El Mexi-Cano Productions L.L.C – Section 333 Exemption Petition

September 3rd, 2015 

U. S. Department of Transportation Docket Management System 

1200 New Jersey Ave, 

SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 91.119(a)(b), 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) 

(1); 91.409(a) (2); 91.417(a)&(b); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(2); and 14 

C.F.R. 417(a)&(b) 

Attn: to whom 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, El Mexi-Cano Productions L.L.C the owner and operator of the 

DJI Phantom 2 quad-copter Unmanned Aircraft System (UAS), seeks an exemption from the Federal 

Aviation Regulations. 

(“FARs”) listed below so that El Mexi-Cano Productions L.L.C can operate our small ultra-light 

weight UAS commercially in airspace regulated by the Federal Aviation Administration (“FAA”). 

(Pilot in Charge [PIC]) and a visual observer (VO)that can perform the functions prescribed in the 

operating manual for all flights under this Exemption, if granted. 

The requested exemption would support an application for a commercial Certificate of Authorization to 

use the system to perform aerial mapping to enhance academic community awareness, augment real 

estate listing videos, filmmaking, golf course, mapping, agricultural mapping, and photogrammetry for 

various industries. 

Use of the DJI Phantom 2 UAS for aerial mapping reduces the need to operate conventional aircraft for 

the same purpose and provides very high quality imagery at a fraction of the dollar cost and danger to 

human life of using conventional aircraft. Note; the VO will not be operating the UAS. 
By approving these exemptions, the FAA will create benefits through safer survey methods by UAS, 

resulting in decreased potential for loss of life and enhanced efficiency and productivity for the affected 

activities, as well as environmental benefits, which are all ultimately in the public interest. 

Committed to safety with each flight, El Mexi-Cano Productions L.L.C 's, exemption request would 

permit operation of ultra-light weight, unmanned (piloted by remote control) and comparatively 

inexpensive UAS in tightly controlled and limited airspace. Currently, similar lightweight, remote 

controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or 

controls in place to prevent catastrophe. In addition, Douglas Trudeau (Exemption No. 11138) and 

Slugwear, Inc (Like On A Tree; Exemption No. 11157) were granted exemptions for these types of 

surveys with the DJI Phantom 2. El Mexi-Cano Productions L.L.C has created and will follow its UAS 

Flight Protocols and Controls for safe operation to avoid and prevent public hazard, as well as manned 

aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's 

specific video and photography usage as El Mexi-Cano Productions L.L.C records flight data and other 

information gained through permitted flight operations to share with the FAA through any required 

FAA reports to assist with future protocol and safety regulation. 

Granting El Mexi-Cano Productions L.L.C's request comports with the Secretary of Transportation’s 

(FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] 

in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's 

for real estate/Realtor purposes. Further, El Mexi-Cano Productions L.L.C , will conduct its own 

operations in compliance with the protocols described herein or as otherwise established by the FAA. 

For the reasons stated below, El Mexi-Cano Productions L.L.C , respectfully request the grant of an 

exemption allowing El Mexi-Cano Productions L.L.C to operate ultra-light weight, remote controlled 

UAS’s for community awareness, enhance real estate listing videos for homeowners, filmmaking, golf 

course, mapping, agricultural mapping, and photogrammetry for various industries. All of which will 

promote local economic growth through increased employment and increased tax base. Both with 

public safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses 

potential public hazard. 

I- Contact Information: 

Alexis Escarfullery Ruiz Esparza

El Mexi-Cano Productions L.L.C 

5033 Lexington Meadow Ln.

Del Valle, TX. 78617

Mobile: (512) 317-2882

Email: alexis@elmexi-cano.com
II- The Specific Sections of Title 14 of the Code of Federal Regulations From Which El MexiCano Productions L.L.C Requests Exemption are: 

14 CFR part21; 

14 CFR 45 23 (b); 

14 CFR 91, et seq; 

14 CFR 407 (a)(1) 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

III- The Extent of relief El Mexi-Cano Productions L.L.C seeks and the Reason El Mexi-Cano 

Productions L.L.C Seeks Such Relief: 

El Mexi-Cano Productions L.L.C submits this application in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent El Mexi-Cano 

Productions L.L.C contemplated commercial cinematic, academic and other flight operations within 

the national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. El 

Mexi-Cano Productions L.L.C 's, ultra-light weight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of El Mexi-Cano Productions L.L.C 's 

ultra-light weight UAS is expressly contemplated by the Reform Act. 

