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Drone Register# FA3Y4HKFM4 

DJI phantom 3 "professional" 

Dear Sir or Madam 

Pursuant to Section 333 of the FAA Modernization and reform Act of 2012 (the Reform Act} and 14 

C.F.R. part 11, John E. Evans a Licensed Real Estate Associated Broker in the State of Idaho and co-owner 

of Evans Realty LLC. Herby applies for an exemption from the Federal Aviation Regulations (FARs) listed 

below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace 

regulated by the Federal Aviation Regulations (FARs) so long as such operation are conducted with and 

under the conditions outlined herein or as be established by the FAA as required by section 333. 

The requested exemption would permit John E. Evans to pursue his commercial interests in providing 

services to clients using a small advanced sUAV in the following areas: Real Estate listing photos and 

videos, Marketing for private and Local Government promotions, and Special Events. John E. Evans 

states that all sUAV flights will occur over private or controlled access property and will do so with the 

property owner's consent and knowledge and that only people who have consented or otherwise have 

agreed to be within the UAS' radius during filming and photography. For public awareness John E. Evans 

to display signs in the immediate vicinity of operations stating: "Aerial Photography in Progress. Use 

Caution." Also writing permission from owner, business and or Government entity permission in writing 

before all flights. 

John E. Evans has demonstrated the ability and effectively fly the sUAV DJI phantom 3 "professional" 

which will be used for all commercial and private purposes. John E. Evans complies with local ordinances 

and law regarding the operations of the sUAV and adheres to all weather and environment restrictions 

or limitations in reference to the operations of sUAV. 

All flights will occur in ordinance with state or local laws regarding privacy. 

I, John E. Evans, am seeking the exemption because I am committed to complying with all of the rules, 

guidelines, limitations, and future legislations set forth by the FAA. I agree to operate the sUAV in the 

manner that I have described, and for the purposes that I decried. Without the exemption request 

granted, I would be unable safely and effectively run my business in a professional ethical manner, and it 

is my intention to comply with the FAA and obtain an exemption of the following regulations. 

The following contains my list of regulations from which I am seeking exemption, and a complete list of 

responsibilities I assume as operator, it also contains information regarding the aircraft, public benefit 

and safety features and similar petitions requests granted. 
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914 C.F.R. 1.103(b) 

14 C.F .R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.40S{a) 14 C.F.R. 91.407{a)(1) 14 C.F.R. 91.409(a)(2) 14 C.F.R. 91.417(a}and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 

Public Benefit and Safety and 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, its expense has been cost-prohibitive. 

Location of Evans Realty LLC is in a small community with the exemption to me would allow me to 

provide services at a much lower cost. With a small community the benefits can help with promotion to local entries (Gem County Chamber of Commerce and Local Government officials" Gem County 

Commissioners and City of Emmett'' for economic growth by Marketing and promotions. 

The Unmanned Aircraft System (UAS) will pose no threat to public given its size and lack of combustible 

fuel when compared to manned aircrafts. The (UAV) safety features include "return to home function" if 

loss of signal to home base, and function can be triggered manually. Person in control (PIC) has a remote 

transmitter that has continuous steaming and readings to altitude, distance and power level of (UAV). 

All with GPS contact to location. 

A summary we can publish in the Federal Register 

I, John E. Evans, on behalf of Evans Realty LLC., am seeking an exemption of the FAA's Sec 333 rules that 

does not allow the use of an Unmanned Aircraft to be used for Commercial purposes with respect to 

National Airspace Safety. I am simply petitioning for an exemption to provide a commercial service to 

our company who wishes to obtain and capture Aerial photography and videos of said properties for 

purposes including them in real estate listings, and for use as a marketing tool for our business, as well 

as inspection and maintenance programs and public needs for a small community. I John E. Evans 

understanding of the importance of different uses and safety concerns regarding FAA regulated 

airspace, we would be a good candidate for an exemption of Sec 333, while not putting Air Safety at risk. 

The specific UAS (OJ I phantom 3 "professional") I am seeking exemption with is one with many safety 

programs, including SAFE technology and GPS navigating. When flying for this commercial purpose we 

would be flying at a maximum altitude of 60 meters and flying mostly horizontally for the purposes of 

taking photos, decreasing the risk of any interference. Our pilot's general knowledge of the aviation 
clear of all utility lines, etc. We intend to be fully aware of our surroundings at all times and to only fly 

the unmanned aircraft within a visual line of sight and only in Visual Flight Conditions. 

We understand and will comply with all the health and safety regulations for PIC's and will have certified 

pilot in charge of the UAS under this exemption. 

We have no intention of using this exemption outside the United States 

Conclusion: 

As set forth herein, John E. Evans 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 sUAS 

commercially. The Administrator will be assisting small business by granting this petition. In accordance 

with the FAA Modernization and Reform Act of 2012John E. Evans respectfully requests that the FAA 

Administrator grants this petition for exemption from below list Regulations from which exemptions is 

requested: 

If you have any questions or require any additional information, please do not hesitate to call. 

Sincerely 

John E. Evans 

Evans Realty LLC. 

1302 S Washington 

Emmett, Idaho 83617 

{208) 365-8545 

John@JohnEvans.cc 

Drone Register# FA3Y4HKFM4 

DJI phantom 3 "professional" 

Regulations from which exemptions is requested: 

Part 21, subpart H 

Sections 45.23 (b) 

61.113 (a) and (b) 

14 C.F.R. 91.103(b) 

14 C.F.R. 91.109' 14 C.F.R. 91.119' 14 C.F.R. 91.121' 

14 C.F.R. 91.151(a)' 14 C.F.R. 91.203(a) and (b)' 14 C.F.R. 91.405(a)' 
pp

I John E. Evans request Exemption from Section 45.23 (b) 

(b) prescribes that when marks include only the Roman capital letter'' and the registration number the 

registration number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

I John E. Evans request Exemption from 61.113(a)and(b) 

(a) No person who holds a private pilots certificate may act as a pilot in command of an aircraft that 

is carrying passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment 

I John E. Evans request Exemption from 91.103(b) 

Prescribes that a pilot shall for any flight, become familiar with runway lengths at airport of intended 

ues, and takeoff and landing distance information 

I John E. Evans request Exemption from 91.109 Flight instruction; Simulated instrument flight and 

certain flight tests. 

