FAA-2007-0001 

Paul Funk

Aerovues

100 W. Montereys Ave.

Schaumburg, IL 60193

847-361-7074 (cell)

This request is in reference to the FAA Modernization and 

Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, 

Section 333. I would like to request an exemption to allow for 

the following applications:

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals
• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Aerial Videography and Photography

• Creation of commercial messages for Television.

• Motion Picture Filming

• Increase public knowledge of UAS and promote safe UAS 

operations.

While requesting the exemption for the use of the UAS for 

these applications I would like to present my case for the 

exemption from the following regulations.

14 C.F.R § 61.113(a) & (b)

91.7(a)

91.121

91.151(b)
91.405(a)

91.407(a)(1)

91.409(a)(1) & (a)(2)

91.417(a) & (b)

The drone we are requesting exemption for is the DJI 

Phantom Pro. We have chosen this drone due to it's 

reliability and safety features which have all been granted 

previous exemptions. This drone will be equipped with a 4k, 

high resolution camera, which will be used for the 

photography and video portion of the applications we are 

seeking exemption for. For the purposes of brevity, the 

extent and reason for relief will be explained below per each 

requirement.

In consideration of the speed, weight, size, and limited 

operating area associated with the unmanned aircraft and its 

operation, Aerovues DJI Phantom Pro’s UAs meets the 
conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.

Accordingly, Aerovues requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness 

certificate. There will still be a safety requirement in effect to 

ensure proper operation of the drone at all times. Which will 

include a manual pre-flight check, a weekly maintenance 

check, and a limit to flight times based on available flight 

capability.

This flight time will not exceed half of the available flight 

time. A maintenance checklist will be maintained for all 
pre-flights and weekly check. Any repairs needed to be made 

will be documented, along with any failures that caused an 

inability to fly. Also at any time the logs will be made 

available to any parties involved with the flight. Also any law 

enforcement may ask at any time for any of the flight 

manuals and/or logs. Records will be kept of each check for 

the life of the use of the drone for commercial purposes. 

These documents will be kept with the (PIC) during flight. 

Relief from certain requirements of Section 61.113(a) and 

(b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested by Arovues, to the extent necessary 

to allow a Pilot in Command (PIC) with a minimum of 20 

hours of UAS flight time with the specified model. This is to 

include emergency maneuvers to avoid any private or public 

damage, and any injuries to the public, by an unforeseen 

failure of the drone in use. A device (such as cell phone) 
capable of contacting emergency services and a first aid kit 

at the flight site at all times. We would also like to request 

relief due to the UAS not being manned but pilot or 

passengers, and due to it's small size and weight, and 

complying with staying under 200 feet of altitude, similar to 

an ultralight which does not require certification either. Also 

since I am requesting exemption from the aircraft worthiness 

certificate I would be unable to provide all of the required 

documentation for gaining the pilot certification. All of the 

(PIC)s will still be required to have yearly physicals, and any 

corrective devices used authorized and prescribed by a 

Board Certified MD.

Aerovues seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom Pro UAS do 

not require an airworthiness certificate in accordance with 14 
C.F.R. Part 21, Subpart H. As such we will maintain 

airworthiness based on the operator manuals and 

precedents set by prior granted exemptions. This is to 

include the aforementioned maintenance check, pre-flight 

checks, and minimum (PIC) requirements.

Aerovues also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI 

Phantom Pro will not have a barometric altimeter onboard. 

However, altitude information of the DJI Phantom Pro UAS 

will be provided to the (PIC) via Global Positioning System 

(GPS) equipment and radio communications telemetry data 

link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. Also with the current model at 

no time will the DJI Phantom Pro leave the (PICS)s visual 

line of sight. With our current intended uses of the UAS we 
will also not have a need to exceed 200 feet of altitude.

Additionally, Aerovues, seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Aerovues submits 

that safety will not be affected by operation of the DJI 

Phantom Pro UAS during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total duration of 

approximately 10 minutes, which is more than enough time 

needed for our intended applications of use. Also to ensure 

safety, once flight time, or battery power (whichever occurs 

first) have reached a halfway mark, the UAS will be returned 

to the flight area and a freshly charged battery will be used if 

more flight time is needed.
In accordance with 14 C.F.R. § 11.81, provides the following 

information in support of its petition for exemption Name and 

contact information of intended Primary (PIC)s

Paul B. Funk

100 W. Monterey Ave.

Schaumburg, IL 60193

(847) 361-7074 cell

Specific areas of requested exemption.

Section Part 21, Subpart H

Section 61.113(a) And (b)

Section 91.121

Section 91.151(b)

Section 91.405(a)

Section 91.407(a)(1)

Sections 91.409(a)(1) And 91.409(a)(2
Sections 91.417(a) And 91.417(b).

Per the mission behind integrating UAS into the NAS below 

is how granting Aerovues an exemption will benefit the 

public. Increased safety for aerial photography. Typical 

means of aerial photography require a manned and piloted 

vehicle. The ability to use a drone will not only cut down on 

environmental and noise pollution, but will also increase 

personal safety by being unmanned, lighter, and using 

electrical propulsion instead of gas powered.

Economical Benefits. Granting us this exemption will help 

Aerovues stabilize it's business plan, in turn this will provide 

Aerovues income, and allow us to assist others with 

advertising of their business which in turn can increase their 

revenue. All of this can also be offered more affordable than 

the typical means, and those that may not have had access 
to this method before now may have a viable solution.

Any concerns of Privacy will be complied with by asking for 

property owner permission before any flight is taken. Also by 

cooperating with any civil service or law enforcement 

agency. Also any commercial flight will be well documented 

with address, time, property owner names, and intent of 

flight. Copies of these will be made available to any involved 

parties that may ask.

Granting these exemptions will not be a danger to public 

safety due to the stringent pre-flight requirements we are 

placing all (PIC)s under. As explained earlier all (PIC)s will 

have a minimum of 20 hours of documented flight time with 

the intended drone, as well as thorough knowledge of the 

maintenance requirements of the specific model. All (PIC)s 
will also maintain the capability (such as a cell phone) to 

contact any emergency services that may be necessary. All 

(PIC)s will also only fly in daylight hours with Visual 

meteorological conditions and Visual flight rules. The drone 

will never be flown longer than 50% of the intended battery 

life or average flight time, whichever occurs first. The drone 

itself is also equipped with several safeties of it's on 

including a return to flyer when it loses connectivity with the 

(PIC) or if the battery life does suddenly drop to %10. These 

safety requirements and pre-flight requirements were all 

pulled from previously granted exemptions by the FAA. 

aerovues have chosen the requirements that we felt we 

could comply with, that also provided an adequate level of 

safety. Some of these requirements were pulled from the 

previously granted exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 
11138, 11150, 11153, 11156, 11158, 11159, 11160,

11161.

Due to having met the previous requirements, and due to the 

size and weight of the intended drone. We also do not 

believe this drone to be a danger to the NAS or National 

Security. This Petition is made pursuant to the FAA

Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, 

Aerovues request for exemption may be granted pursuant to 

the authority of FMRA Section 333 and 14 C.F.R. Part 11, as 

set forth above. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose 

a threat to national security; and further, provides the 
authority for such UAS to operate without airworthiness 

certification. As discussed in detail above, Aerovues will 

operate the DJI Phantom Pro UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security.

In Conclusion, Aerovues thanks the FAA for it's time, we 

understand many of exemptions are being requested at this 

time, therefore we have tried our best to cover the material 

necessary but in a brief format. If there are any other 

questions please feel free to contact the

owner, Paul Funk for answers to any technical or safety 

concerns.