# Ferrer Video Productions PO B ox 363564 S a n Juan, Puerto Rico 00936

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### Page 1 Friday, July 31, 2015 U. S. Department of Transportation, Docket Operations We st Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Wa shington, DC 20590

Re: **Exemption Request Section 333 of the FA A**  **Reform A ct of the Federal A**  **viation Regulati ons from**  **14 CFR 21 subpart H; 14 CFR 45.23(b);**  **14 CFR 61.101(e)(4) & (e)(5),**  **14 CFR 61.113(a),**  **14 CFR 61.315(a)**  **; 14 CFR 91.7(a); 14 CFR91.9(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); also request to exercise the privileges of**  **a exemption outside of the United**  **States, Sec.11.83** Dear Sir or Madam: In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I Francisco R. Ferrer , owner of Ferrer Video Production referred to hereafter as the petitioner, request exemption from the following sections of Title 1 4, Code of Federal Regula tions §§ **14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.101(e)(4) & (e)(5),**  **14 CFR 61.113(a),**  **14 CFR 61.315(a)**  **; 14 CFR 91.7(a); 14 CFR91.9(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 C**  **FR 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);**  **also request to exercise the privileges of a exemption outside of the United States, Sec.11.83**  In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems

. S o 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, engin eering 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.

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### Page 2 • Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

• The ability to offer t raining to Ferrer Video Productions employees 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 an d property

. 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 op erations 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 o peration of such aircraft systems in the national airspace system."

**INTRODUCTION A ND INTERESTS OF THE PETITIONER**  Ferrer Video Productions is a full

- service video production company offering state of the art equipment, professional staff a nd technical ex pertise, for the production of social events, corporation presentations, and advertising agencies and their clients in a wide variety of industries. Our goal is to create educational; fun; emotional; breathtaking films for our clients. Weare based in Sa n Juan, Puerto Rico, and specialize in offering our services to U.S. continental and international clients who visit and do business in Puerto Rico. Serving this market area for the past 15 years, we had film more than 2 000 video projects, each different a nd unique, and each successfully meeting our clients goals. As member of the Puerto Rico Convention Bureau, the Association of Bridal Consultants (ABC

- USA) , and also, been a part of the prefer vendor of an elite group of locals hotels, we are continuously asked for the latest wa ys to provide and produce the results they (our clients) are looking for. And with the new tools and technologies coming up, we feel enthusiastic and inspired as ever! Ferrer Video Productions will utilize the DJI Phantom 3 Advance to commercially provide professional aerial photography, video, cinematography, inspection to our clients. Use of the DJI Phantom 3 Advance will provide Ferrer Video Productions a safe and efficient platform to perform its business operations. **SEEKING TO EXERCISE THE PRIVILE**  **GES OF THE**  **EXEMPTION OUTSIDE OF THE UNITED STA**  **TES, A S**  **ESTA BLISH IN SEC.11.**  **83** Weare always cautious about the security of intellectual property and had built our reputation on reliable confidentiality. A good reputation produces favorable references. The proprietary nature of so many of our projects had created a word

- of

- mouth consumer's interest for our company's services. Clients that had been satisfied with our work have been offering us to continue filming services in their cities and countries of origin. This soliciting of our services, in addition to the ones of Puerto Rico residents (locals) clients, made us begin to think about the wisdom of continuing to operate in the alre ady know market atmosphere, to venture in other produ ction facilities outside United States (as we will maintain our operational base in San Juan).

