8A Pilot Services, LLC 

William M. Ochoa 

1350 NW 143rd Avenue 

Pembroke Pines, FL 33028 

(719) 351-2581 

will8a2@msn.com 

Date: May 20, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Petition of 8A Pilot Services, LLC for Exemption Pursuant to Section 333 of the FAA 

Reform Act of 2012. 

Attn: To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, 8A Pilot Services, LLC, operator of Small Unmanned Aircraft Systems 

(“sUASs”) equipped to conduct aerial photography and videography, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUASs, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333.1. 

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace 

that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, 

would allow 8A Pilot Services, LLC to conduct commercial operations of small unmanned 

aircraft systems (“UAS”) meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333, Page 2. 

8A Pilot Services, LLC is an aviation services company owned and run by William M. Ochoa. 

Mr. Ochoa has an Airline Transport Certificate and is type rated in multiple corporate 

aircraft. He has nearly 18 years flying military airlift operations as well as Part 91 large 

cabin operations. His total time is nearly 4,400hrs. Also, Mr. Ochoa has been active in Radio 

Controlled Aircraft for over 35 years with experience in fixed wing and rotary wing aircraft. 

8A Pilot Services, LLC plans to exploit the capabilities of Unmanned Aerial Systems to offer a 

multitude of services, including: 

- Aerial surveying 

- Event Photography/Videography 

- Agriculture purposes 

- Real Estate Photography/Videography 

- Aerial Filmmaking and Photography 

- Construction site inspections and monitoring 
Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft 

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS 

operations in the NAS. Section 333(a) states that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before 

completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this 

Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress 

made it clear that Section 333 provides a mechanism for “expedited operation 

authorization” if several factors are met. Petitioner meets all requirements to permit FAA 

approval of commercial UAS operations. 

The Petitioner Requests Relief From the Following: Regulations from which the exemption is 

requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 Page 3 

14 C.F.R. 91.151(a) 

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

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401 - 91.417) 

Unmanned Aircraft System (UAS) are oftentimes seen as superior to helicopters due to the 

smaller devices, cheaper equipment and personnel cost, reduced noise and as such, a much 

smaller environmental impact which promotes public safety. 

We are petitioning for exemption to enable 8A Pilot Services, LLC to operate a DJI Inspire 1 

sUAS upgraded to the Version 1.2.1.03 firmware and equipped with a two-axis camera 

gimbal and using a High-Definition camera. This sUAS has a built-in capability to limit the 

height it flies above the ground and to limit the radius of the distance it flies from the 

operator. The Inspire 1 also has the failsafe function of the autopilot system which means 

when the communication between the Main Controller and the transmitter is disconnected, 

the outputs of all command sticks from controller will go to the center position. If the GPS 

signal is good enough, the system will automatically trigger a Return to Home function and 

will automatically land safely. 

Please refer to the included DJI Inspire 1 Instruction Manual for the performance limitations 

and flight operations. 

Aircraft weight is 6.5 lbs with battery, 2-Axis Camera Gimbal, and Camera.
A Pre-flight inspection will be performed by the PIC in accordance with the factory 

instruction manual. An added step will be the inspection of the propellers. A propeller will 

be replaced if it has any nicks and cracks with a manufacturers authorized propeller. 

The sUAS will be maintained in accordance with the manufacturers instruction manual and 

only manufacturer's authorized replacement parts will be used. 

FCC Information 

The Inspire 1 Remote Controllers will be used for controlling the sUAS and complies with part 

15 of the FCC rules. Operation is subject to the following two conditions: (1) This device 

may not cause harmful interference, and (2) this device must accept any interference 

received, including interference that may cause undesired operation. The Inspire 1 radio 

transmitter used for controlling the sUAS is wireless technology which has been tested and 

found to be compliant with the applicable regulations governing a radio transmitter in the 

2.400GHz frequency with a maximum transmission distance of 2km. 

Antenna Separation Distance 

When operating our Inspire 1 transmitter, the PIC will maintain a separation distance of at 

least 5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the 

antenna to meet RF exposure safety requirements as determined by FCC regulations. 

Pilot in Command and Observer Qualifications and Duties

The PIC will maintain at least a Private Pilot Certificate and a current Class III medical 

certificate, plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in the 

type of UAS utilized in operations. The PIC will have at least 100 hours total time and at 

least 30 hours flying Radio Controlled Model Aircraft of which will be 10 hours flying sUAS's. 

