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Tecnomedia		&	Satellite	Services	LLC

Attn:	Claudio	P.	Fernandez

2179	N	Powerline	Road	Ste	1

Pompano	Beach	FL	33139

US	Department	of	Transportation

Docket	Management	System

1200	New	Yersey	Ave.,	SE

Washington	DC	20590

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation	Regulations	

from:	14	CFR	21	subpart	H;	14	CFR	45.23(b);	14	CFR	61.113(a)	and	(b);	14	CFR	91.7(a);	14	CFR	91.9(b)(2);	14	CFR	91.103;	

14	CFR	91.109;	14	CFR	91.119(c);	14	CFR	91.121;	14	CFR	91.151(a);	14	CFR	91.203	(a)	and	(b);	14	CFR	91.405	(a);	14	CFR	

91.407	(a)	(1)	14	CFR	91.409	(a)(1)	and	(2);	14	CFR	91.417(a)	and	(b)	

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14	CFR	Part	11,	V-Tail	

Aviation	Inc.,	operator	of	an	Unmanned	Aircraft	System	(UAS),	hereby	applies	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	UAS,	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.	

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	sensors,	would	operate	in	

the	following	manner:	

Aerial	 photography	 and/or	 video	 for	 public	 and/or	 private	 use	 including	 real	 estate,	 architecture,	 land	 surveying,	

engineering	and	other	related	professional	activities.

Aerial	video	and/or	photography	 for	public	and/or	private	use	including	 television,	public	events,	cinematography	and	

news	gathering.	

Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	the	owners	or	local	government	

authority.

Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	including	but	not	limited	to	electrical	power	

lines,	wind	turbines	and	cell	towers.

Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue	operations	in	cases	of	an	emergency	

or	natural	disaster	only	when	the	local	authorities	or	government	has	requested	it	by	contract	or	donation.

The	ability	 to	offer	 training	 to	persons	individually	or	belonging	 to	both	private	and/or	public	organizations	 that	have	

interests	in	the	use	and	application	of	a	UAS	for	the	purpose	of	the	safe	operation	of	a	UAS	to	enhance	the	safety	of	the	

National	Airspace	System	(NAS)	as	well	as	for	the	protection	of	the	persons	and	property.	
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As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	a	UAS	under	controlled	conditions	in	

the	NAS	that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	will	provide	safety	enhancements	to	the	already	

safe	operations	in	the	industry	presently	using	conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance	

safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	“....establish	requirements	

for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace	system.”	

The	name	and	address	of	the	applicant	is:	

Tecnomedia	 &	 Satellite	 Services	 LLC. Attn:	 Claudio	 P.	 Fernandez,	 CEO. Phone:	 +1 786	 342	 9400 Email:	

pfernandez@tecnomedia.tv Address:	2179	N	Powerline	Road	Ste	1,	Pompano	Beach,	FL	33069

Regulations	from	which	the	exemption	is	requested:	14	CFR	Part	21	subpart	H 14	CFR	45.23	(b) 14	CFR	61.113	(a)	&	(b)	

14	CFR	91.7	(a) 14	CFR	91.9	(b)	(2) 14	CFR	91.103 14	CFR	91.109 14	CFR	91.119	(c) 14	CFR	91.121 14	CFR	91.151	(a) 14

CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b) Tecnomedia	

&	Satellite	Services	LLC.	will	operate	 the	DJI	Phantom	 3	Professional	, Model	W323A,	with	a	 total	weight	of	 1280g	or	

2.82Lbs,	 including	 battery and	 propellers. GPS	Mode:	 GPS/GLONASS.	 Maximun	 ascent	 speed	 5	 mts/seg;	 11.18	 mph,

Maximun	descent	speed	3 mts/seg;	6.71 mph.	Maximun	Speed,	no	wind conditions:	16 m/s; 35.79 mph.	 Software	Altitude	

Limit	120m;	393ft.	