El Mexi-Cano Productions L.L.C would like to operate its ultra-light weight UAS prior to the time 

period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, 

providing direct experience and valuable information for formal regulation that can be administered 

uniformly to all agriculture, mapping, and real estate related UAS aerial video and photography. The 

Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our 

national airspace system. Considerations include: The weight, size, speed and overall capabilities of the 

UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the 

UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an 

exemption for El Mexi-Cano Productions L.L.C . 

El Mexi-Cano Productions L.L.C ’s UAS utilizes four (4) counter-rotating propellers for balance, 

control and stability. Weighing less than five (5) pounds (far below the maximum 55 pound limit);

including camera with gimbal. El Mexi-Cano Productions L.L.C ’s UAS is equipped with a compass, 

GPS, auto return safety technology if communication is lost between the UAS and the controller, RealTime Fight Data Display, and a No Fly Zone software default setting to force the device to abide by 

International Civil Aviation Organization regulations. 
El Mexi-Cano Productions L.L.C considers safety as foremost with each flight. El Mexi-Cano 

Productions L.L.C ’s small UAS is designed to hover in place via GPS and operate in less than a 24 

knot (15 mph) wind. For safety, stability and fear of financial loss, El Mexi-Cano Productions L.L.C 

will not fly in winds exceeding 16 kph (10 mph) nor exceed an indicated airspeed of 29 knots (15 

m/s).DJI’s “No Fly Zone”: Two classes in this mode limit the DJI Phantom 2’s ability to fly near 

restricted airport air space. Class A will not allow the UAS to take off within 1.5 miles of the GPS 

location of an airport. Class B will has incorporated an increasing height limit from 35 feet AGL at 1.5 

miles from an airport, increasing to 400 feet at 5 miles an airport. The UAS control system will also 

automatically warn the PIC when the UAS has approached within 330 feet of the 5-mile buffer zone 

around an airport. This software will also not allow the user to set GPS waypoints within 5 miles of the 

5-mileNo Fly Zone around an airport. For further details, visit http://www.dji.com/fly-safe/category-mc 

Built-in safety Real-Time Flight Data includes UAS flight height, horizontal speed, vertical speed, and 

distance from the PIC. 

Built-in safety systems include a GPS mode that allows El Mexi-Cano Productions L.L.C ’s UAS to 

hover in place when radio controls are released. With three modes to choose from, El Mexi-Cano 

Productions L.L.C will utilize the Smart Mode for aerial videography/photography. This is the safest, 

most reliable and stable mode to prevent accident and hazard. When PIC communication is lost, El 

Mexi-Cano Productions L.L.C ’s UAS is designed to slowly descend to point of take-off (Return to 

Home). El Mexi-Cano Productions L.L.C will not operate the UAS near Airports, Hospitals, nor Police 

heliports, and will not operate near areas where general public is within fifty to one hundred (50-100) 

yards depending on location, conditions and weather. El Mexi-Cano Productions L.L.C ’s PIC and VO 

will be on constant alert for any manned aircraft (Police/Medical helicopters, etc.) or other UAS, and 

prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft or 

UAS approach El Mexi-Cano Productions L.L.C 's location, or El Mexi-Cano Productions L.L.C 

suspects manned aircraft or UAS may approach near our location. El Mexi-Cano Productions L.L.C ’s 

UAS is capable of vertical and horizontal operations, and is only flown within the line of sight of both 

the PIC and VO. Utilizing battery power rather than combustible fuels, flights with El Mexi-Cano 

Productions L.L.C ’s UAS generally last between five (5) to seven minutes, with an altitude under 400 

feet. 

El Mexi-Cano Productions L.L.C will utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is nine (9) to 12 minutes as tested. El Mexi-Cano 

Productions L.L.C will not operate our UAS at or below manufacturer recommend minimum charge 

levels for operation; preferring to remain well within a safe operating range to insure adequate 

communication between radio control and UAS to eliminate potential for crash, loss of control or 

hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level 
of operation. El Mexi-Cano Productions L.L.C does not believe in taking risk that may cause a crash 

that could create hazard to the public/property/manned aircraft, and has no desire to lose an investment. 

