Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Name: Tony Santoro

Address: 3223 Crow Canyon Rd. #110, San Ramon, CA 94583

Phone: 925-209-9597

Email: tony@clarksonsantoro.com

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

Petition for Exemption under Sec 333

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

Sec 333 prohibits the use of a UAS for commercial purposes on private property. I am a

member of the Academy of Model Aeronautics and 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 supplementing real estate listing 

videos. I would like to be able to accept payment for these services therefore making this a 

commercial use of a UAS.

How your request would benefit the public as a whole;

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 an experienced and certified RC Pilot in Command that understands how to safely

operate such technology. It would also help to increase property values in the neighborhoods 

where the photos and videos are taking by generating more interest to the online consumer for 

the property that feature the aerial photos and videography as part of the marketing material 

while listing the property.

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;

Being an AMA member and RC Pilot and therefore understanding 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 UAS (DJI 

Inspire 1 whose Operating Manual, Maintenance Manual and Safety Guidelines documents are 

Included in my petition) I am seeking exemption with is one with many safety programs, 

including SAFE technology and GPS navigating. 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, decreasing the risk of any interference. I would not be flying near disaster areas, 

sporting events, or high traffic areas including airports.

Furthermore, the system is fully FCC compliant. See FCC Compliance in the Appendix section, 

page 62, of the attached i1 User Manual for a full compliance statement.

I Intend to fly in one of these two safe modes:

• Flight Mode P– Positioning Mode 

• Flight Mode F– Function Mode

A detailed description of both flight modes is document on page #12 of the attached i1 User 

Manual.

I Intend to follow these general safety precautions along with all the Safety Guidelines 

detailed in the attached i1 Safety Guidelines document.

• 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 you.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

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

I, Tony Santoro, on behalf of Clarkson Santoro Inc., am seeking an exemption for of the FAA’s 

Sec 333 rules that does 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. I am a member of the 

Academy of Model Aeronautics and 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 supplementing real estate listing videos. I 

would like to be able to accept payment for these services therefore making this a commercial 

use of a UAS.
Being an AMA member and RC Pilot and therefore understanding 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 UAS (DJI 

Inspire 1) I am seeking exemption with is one with many safety programs, including SAFE 

technology and GPS navigating. 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, 

decreasing the risk of any interference. I would not be flying near disaster areas, sporting 

events, or high traffic areas including airports.

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

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

manual for the DJI Inspire1 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, 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 Conditions.

My Membership Number in the Academy of Model Aeronautics is 1076467 for 2015

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

the only operator under this exemption.

Please refer to the attached i1 User Manual for system specifications:

General Safety Precautions and Warnings I intend to Follow

• Always keep a safe distance in all directions around your model to avoid collisions

or injury. This model is controlled by a radio signal subject to interference

from many sources outside your control. Interference can cause momentary

loss of control.

• Always operate your model in open spaces away from full-size vehicles, traffic

and people.

• Always carefully follow the directions and warnings for this and any optional

support equipment (chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach

of children.

• Always avoid water exposure to all equipment not specifically designed and

protected for this purpose. Moisture causes damage to electronics.

• Never place any portion of the model in your mouth as it could cause serious

injury or even death.

• Never operate your model with low transmitter batteries.

• Always keep aircraft in sight and under control.

• Always move the throttle fully down at rotor strike.

• 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.

• 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 have no intention on using this exemption outside the United States