Submitted by: 

Derrick J. Parsons 

 Accrue Land Services LLC 

3031 Haskell Road 

North East, PA 16428 (814) 881-4017 

Dparsons34@gmail.com 

Scope: 

Enhance and edit real estate listing videos and accurately survey property lines in 

Oil and Gas Title Research by using the Phantom 3 Professional Unmanned 

Aircraft System to conduct aerial photography, videography and surveying of real 

property. 

UAV Phantom 3 Professional: 

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

1280 Grams or 2.82192 Pounds. The Phantom 3 UAS that Derrick J. Parsons 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 mobile phone or tablet, and a 720p HD 

view of everything your camera sees as you fly is displayed live. This high 

resolution 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. Each of the four legs of 

the Phantom 3 contains a high-powered antenna, all constantly broadcasting the 

live video feed and receiving control commands from any direction. 

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 Derrick J. Parsons seeks 

1. Extent of Relief that Derrick J. Parsons 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 to operate the Derrick J. Parsons 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 Derrick J. Parsons’s business, Accrue Land Services LLC. The 

Phantom 3 is not able to carry passengers. 

2. Extent of Relief that Derrick J. Parsons seeks in regards to Section 91.7(a) Civil 

Aircraft Airworthiness 

Relief from Section 91.7(a) is requested to allow Derrick J. Parsons 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. Derrick J. Parsons will follow the DJI Phantom 3’s aircraft/component, 

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

c. Derrick J. Parsons will comply with all DJI manufacturer Safety Bulletins. 

3. Extent of Relief that Derrick J. Parsons seeks in regards to Section 91.119 

Minimum Safe Altitudes General relief from 91.119 is requested to allow Derrick 

J. Parsons 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. Derrick J. Parsons 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. 

Derrick J. Parsons will adhere to the following in order to maintain an 

acceptable level of safety associated with operations over private property: 

(a) Derrick J. Parsons will display signs in the immediate vicinity of 

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

(b) Derrick J. Parsons will not allow the Phantom 3 to operate at a speed greater 

than 

10kts. 
(c) Derrick J. Parsons 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) Derrick J. Parsons 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 Derrick J. Parsons 

operates. 

(e) Derrick J. Parsons 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) Derrick J. Parsons will not operate over private property without first finding 

a suitable alternate landing spot on the property. 

(g) Derrick J. Parsons will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

(h) Derrick J. Parsons 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) Derrick J. Parsons will not permit flight around vessels, vehicles and 

structures without permission from the owner. 

4. Extent of Relief that Derrick J. Parsons 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 

Derrick J. Parsons UAS will abort the flight in the events that the UA loses 

communications with the GPS signal. 

5. Extent of Relief that Derrick J. Parsons 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 Derrick J. Parsons 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 Derrick J. Parsons 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 Derrick J. Parsons 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. Derrick J. Parsons 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 and surveying for real estate marketing and/or oil and gas title 

research 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. 

Granting this exemption to me would allow me to provide this service and much 

needed information 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 and residents looking to 

relocate or build in the Erie area. 

Conclusion: 

As set forth herein, Derrick J. Parsons 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 and Oil and Gas markets. The Administrator 

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

FAA Modernization and Reform Act of 2012, Derrick J. Parsons 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)