El Mexi-Cano Productions L.L.C has clocked numerous practice flights in remote areas as a hobbyist 

simulating flights for future commercial use to gain familiarization with the characteristics of this 

specific UAS's performance under different temperature and weather conditions. El Mexi-Cano 

Productions L.L.C also practices computerized simulated flights to maintain adequate skills and 

response reflex time, for the sake of safety. El Mexi-Cano Productions L.L.C is extremely cautious 

when operating any UAS and will not “create a hazard to users of the national airspace system or the 

public.” 112 P.L. 95 § 333 (b).

Given the small size and weight of El Mexi-Cano Productions L.L.C ’s UAS, it falls well within 

Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding 

directive to integrate UAS's into the national airspace system. El Mexi-Cano Productions L.L.C UAS, 

used in hobby flight, has a demonstrable safety record and does not pose any threat to the general 

public or national security.

IV. How El Mexi-Cano Productions L.L.C ’s Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness in real estate, filmmaking, golf course, mapping, 

agricultural mapping, and photogrammetry for various industries has been around for a long time 

through manned fixed wing aircraft and helicopters. For small budget companies, farms and average 

homeowners, the expense of manned aerial videography is cost prohibitive. Only large companies can 

afford to absorb such expense, this depriving the remainder of the public from a valuable marketing a 

and mapping tool. 

V. Reasons Why El Mexi-Cano Productions L.L.C ’s Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

El Mexi-Cano Productions L.L.C ’s exemption will not adversely affect safety. Quite the contrary, for 

the reasons stated, permitting El Mexi-Cano Productions L.L.C to log more flight time in FAA 

controlled airspace, with communication with the FAA, will allow us to contribute to the innovation 

and implementation of new and novel techniques for realtors, filmmaking, golf courses, agricultural 

mapping, and photogrammetry for various industries as well as continuing to educate the public 

through publishing articles. In addition, El Mexi-Cano Productions L.L.C submits the following 

representations of enhancements to current aerial videography and photography for real estate, 

filmmaking, golf courses, agricultural mapping, and photogrammetry for various industries: 

El Mexi-Cano Productions L.L.C ’s UAS weighs less than 5 pounds complete with a small ultra-light 

weight high quality GoPro 4 Black camera or Ricoh Theta ultra light camera; El Mexi-Cano 

Productions L.L.C will only operate this UAS below 400 feet, as recommended by the FAA 
Modernization and Reform Act of 2012; El Mexi-Cano Productions L.L.C ’s UAS will only operate for 

10 minutes per flight; El Mexi-Cano Productions L.L.C will land this UAS prior to manufacturer 

recommended minimum level of battery power, 30% battery power remaining. Also, El Mexi-Cano 

Productions L.L.C ’s UAS has an automated function which results in immediate landing when a low 

battery is detected; El Mexi-Cano Productions L.L.C will pilot this UAS through remote control by line 

of sight; El Mexi-Cano Productions L.L.C s UAS has GPS-controlled autopilot system to maintain 

UAS stability and control, El Mexi-Cano Productions L.L.C 's UAS has an Auto Return-to-Home & 

Landing function to increase safe return of the UAS to the ground, A pre-programmed flight safety 

feature whereby El Mexi-Cano Productions L.L.C ’s UAS automatically hovers and then slowly lands 

if communication with the remote control pilot is lost; El Mexi-Cano Productions L.L.C will actively 

analyze flight data and other sources of information to constant update and enhance safety protocols; El 

Mexi-Cano Productions L.L.C will only operates in reasonably safe environments that are strictly 

controlled and are away from: power lines, elevated lights, airports and actively populated areas; El 

Mexi-Cano Productions L.L.C will conduct extensive pre-flight inspections and protocol review, 

during which safety carries primary importance; Any maintenance or alterations of El Mexi-Cano 

Productions L.L.C ’s UAS that could affect operation or flight characteristics will require a functional 

test flight before returning to work; El Mexi-Cano Productions L.L.C will always obtain all necessary 

permissions prior to operation, Including issuing a notice to airmen(NOTAM)prior to operations; and, 

El Mexi-Cano Productions L.L.C will have procedures in place to abort flights in the event of safety 

breaches or potential danger.