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction 

may be given in an airplane that is equipped with a single, functioning throw over control wheel that 

controls the elevator and ailerons, in place of fixed, dual controls, when-

(1) The instructor has determined that the flight can be conducted safely; and 

(2) The person manipulating the controls has at least a private pilot certificate with appropriate category 

and class ratings. 

(b) An airplane equipped with a single, functioning throw over control wheel that controls the elevator 

and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review 

required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency 

check required by §61.57 when-

(1) The airplane is equipped with operable rudder pedals at both pilot stations; 

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the 

entire flight; 

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the 

requirements of §61.195(b), and has logged at least 25 hours of pilot-in-command flight time in the 

make and model of airplane; and 

(4) The pilot in command and the instructor have determined the flight can be conducted safely. 

(c) No person may operate a civil aircraft in simulated instrument flight unless-

( I) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate 

with category and class ratings appropriate to the aircraft being flown. 

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent 

observer in the aircraft adequately supplements the vision of the safety pilot; and 
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(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot 

certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the 

pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in 

command of the aircraft. 

[Doc. No. 18334, 54 FR 34294, Aug. 18, 1989, as amended by Arndt. 91-324, 76 FR 54107, Aug. 31, 2011] 

I John E. Evans request Exemption from 91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface-

(!) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this 

section, provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums 

prescribed in paragraph (c) of this section. 

[Doc. No.18334, 54 FR 34294, Aug. 18, 1989, as amended by Arndt. 91-311,75 FR 5223, Feb. 1, 2010] 

I John E. Evans request Exemption from 91.121 Altimeter settings. 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating-

(!) Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not 

equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting 

available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92" Hg. 

{b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as 

shown in the following table: 

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 
Current altimeter setting Adjustment factor 

29.92 (or higher) None 29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 

I John E. Evans request Exemption from 91.151(a} Fuel requirements for flight in VFR conditions. 

No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast 

weather conditions} there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruising speed 

I John E. Evans request Exemption from 91.203(a) and (b) Civil aircraft: Certifications required 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to 

comply with this subparagraph (except a special flight permit, a copy of the applicable operations 

specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual 

required by parts 121 and 135 ofthis chapter containing that portion of the operations specifications 

issued under §21.197(c), or an authorization under §91.611) must have on it the registration number 

assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not 

have on it an assigned special identification number before 10 days after that number is first affixed to 

the aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards 

district office. 

{2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, 

the second copy of the Aircraft Registration Application as provided for in §47.31(c), a Certificate of 

Aircraft registration as provided in part 48, or a registration certification issued under the laws of a 

foreign country. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

I John E. Evans request Exemption from 91.405(a) Maintenance required. 

Each owner or operator of an aircraft-

( a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter; 

I John E. Evans request Exemption from to 91.407{a)(1) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration. 
inspection required by this paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an "annual" inspection in the required maintenance records. 

I John E. Evans request Exemption from 91.417(a)and (b) Maintenance records. 

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph 

(b) (b) ofthis section 

I John E. Evans request Exemption from 91.7{a) Civil aircraft airworthiness. 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

I John E. Evans request Exemption from 91.9(b)(2) Civil aircraft flight manual, marking, and placard 

requirements. 

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

I John E. Evans request Exemption from 91.109 Flight instruction; Simulated instrument flight and 

certain flight tests. 

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction 

may be given in an airplane that is equipped with a single, functioning throw over control wheel that 

controls the elevator and ailerons, in place of fixed, dual controls, when-

(1) The instructor has determined that the flight can be conducted safely; and 

(2) The person manipulating the controls has at least a private pilot certificate with appropriate category 

and class ratings. 

(b) An airplane equipped with a single, functioning throw over control wheel that controls the elevator 

and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review 

required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency 

check required by §61.57 when-

(1) The airplane is equipped with operable rudder pedals at both pilot stations; 

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the 

entire flight; 

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the 

requirements of §61.195(b), and has logged at least 25 hours of pilot-in-command flight time in the 

make and model of airplane; and 

(4) The pilot in command and the instructor have determined the flight can be conducted safely. 

(c) No person may operate a civil aircraft in simulated instrument flight unless-

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate 

with category and class ratings appropriate to the aircraft being flown. 

{2) The safety pilot has adequate vision forward and to each side ofthe aircraft, or a competent 

observer in the aircraft adequately supplements the vision of the safety pilot; and 
(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot 

certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the 

pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in 

command of the aircraft. 

[Doc. No. 18334, 54 FR 34294, Aug. 18, 1989, as amended by Arndt. 91-324,76 FR 54107, Aug. 31, 2011] 

91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface-

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this 

section, provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums 

prescribed in paragraph (c) of this section. 

[Doc. No. 18334,54 FR 34294, Aug. 18, 1989, as amended by Arndt. 91-311, 75 FR 5223, Feb. 1, 2010 

FINAL 

If you have any questions or require any additional information, please do not hesitate to call. 

Sincerely 

John E. Evans 

Evans Realty LLC. 

1302 5 Washington 

Emmett, Idaho 83617 

(208) 365-8545 

John@JohnEvans.cc 

Drone Register# FA3Y4HKFM4 

DJI phantom 3 "professional"