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### Page 3 We recognize that in generally, non

- citizens of some countries must apply for a work permit in order to work in. Once we’ve received an offer of work, our ne xt step will be to ask the client for an official written offer of service to be provided. W e recognize that a foreign country still may not allow us to operate in that country without meeting the ICAO standard. As our clients complies with final contract documents, we will s t art working for a written and/or verbal permission (f light permits) from count ry or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies to obtain permission from the Civil Aviation Author i ty (CAA) before commencing a flight

. Wealso rec o gnize that for the majority of one

- off permit applications, we may require a PDF copy of the following:

- Aircraft Certificate of Registration

- Aircraft Certificate of Airworthiness (If restricted please sup ply details)

- Insurance Certificate showing worldwide coverage or country specific coverage

- Pilot License and Medical **The name and address of the applicant is: Ferrer Video Productions**  Attn: Francisco R. Ferrer/owner Ph one : 787

- 283

- 7309 Email: ferrerv ideo@yahoo.com Postal Address: PO Box 363564 San Juan,PR 00936

- 3564 Office Address: A

- 37 Park Gardens, Rio Piedras, PR 00926 **Regulations from which the exemption is requested:**
1 4 CFR Part 2 1 subpart H 1 4 CFR 45.23 (b) 14 CFR 61.101(e) (4) & (e)(5) 14 CFR 6 1.1 1 3 (a) 14 CFR 61.315(a) 1 4 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.1 1 9 (c) 1 4 CFR 91. 1 21 14CFR91.151 (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)

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### Page 4 **BA C**  **KGROUND** Ferrer Video Productions will operate the PHANTOM 3, Model ADVANCE

. The DJI Phantom 3 is a highly effective consumer grade small rotorcraft in the quad copter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum limb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certif ied radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and co ntrol camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 15 minutes. The Phantom 3 will be controlled with the C I remote controller with an operating frequency of 2.400GHz

- 2.483GHz. The live video feed will have an operating frequency of 5.728GHz

- 5.850G Hz. The applicant will operate the UAS in line of sight within a closed off and predetermined area owned and/ operated by the property representative. More information is available at http://www.dji.com/product/phantom

- 3/download 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 opera tions 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. **AI RCRA**  **FT AN**  **D EQUIVA LENT LEVEL OF SA**  **FETY** The petitioner has reviewed FAA exemptions reference’s 1

- 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections befo re each flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safety standards and regulations



### . 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 conductin g 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. • The UAS will have a maximum operating speed of no more than 50mph

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

.

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### Page 5 • Maximum flight time for each operational flight will be 30 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 Second or higher Class Medical Certificate. If the PIC feels another operato r to be qualified with the necessary skills to be PIC & possess a Commercial Pilot's License along with a Second 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 (VMC) only. • The flights will o ccur 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 co ntrolled 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 file FAA Form 7711

- 1, or its equivalent, as mo dif ied in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. • The operator will obtain verbal/written consent of all persons involve d with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the approved

. • The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particul ar UAS to be operated. • The PIC and VO will be able to communicate by voice, radio, and/or text at all times.
• W ritten and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcemen t, 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 autonomousl y. • The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

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### Page 6 **Public interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to simi lar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for prope rty owners or their designees seeking an enhanced perspective for characteristics, amenities, and benef its of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable market ing tool that can lead to increased commerce and enhance personal photography. This will increase Puerto Rico's tourism revenue and aid the state and local economies on a more environmentally friendly, more economic, and a safer basis

. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic/video data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observe r will be utilized. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means or other means as required



### . **Specific Exemptions Requested 14 C.F.R. Part 21, Subpart H: A** **irw orthiness Certificates 14 C.F.R. §91.203 (a) (1)**  Subpart H, entitled Airworthiness Cert if icates, 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 P art 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 o perated 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 th e 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 desi gnated 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. The FAA will have advance notice of all operations. 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 sa me 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 externa l load. **14 C.F.R. § 45.23 (b).** Marking of the Aircraft The regulation requires: Wh en 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 provi sionally 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