In recognition of the FAA’s Exemption No. 11062, and specifically Exemption No. 11138 for the 

same UAS model (DJI Phantom 2); prior to conducting operations for the purpose of aerial 

photography/videography, El Mexi-Cano Productions L.L.C ’s PIC will have accumulated 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours as a UAS pilot with a multi-rotor UAS. 

Prior to operations, El Mexi-Cano Productions L.L.C ’s PIC must also have accumulated a minimum of 

5 hours as a UAS pilot operation the DJI Phantom 2. In addition to the hour requirements, the PIC must 

accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes). El Mexi-Cano 

Productions L.L.C ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It 

is important to note that absent the integration of commercial UAS into our national airspace system, 

helicopters are the primary means of aerial video and photography for community awareness and real 

estate. While the safety record of such helicopters is astounding, there has been local incidents 

involving loss of life as well as extensive property damage; it is far safer to operate a battery powered 

ultra-light weight UAS. 

First, the potential loss of life is diminished because UAS's carry no people on board and El Mexi-Cano 

Productions L.L.C will only operate its UAS in specific areas away from mass populations. 
Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished. 

Third, the small size and extreme maneuverability of El Mexi-Cano Productions L.L.C ’s UAS allow 

the PIC to remotely pilot away from and avoid hazards quickly and safely . Lastly, given its small size 

and weight, even when close enough to capture amazing images, El Mexi-Cano Productions L.L.C ’s 

UAS need not be so close to the objects they are focused on through the technology and use of post 

editing software allowing pan and zoom. Accordingly, El Mexi-Cano Productions L.L.C ’s UAS has 

been experimentally operated for familiarization/competency and will continue to operate at and above 

current safety levels. Furthermore, El Mexi-Cano Productions L.L.C ’s PIC has accumulated 25 hours 

of total time as a UAS multi-rotor pilot. El Mexi-Cano Productions L.L.C ’s PIC has also accumulated 

more than 5 hours as a UAS pilot operation the DJI Phantom 2. 

VI A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.14 C.F.R. Part 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational 

area of El Mexi-Cano Productions L.L.C ’s UAS permits exemption from Part 21 because El MexiCano Productions L.L.C ’s UAS meets (and exceeds) an equivalent level of safety pursuant to Section 

333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. El Mexi-Cano Productions L.L.C ’s current UAS meets or exceeds each of the 

elements. 

14 C.F.R. 91.7(a) 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. 

However, El Mexi-Cano Productions L.L.C ’s PIC will still ensure that the UAS is in an airworthy 

condition based on compliance with the operating documents prior to every flight. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots 

or passengers, and given the size of the UAS, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a safety/flight manual delineating areas where safety can be 

defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,10602, 10700 and 32827. However, El Mexi-Cano 

Productions L.L.C ’s UAS operations manual will be kept in a location accessible by El Mexi-Cano 

Productions L.L.C ’s PIC. 
14 C.F.R. § 91.103 regarding preflight action. El Mexi-Cano Productions L.L.C ’s PIC will take certain 

actions before flight to ensure safety of the flight. These will include reviewing weather, flight battery 

requirements, landings, and takeoff distances and aircraft performance data before initiation of the 

flight. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as El Mexi-Cano Productions 

L.L.C ’s UAS utilizes electronic GPS with a barometric sensor. According to the manufacturer of El 

Mexi-Cano Productions L.L.C ’s UAS, the GPS sensor is accurate to 2.6 feet Vertical and 8.2 feet 

Horizontal. These accuracies are adequate for El Mexi-Cano Productions L.L.C to safely operate the 

UAS for its exempted purposes. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. 

They are inapplicable for the same reasons described above. The equivalent level of safety will be 

achieved by maintaining any such required certifications and registrations by El Mexi-Cano 

Productions L.L.C in a location accessible by El Mexi-Cano Productions L.L.C ’s PIC. 