Training will be conducted at a local Radio Control Club flying field. 8A Pilot Services, LLC 

has the ability to provide "dual controls" utilizing two Inspire 1 transmitters with a wireless 

link between the transmitters. One transmitter is designated the master transmitter and 

the other transmitter is designated as a slave. The PIC instructor, utilizing the master 

transmitter, will be at all times be able assume control of the sUAS. 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties 

include all preflight preparation, in-flight operation, post-flight requirements, all procedures 

including but not limited to: Safe in-flight operations; Risk Mitigation to Persons and 

property; Airfield Suitability. 

The Observer must have the visual acuity to observe the sUAV and be able to communicate 

clearly with the PIC. 

The Observers duties are: 

-- warning the PIC of any impending obstacles in the flight path of the sUAS. 

-- warning the PIC of any deviations in the planned flight path of the sUAS. 

-- warning the PIC should any unauthorized personnel appear in the area of the planned 

flight. The Observer will have the authority to order the PIC to terminate the flight should 

he feel the flight cannot be conducted safely. 
General Operating Standards 

• 8A Pilot Services, LLC will only operate its sUAS in line of sight of a pilot and/or observer 

and will operate at sites that are a 'sufficient distance' from populated areas. Such 

operations will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public." 

• Before an operation of a sUAV within 5NM of an airport with a control tower, the control 

tower will be notified to gain permission to operate the sUAS. The PIC will give the position, 

altitude and the times the sUAV will be operated. The sUAS will not be operated at an 

altitude of over 300 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot 

ceiling. 

Before an operation of a sUAS within 5NM of a non-tower controlled, airport operators will 

be notified and the PIC will give the right of way to avoid flying in the proximity of full-scale 

aircraft. At no time will the sUAV be operated within the final approach course and the 

takeoff course of any runway. 

• Maximum flight time for each operational flight will be 30 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit. 

• The sUAV will be programmed so that it will not be operated at an altitude of more than 

400 feet AGL, and not more than 200 feet above an elevated platform from which filming is 

planned. 

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer. 

• The sUAV operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbals). 

• The sUAV will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the sUAV and the restricted sterile environment within which they 

will operate, our sUAV operations adhere to the Reform Act's safety requirements. 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on board 

and will thereby reduce current risk levels and thereby enhance safety and diminish the 

likelihood of death or serious bodily injury. With a small payload and maximum flight time 

of only 20 minutes, this offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than ground 

based imagery for displaying the characteristics of large, complex properties with several 
buildings and large trees. Compared to manned aircraft, the benefits of reduced cost and 

improved quality of presentation from the UA will be valuable to and benefit many buyers 

and sellers of real property. Additionally, we request that we be allowed to use our system 

to benefit first responders nearby who might require assistance, including fire fighters, the 

police, the sheriff, et al., while remaining subject to all limitations cited in this application 

as we do so. (a) No flight will be made with a Gross weight exceeding 55 pounds; 

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an 

airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; 

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the 

property owner; 

(e) All required permits will be obtained from state and local government prior to operation; 

(f) 8A Pilot Services, LLC UAS aircraft will not be operated over densely populated areas; 

(g) 8A Pilot Services, LLC UAS aircraft will not be operating over any open-air assembly of 

people; 

(h) 8A Pilot Services, LLC UAS aircraft will not be operating over heavily trafficked roads; 

(i) 8A Pilot Services, LLC UAS aircraft will not be operating at night. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

8A Pilot Services, LLC requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, 

we request an experimental certificate be issued for the DJI Inspire 1 under either or both of 

the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes: (a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and 

other operations to show compliance with the airworthiness regulations including flights to 

show compliance for issuance of type and supplemental type certificates, flights to 

substantiate major design changes, and flights to show compliance with the function and 

reliability requirements of the regulations. Since the experimental certificate can be used 

for commercial purposes such as market surveys, sales demonstrations, and customer crew 
training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will 

only fly under strict operational requirements. Combined with the UA's light weight, being 

constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as 

safe, if not safer, than a conventionally certificated aircraft performing the same mission. If 

an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an 

airworthiness certificate in general, citing the equivalent level of safety outlined in the 

previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on 

the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual 

Observer) and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation. Additionally, we feel that the permanent placard discussed in 

the previous paragraph will provide the aircraft's registration information at the ground 

station. Finally, we will display at the ground station a high contrast flag or banner that 

contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. 