The	DJI	Phantom	3	Professional has	the	ability	to	hover	and	move	along	a	vertical	and	horizontal	plane	simultaneously.	

The	DJI	Phantom	3	Professional has	four motors,	Motor	Model	DJI	2312,	powered	by	a 4480mAh,	15.2V, LiPo	2S,	68Wh

battery. There	are	four	propellers,	Propeller	Model	DJI	9450L,	in	use.	The	DJI	Phantom	3	Professional	will	be	controlled	

with	the	DJI	Model	GL300B remote	controller	with an	operating	frequency	of	2.400GHz	– 2.483GHz.	The	live	video	feed	

will	have	an	operating	frequency	of	2,4Ghz.	The	applicant	will	operate	the	UAS	in	line	of	sight	within	a closed	off	and	

predetermined	 area	 owned	 and/operated	 by	 the	 property	 representative. Given	 the	 small	 size	 of	 the	 UAS	 and	 the	

controlled	 environment	 provided	 the	 proposed	 operations	 will	 adhere to	 the	 Reform	 Act’s	 safety	 requirements.	 The	

approval	of	this	application	presents	no	national	security issues.	Regarding	the	level	of	safety	surrounding	the	proposed	

operations	and	the	public	benefit,	reduction	in	environmental	impacts,	including	but	not	limited	to	reduced	emissions	and	

noise,	the	grant	of	the requested	exemption	is	in	the	public	interest.	Accordingly, the	applicant	requests	that	the	FAA	

grant	the	requested	exemption	with	minimum	delay.	

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY	

The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety	because	operations	will	further	enhance	the	

safety	of	the	persons	and/or	property	using	conventional	aircraft. These	limitations	and	conditions	to	which	the	applicant	

agrees	to	adhere	to	when	conducting	commercial	operations	under	the	FAA	issued	exemption	as	set	forth	in	the	Flight	

Operations	Manual	(FOM)	include:	

The	UAS	will	weigh	less	than	55	lbs.	
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The	UAS	will	have	a	maximum	operating	speed	of	no	more	than	50mph.

Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual	Observer	(VO).

Maximum	flight	time	for	each	operational	flight	will	be	17	minutes.	Flights	will	be	terminated	at	25%	battery	power	reserve	

or	30	minutes	of	flight	time	whichever	occurs	first.	

Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(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	UAS	Pilot,	the	Visual	Observer	(VO)	and	may include	but	not	limited	

to	a	Camera	Operator.	

The	UAS	pilot	will	be	a	designated	Pilot	in	Command	 (PIC)	and	hold	a	Commercial	Pilot’s	License	along	with	a	Third	or	

higher	Class	Medical	Certificate.	If	 the	PIC	 feels	another	operator	 to	be	qualified	with	 the	necessary	skills	 to	be	PIC	&	

possess	a	Commercial	Pilot’s	License	along	with	a	Third	or	higher	Class	Medical	Certificate,	that	person	may	be	designated	

PIC	provided	they	have	a	minimum	of	20	hours	of	flight	time	with	the	UAS.	

A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	day’s	flight	consisting	of	all	the	days’	

production	activities.

All	flights	will	occur	under	Visual	Flight	Rules	Meteorological	Conditions	(VFR)	only.

The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	 (ARP)	of	a	tower	

controlled	or	uncontrolled	airport.	

If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	(ARP) of	a	tower	controlled	

or	uncontrolled	airport	the	respective	airports	will	be	contacted	advising	them	of	the	estimated	flight	time,	flight	duration,	

elevation	of	flight	and	other	pertinent	information.

The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	planned	operation	and	ensure	that	only	

consenting	persons	will	be	allowed	within	100	feet	of	the	flight	operation,	and	the	radius	may	be	reduced	to	30	feet	based	

upon	an	equivalent	level	of	safety	determination,	as	required	under	the	FOM.	With	the	advanced	permission	of	the	FSDO,	

operations	at	closer	range	may	be	approved.

The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up-to-date	information	for	the	particular	UAS	to	

be	operated.