B. 14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. El Mexi-Cano Productions L.L.C ’s UAS, by definition, is unmanned. Therefore the 

UAS does not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal 

lettering requirement. The FAA has previously issued exemptions to this regulation through 

Exemptions Nos. 8738, 10167, 10167A and 10700.C. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119(a) and (b) prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. El Mexi-Cano Productions L.L.C ’s 

UAS will never operate at an altitude greater than 400 AGL; safely within the standard 400 AGL as 

recommended by the FAA Modernization and Reform Act of 2012. El Mexi-Cano Productions L.L.C 

will however operate its UAS in safe areas away from areas depicted in “yellow” on VFR charts, 

providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. El 

Mexi-Cano Productions L.L.C will conduct all operations under El Mexi-Cano Productions L.L.C ’s 

Protocols and Controls , including posting a warning sign reading: “Attention Aerial Photography in 

Progress – Remain Back 150 Feet”. El Mexi-Cano Productions L.L.C will operate its UAS in 

accordance with Exemption No. 11109, which may require the UAS be operated closer than 500 feet to 

essential persons. Non-participating persons must remain at appropriate distances (500 feet) from the 

UAS, and if they need to be closer than 500 feet, non-participating persons will remain behind barriers 

or structures that can sufficiently protect them from the UAS debris in the event of an accident. Given 

the size, weight, maneuverability and speed of El Mexi-Cano Productions L.L.C ’s UAS, an equivalent 

or higher level of safety will be achieved.
D. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 

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. . .” 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, 

apply to El Mexi-Cano Productions L.L.C ’s UAS. However, as a safety precaution El Mexi-Cano 

Productions L.L.C ’s PIC and VO will inspect El Mexi-Cano Productions L.L.C ’s UAS before and 

after each flight. 

A Summary the FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1).The size, weight and enclosed operational 

area of El Mexi-Cano Productions L.L.C ’s UAS permits exemption from Part 21 because El MexiCano Productions L.L.C ’s UAS meets an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement 

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. El Mexi-Cano Productions L.L.C ’s UAS meets or exceeds each of the elements. 14 

C.F.R. 91.7(a) 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 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance 

program that involves regular software updates and curative measures for any damaged hardware. 

Therefore, an equivalent level of safety will be achieved. 

In summary, El Mexi-Cano Productions L.L.C seeks an exemption from the following 

Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 

14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119 (a)(b); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. 

§ 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially 
operate El Mexi-Cano Productions L.L.C ’s small unmanned vehicle/lightweight unmanned aircraft 

vehicle in community awareness, real estate operations, filmmaking, golf course mapping, agricultural 

mapping, and photogrammetry for various industries and to develop economic platforms for real estate 

and golf courses. Currently, area awareness, filmmaking, real estate aerial videography/photography, 

golf course mapping, agricultural mapping, and photogrammetry for various industries relies primarily 

on the use of larger aircraft running on combustible fuel, posing potential risk to the public. Granting El 

Mexi-Cano Productions L.L.C ’s request for exemption will reduce current risk levels and thereby 

enhance safety. El Mexi-Cano Productions L.L.C ’s UAS craft does not contain potentially explosive 

fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic 

aircraft with much less flight time. Further, El Mexi-Cano Productions L.L.C will operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and from established air 

fields. El Mexi-Cano Productions L.L.C has been informally analyzing flight information and will 

compile safety protocols and the implementation of a flight operations manual for real estate usage that 

exceeds currently accepted means and methods for safe flight. Formal collection of information shared 

with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the 

FAA Modernization and Reform Act of 2012. 

There are no personnel on board El Mexi-Cano Productions L.L.C ’s UAS and therefore the likelihood 

of death or serious bodily injury is significantly diminished. El Mexi-Cano Productions L.L.C ’s 

operation of its UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas 

will provide an equivalent level of safety as that achieved under current FARs. Accordingly, El MexiCano Productions L.L.C respectfully request that the FAA grant El Mexi-Cano Productions L.L.C ’s 

exemption request and El Mexi-Cano Productions L.L.C is willing to cooperate in sharing information 

to benefit the FAA, safety of manned aircraft, and the general public at large. 

Respectfully submitted 

Alexis Escarfullery Ruiz Esparza

El Mexi-Cano Productions L.L.C 

5033 Lexington Meadow Ln.

Del Valle, TX. 78617

Mobile: (512) 317-2882

Email: alexis@elmexi-cano.com