Since the aircraft will operate within 3/4 NM of the ground station, the banner should be 

visible to anyone that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a Private Pilot certificate may act as pilot 

in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot 

to act as pilot in command of an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not 

carry passengers or property for compensation or hire. Our proposed operations require that 

the PIC must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA 

and since the aircraft cannot carry passengers or property, we feel we meet the intent of 

61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This 

regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. We 

request an exemption to this requirement since the aircraft is not only too small to carry 
documentation, the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose 

that a current, approved sUAS Flight Manual must be available to the crew at the ground 

station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The 

regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." Training will be 

conducted at a local Radio Control Club flying field. 8A Pilot Services, LLC has the ability to 

provide "dual controls" utilizing two Inspire 1 transmitters with a wireless link between the 

transmitters. One transmitter is designated the master transmitter and the other transmitter 

is designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all 

times be able assume control of the sUAV. 

91.119 Minimum safe altitudes: 

General. The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the sUAS would be photography or survey of persons, vessels, vehicles or 

structures it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been obtained 

and careful pre-planned flight path has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore we maintain that due to the small size of the 

UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, 

which should be considered in granting the exemption. 

CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 

feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with 

other aircraft. An Above Ground Level altimeter measurement above the takeoff point is 

transmitted via radio from the sUAS on-board computer to the display screen held by the 

PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly 

after that for at least 30 minutes. We feel the intention of this paragraph is to provide an 

energy reserve as a safety buffer for delays to landing. The sUAV is battery operated and the 

maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. 

Since the aircraft will never fly more than 3/4 NM from the point of intended landing, a full 

battery charge at launch will ensure that we meet the reserve energy requirement of this 

paragraph. We request an exemption to the word "fuel" and ask for an equivalent 

interpretation with the word "energy". 
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross 

weight of 6.5 pounds, the sUAS is too small to carry documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of 

safety and meet the intent of 91.203, we propose that documents deemed appropriate for 

this aircraft by the FAA will be with the crew at the ground control station and available for 

inspection upon request. In order to identify the aircraft, we propose that the information 

found on airworthiness and registration certificates be permanently affixed to the aircraft 

via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the 

requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43.7" after maintenance and inspection. It is our intention that the PIC 

perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every two 

hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and firmware 

for the on-board computer. All other maintenance will be performed by the manufacturer or 

their designated repair facility. The PIC will document work performed in accordance with 

91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can 

ensure an equivalent level of safety. 

Safety and Benefits of the UAS 

8A Pilot Services, LLC will be using the UAS in a variety of applications that generally require 

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer 

myriad benefits over the use of full-sized manned aircraft for electric power line inspection, 

oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a 

few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with 

small UAS carrying no passengers or crew creates a much greater margin of safety for the 

pilots and crew. By granting 8A Pilot Services, LLC‘s requested exemptions, the FAA will help 

drive development of safe and successful commercial UAS operations and will advance the 

public knowledge base for such operations. 8A Pilot Services, LLC is committed to promoting 

the UAS research efforts of policymakers including the FAA, NASA, DOD, and DARPA by 

sharing data from its commercial UAS operations and serving as a resource for future UAS 

research operations. Thus, the FAA has good cause to grant this Petition. 

Conclusion 

As pointed out in this application, all the sUAS which our company would use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of 
sight (LOS) of the Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 

miles from any airport, heliport, seaplane base, spaceport, or other location with aviation 

activities, unless the air traffic control authorities (ATC) have been notified and have 

authorized each flight within a radius of this distance. 

All our sUAS have proven capability for controlled flight. They are devices offered for 

general sale on the market around the world and have often been used as Model Aircraft in 

the USA. We are certain that the studies conducted until now by the FAA, about Section 332, 

Public Law 112-95, 2014, have already provided you with the assurances on the airworthiness 

of sUAS such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and 8A Pilot 

Services, LLC should be permitted to conduct small UAS operations in accordance with its 

manuals and all other operating parameters deemed necessary and appropriate by the FAA. 

The submission of this application and its contents is the best demonstration that indeed it is 

possible to pursue the authorization process so that some sUAS may be used for legitimate 

commercial activities and under reasonably safe conditions. 

Signed, 

William M. Ochoa 

8A Pilot Services, LLC