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### Page 7 more than 6 inches high, the words "limited," "restricted," "lightsport," "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 b y §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental." **14 C.F.R. § 61.101(e)(4) & (e)(5),**  Recreational pilot privileges and limitations **14 C.F.R. § 61.113(a),**  Private pilot privilege s and limitations: Pilot in command **and 14 C.F.R. §**  **61.315(a)** Wh at are the privileges and limits of my sport pilot certificate Relief from Sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges and limitations; Section 61.113(a), entitled Private pilot privileges and limitations: Pilot in command; and Section 61.315(a), entitled What are the privileges and limits of my sport pilot certificate, is requested to the extent necessary to allow a PIC holding a sport pilot, recreational 16 pilot, or private pilot certificate, as well as an airman medical certificate or U.S. issued driver’s license, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire, subject to the co nditions and limitations below. This relief is requested since the limitations set forth in Sections 61.101(e)(4) & (e)(5) state that no person who holds a recreational pilot certificate may act as pilot in command of an aircraft for compensation or hire or in furtherance of a business. Relief is requested from 61.113(a) since the limitations set forth in that section state that no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. Relief is requested from 61.315(a) since the limitations set forth in that section only allow a person who holds a sport pilot certificate t o act as pilot in command of a light

- sport aircraft. As set forth more fully below, Ferrer Video Productions submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Advance UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate the DJI Phantom 3 Advance UAS in a manner consistent with the operations specifications as set forth herein, including evasive and emergency man euvers, as well as maintaining appropriate distances from people, vessels, vehicles, and structures. Further, Ferrer Video Productions submits that the additional airmanship experience of a commercially certified pilot would not correlate to the airmanshi p skills necessary for Ferrer Video Productions specific proposed operations

.

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### Page 8 **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 stan dard 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 Fli ght Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane o r Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size a nd 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 main tained 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. Flight control is accomplished through t he 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. T he equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft along with the size and speed of the aircraft used. **14 C.F.R. §91.119:** Minimum Safe Altitudes. Section 91.119 establishes safe altit udes 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 thi s 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 abo ve the highest point on the structure.

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### Page 9 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 ach ieved 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 th e f ilming 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 SSibs. proposed herein and the lack of flammable fuel, any risk assoc iated 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 t he 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 ope rator, 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) D uring the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §9 1.151, 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 twilig ht 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 minut es 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.

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### Page 10 **14 C.F.R. §91.203 (a) and (b):** Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Exce pt 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.... (2) 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 flyi ng 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 w ill 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.
**A Summary** 

**T he FAA** 

**May Publish in**  **the Federal Register:** In summary, Ferrer Video Productions seeks an exemption from the following Regulations of Title 14, Code of Federal Regulations §§ 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.101(e)(4) & (e)(5), 14 CFR 61.113(a), 14 CFR 61.315(a) ; 14 CFR 91.7(a); 14 CFR91.9(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); also request to exercise the privileges of a exemption outside of the United States, Sec.11.83 The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, videography, inspections and other flight operations”. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround tim e associated with

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### Page 11 additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services t o individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their bus iness or hobby. Currently, area awareness and commercial aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting Ferrer Video Productions' , request for exemp tion will reduce current risk levels and thereby enhance safety. Its UAS does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional commercial video and photographic aircraft with much less flight time. Furt her, it is operated at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. There is no personnel on board Ferrer Video Productions' UAS and therefore the likelihood of death or serious bod ily injury is significantly diminished. Ferrer Video Productions’ operation of its UAS, weighing less than 5 pounds and traveling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordi ngly, Ferrer Video Productions respectfully request that the FAA grant it’s exemption requested and it is willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted

Date: Friday, July 31, 2015 Francisco R. Ferrer, Owner **Ferrer Video Productions** PO Box 363564 San Juan, PR 00936

- 3564 Line Phone: 787

- 283

- 7309 Cellular.787

- 642

- 5427 email: ferrervideo@yahoo.com
Appendices: A

- Phantom_3_Advanced_User_Manual_v1.2_en.pd f B

- DJI I1, P3 and P2 V Quadcopter Pre

- Flight Checklist.pdf C

- 

### P reflight.pdf D

- Phantom Logbook.xlsx E

- PHANTOM_Flying_Flowchart_v1.0_en.pdf