The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	times.

Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	county	or	city	jurisdictions,	including	

law	enforcement,	fire	or	other	appropriate	governmental	agencies.

If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS	will	have	the	capability	to	return	

to	a	pre-determined	location	within	a	designated	location	and	land	autonomously.
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The	UAS	will	have	the	capability	to	abort	a flight	in	case	of	unpredicted	obstacles,	weather,	or	emergencies.	

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)	

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	issuance of	airworthiness	

certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	and	limited	operating	area	associated	with	the	aircraft	to	be

utilized	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety	

under	Part	11	and	Section	333	of	the	Reform	Act.	The	Federal	Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of	the	

Reform	 Act	 both	 authorize	 the	 FAA	 to	 exempt	 aircraft	 from	 the	 requirement	 for	 an	 airworthiness	 certificate,	 upon	

consideration	 of	the	 size,	weight,	 speed,	 operational	 capability,	and	 proximity	 to	airports	and	 populated	areas	 of	 the	

particular	UAS.	In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	an	airworthiness	

certificate,	 in	 the	 restricted	environment	 and	 under	 the	 conditions	 proposed	 will	 be	 at	 least	 as	 safe,	 or	 safer,	 than	 a	

conventional	aircraft	 (fixed	wing	or	 rotorcraft)	operating	with	an	airworthiness	certificate	without	 the	 restrictions	and	

conditions	proposed.	

The	 UAS	 to	 be	 operated	 hereunder	 is	 less	 than	 55	 lbs.	 fully	 loaded,	 carries	 neither	 a	 pilot	 nor	 passenger, carries	 no	

explosive	materials	or	flammable	liquid	fuels,	and	operates	exclusively	within	a	secured	and designated	area.	Unlike	other	

civil	aircraft,	operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	both	the	operator	and	under	

the	requirements	and	in	compliance	with	local	public	safety	requirements.	These	safety	enhancements	provide	a	greater	

degree	 of	 safety	 to	 the	 public	 and	 property	 owners	 than	 conventional	 operations	 conducted	 with	 airworthiness	

certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	

Lastly,	application	of	these	same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	security	posed	by	the	

UAS,	due	to	its	size,	speed	of	operation,	location	of	operation,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	

inability	to	carry	a	substantial	external	load.	

14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft	

The	regulation	requires: When	marks	include	only	the	Roman	capital	letter	"N"	and	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	each	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. Even	though	the	UAS	will	have	no	airworthiness	certificate,	an	exemption may	be	needed	as	the	UAS	will	have	

no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word	“Experimental”	can	be	placed.	Given	the	size	of	the	

UAS,	two-inch	lettering	will	be	impossible.	The	word	“Experimental”	will	be	placed	on	the	fuselage	in	compliance	with	

§45.29	(f). The	equivalent	level	of	safety	will	be	provided	by	having	the	UAS	marked	on	its	fuselage	as	required	by	§45.29	

(f)	where	the	pilot,	observer	and	others	working	with	the	UAS	will	see	the	identification	of	the	UAS	as	“Experimental.”	
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14	C.F.R.	§	61.113	(a)	and	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.	

Pursuant	to	14	CFR	61.113	(a)	&	(b),	no	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in command	of	an	

aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	Tecnomedia	&	Satellite	Services	LLC.	may	achieve	

an	equivalent	level	of	safety	as	achieved	by	current	Regulations	because	the	applicant’s	UAS	do	not	carry	any	pilots	or	

passengers	 nor	 property.	 The	 risks	 attendant	 to	 the	 operation	 of	 UAS	 is	 far	 less	 than	 the	 risk	 levels	 inherent	 in	 the	

commercial	activities	outlined	in	14	CFR	61.

14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness.	

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	As	there	will	be	no	

airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	

for	determining	airworthiness.	Given	the	size	of	the	aircraft	for	maintenance	and	use	of	safety	check	lists	prior	to	each	

flight	an	equivalent	level	of	safety	will	be	provided.	

