petition:

I request an exemption from TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 

91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 

(a) and (b)

The Extent Of Relief that Jake Coon seeks

1. Extent of Relief that Jake Coon seeks regarding Section 61.113 (a) and (b) 

Private Pilot Privileges and Limitations
Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in 

Command holding a current Private Pilots Certificate to operate the Jake 

Coon's Phantom 3. The flight would be complimented by a Visual Observer 

who, along with the pilot, will maintain Visual Line of Sight with the 

Phantom 3 at all times. All operations conducted will be incidental to Jake 

Coon's business. The Phantom 3 is not able to carry passengers.

2. Extent of Relief that Jake Coon seeks in regards to Section 91.7(a) Civil 

Aircraft Airworthiness

Relief from Section 91.7(a) is requested to allow Jake Coon to determine 

airworthiness of the Phantom 3. As part of this determination the following 

will be adhered to:

a. Prior to the Phantom 3's flight the PIC will inspect the UA to ensure it is 

in a condition that will be conducive for a safe flight. The ground control 

station will be included in the above inspection.

b. Jake Coon will follow the DJI Phantom 3’s aircraft/component, 

maintenance, overhaul, replacement, inspection and life limit requirements.

c. Jake Coon will comply with all DJI manufacturer Safety Bulletins.

3. Extent of Relief that Jake Coon seeks in regards to Section 91.119 

Minimum Safe Altitudes General relief from 91.119 is requested to allow 

Jake Coon to operate the Phantom 3 at altitudes not to exceed 400’ AGL 

over private property at a distance at or greater than 5NM from the nearest 

airport as depicted on current Aeronautical Charts. Jake Coon also wishes to 

be granted exemption to operate at an altitude not greater than 50’ AGL 

(below tree level) between 1NM and 5NM from the nearest airport as 

depicted on current Aeronautical Charts.

Jake Coon will adhere to the following in order to maintain an acceptable 

level of safety associated with operations over private property:

(a) Jake Coon will display signs in the immediate vicinity of operations 

stating: “Aerial Photography In Progress. Use Caution.”

(b) Jake Coon will not allow the Phantom 3 to operate at a speed greater than 

10kts.

(c) Jake Coon will require the UAS operator (PIC) to be fully trained on the 

Phantom 3 by adhering to the recommendations contained within the 

Phantom 3’s operating manual.

(d) Jake Coon will have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. In addition the operator will have logged a minimum of 5 

hours as a UAS pilot operating the make and model UAS that Flying Jake 

Coon operates.
(e) Jake Coon will be familiar with and able to manually institute the 

Phantom 3’s Return to Home (RTH) feature. This feature aborts a flight 

operation and automatically returns the UAS to a predetermined GPS safe 

point.

(f) Jake Coon will not operate over private property without first finding a 

suitable alternate landing spot on the property.

(g) Jake Coon will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

(h) Jake Coon will utilize a two man flight team consisting of the Pilot in 

Command (PIC) and a Visual Observer (VO). This team will maintain visual 

line of sight with the Phantom 3 at all times and remain within hearing of 

one another.

(i) Jake Coon will not permit flight around vessels, vehicles and structures 

without permission from the owner.

4. Extent of Relief that Jake Coon seeks in regards to Section 91.121 

Altimeter Settings

Relief from 91.121 is requested because the Phantom 3 utilizes electronic 

GPS with a barometric sensor.

In order to maintain an equal level of safety that 91.121 requires, the PIC of 

the Jake Coon's UAS will abort the flight in the events that the UA loses 

communications with the GPS signal.

5. Extent of Relief that Jake Coon seeks in regards to Section 91.151(b) Fuel 

Requirements for Flight in VFR Conditions

Relief from 91.151(b) is requested to the extent that allows Jake Coon to 

operate the Phantom 3 up to a point (considering wind and forecast weather 

conditions) that there is enough power to fly at normal cruising speed to the 

intended landing point and land the UA with 30% battery power remaining.

6. Extent of Relief that Jake Coon seeks in regards to Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) These are all 

associated a with Airworthiness certificate

Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is 

requested to the extent that allows Jake Coon to operate the Phantom 3 

Quad-Copter as necessary. These sections are all related to airworthiness 

certificates of aircraft. There is not currently an airworthiness certificate for 

small UAS’s. Jake Coon would comply in full to any conditions and 

limitations that the Administrator would place in order to receive an 

approved Grant of Exemption.

Public Interest:
Aerial videography for real estate marketing has been around for a long time 

through manned fixed wing aircraft and helicopters, but for small business 

owners, it's expense has been cost-prohibitive. Granting this exemption to 

me would allow me to provide this service at a much lower cost. My UAS 

will pose no threat to the public given its small size and lack of combustible 

fuel when compared to manned aircraft. The operation of my UAS will 

minimize ecological damage and promote economic growth by providing 

information to companies looking to relocate or build in the Salt Lake area. 

Conclusion:

As set forth herein, Jake Coon seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the DJI Phantom 3 UAS 

commercially within the Real Estate markets. The Administrator will be 

assisting small business by granting this petition. In accordance with the 

FAA Modernization and Reform Act of 2012, Jake Coon respectfully 

requests that the FAA Administrator grants this petition for exemption from 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 

91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)