14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.	

Section	 91.9	 (b)	 (2)	 provides:	 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.	The	

UAS,	given	its	size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight	manual	on	the	aircraft,	not	only	because

there	is	no	pilot	on	board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft.	The	equivalent	

level	of	safety	will	be	maintained	by	keeping	the	flight	manual	at	the	ground	control	point	where	the	pilot	flying	the	UAS	

will	have	immediate	access	to it.	

14	C.F.R.	§	91.103:	Preflight	Action.	

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure	the	safety	of	flight.	As	FAA	

approved	rotorcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an	exemption	will	be	needed.	The	PIC	will	take	all	

actions	as	stated	in	the	FOM	in	Section	4	under	Normal	Procedures	including	but	not	limited	to	reviewing	weather,	flight	

battery	requirements,	landing	and	takeoff	distances	and	aircraft	performance	data	before	initiation	of	flight.	

14	C.F.R.	§91.109:	Flight	Instruction.	

Section	91.103	provides	that	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.	UAS and	remotely	piloted	aircraft,	by	their	design	

do	not	have	fully	functional	dual	controls.	
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Flight	 control	 is	 accomplished	 through	 the	 use	 of	 a	 control	 box	 that	 communicates	 with	 the	 aircraft	 via	 radio	

communications.	The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional	dual	controls	for	a	number	

of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	The	equivalent	level	of	safety	provided	by	the	fact	that	neither	

a	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by	the	size	and	speed	of	the	aircraft.	

14	C.F.R.	§91.119:	Minimum	Safe	Altitudes.	

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	91.119	(d)	allows	helicopters	to	be	operated	

at	less	than	the	minimums	prescribed,	provided	the	person	operating	the	helicopter	complies	with	any	route	or	altitudes	

prescribed	 for	helicopters	by	 the	FAA.	As	 this	exemption	is	 for	a	UAS	 that	is	a	helicopter	and	 the	exemption	 requests	

authority	to	operate	at	altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	elevated	platform	from	which	filming	is	

planned,	an	exemption	may	be	needed	to	allow	such	operations.	As	set	forth	herein,	the	UAS	will	never	operate	at	higher	

than	400	AGL	with	the	exception	that	in	circumstances	where	the	UAS	is	used	to	survey	or	photograph	a	structure	whose	

height	exceeds	400	feet	AGL,	the	UAS	will	not	be	operated	more	than	200	feet	above	the	highest	point	on	the	structure.	

It	will	however	be	operated	in	a	restricted	area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed	

to	operations	without	their	pre-obtained	consent. The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	

speed	of	the	UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of the	property	

owner	or	local	officials.	Because	of	the	advance	notice	to	the	property	owner	and	participants	in	the	filming	activity,	all	

affected	individuals	will	be	aware	of	the	planned	flight	operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	

weighting	far	more	than	the	maximum	55lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any	risk	associated	with	

these	operations	is	far	less	than	those	presently	presented	with	conventional	aircraft	operating	at	or	below	500	AGL.	In	

addition,	the	low-altitude	operations	of	the	UAS	will	ensure	separation	between	these	UAS	operations	and	the	operations	

of	conventional	aircraft	that	must	comply	with	Section	91.119.	

14	C.F.R.	§91.121	Altimeter	Settings.	

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	altitude	by	reference	to	an	altimeter	that	

is	set	“...to	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter	setting	available	before	departure.”	As	the	

UAS	may	not	have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may	be	needed.	An	equivalent	

level	of	safety	will	be	achieved	by	the	operator,	pursuant	to	the	safety	check	list	and	live	flight	data	monitoring,	confirming	

the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight.	

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions	

Section	91.151	(a)	prohibits	an	individual	from	beginning	“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	– (1)	During	the	day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	

least	45	minutes.”	
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The	 battery	 powering	 the	UAS	 provides	approximately	 30 minutes	 of	 powered	 flight.	To	meet	 the	 30	minute	 reserve	

requirement	in	14	CFR	§91.151,	UAS	flights	would	be	limited	to	approximately	10	minutes	in	length.	Given	the	limitations	

on	the	UAS’s	proposed	flight	area	and	the	location	of	its	proposed	operations	within	a	predetermined	area,	a	longer	time	

frame	 for	 flight	in	daylight	or	twilight	VFR	conditions	is	reasonable.	Applicant believes	that	an	exemption	 from	14	CFR	

§91.151(a)	falls	within	the	scope	of	prior	exemptions.	Operating	the	UAS,	in	a	tightly	controlled	area	where	only	people	

and	property	owners	or	official	representatives	who	have	signed	waivers	will	be	allowed,	with	less	than	30	minutes	of	

reserve	fuel,	does	not	engender	the	type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	

of	the	small	UAS.	Additionally,	limiting	UAS	flights	to	10	minutes	would	greatly	reduce	the	utility	for	which the	exemption	

will	be	granted.	Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	minutes	or	

25%	of	battery	power— whichever	happens	first.	This	restriction	would	be	more	than adequate	to	return	the	UAS	to	its

planned	landing	zone	from	anywhere	in	its	limited	operating	area.	

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration	

The	regulation	provides	in	pertinent	part: (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.	.	.	. (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. The	UAS	fully	

loaded	weighs	no	more	than	55	lbs.	and	is	operated	without	an	onboard	pilot.	As	such,	there	is	no	ability	or	place	to	carry	

certification	and	registration	documents	or	to	display	them	on	the	UAS. An	equivalent	level	of	safety	will	be	achieved	by	

keeping	these	documents	at	the	ground	control	point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to	them,	

to	the	extent	they	are	applicable	to	the	UAS.	

14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections.	

These	regulations	require	that	an	aircraft	operator	or	owner	“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...,”	and	others	shall	inspect	or	maintain	the	aircraft	in	compliance	with	

Part 43.	Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate,	these	sections	will	

not	apply	to	the	applicant.	Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	

handbook.	An	equivalent	level	of	safety	will	be	achieved	because	 the	UAS	is	very	limited	in	size	and	will	carry	a	small	

payload	and	 operate	 only	in	 restricted	areas	 for	a	limited	 period	 of	 time.	If	mechanical	issues	arise	 the	UAS	 can	land	

immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	The	operator	will	ensure	that	the	UAS	is	in	working	

order	prior	to	initiating	flight,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance	performed.	Moreover,	

the	operator	is	the	person	most	familiar	with	the aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	

to	 provide	 the	 equivalent	 level	 of	 safety.	 An	 equivalent	 level	 of	 safety	 will	 be	 achieved	 because	 maintenance	 and	

inspections	will	 be	 performed	in	accordance	with	 the	UAS	Manufacturer's	User	Manual.	As	 provided	in	 the	FOM,	 the	

operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight	and	perform	required	maintenance	needed.	
2179	N	Powerline	Road	Ste	1	Pompano	Beach	FL	33069

Tel	+1	786	342	9400		- Email:	info@tecnomedia.tv

Additional	Information	

The	applicant,	Edmond	J	Mueller	III	(Ted)	,	has	been	involved in	the	building	and	piloting	of	remote	controlled	aircraft	for	

more	than	10	years.	Also	the	primary	pilot,	Edmond	J	Mueller	III	(Ted),	currently	holds	a	Commercial	Pilots	Certificate	

with	Instrument	rating.	Claudio	P.	Fernandez has	an	in-depth	understanding	of	the	capabilities	and	safety	concerns	

involved	in	using	this	technology	as	an	asset	to	the	community.	Satisfaction	of	criteria	provided	in	Section	333	of	the	

Reform	Act	of	2012	provide	more	than	adequate	justification	for	the	grant	of	the	requested	exemptions	allowing	the	

commercial	operation	of	the	applicant’s	UAS.	

Sincerely, Claudio	P.	Fernandez