Ferrer Video Productions

 PO Box 363564

 San Juan, Puerto Rico 00936-3564

Page 1

Friday, July 31, 2015

U. S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

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 

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 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 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.

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.
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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• 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 training 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 and 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 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."

INTRODUCTION AND INTERESTS OF THE PETITIONER

Ferrer Video Productions is a full-service video production company offering state of the art equipment, 

professional staff and technical expertise, 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. 

We are based in San 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 2000 video projects, each different and 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 

ways 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 PRIVILEGES OF THE EXEMPTION OUTSIDE OF THE UNITED STATES, AS 

ESTABLISH IN SEC.11.83

We are 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 already know market atmosphere, to 

venture in other production facilities outside United States (as we will maintain our operational base in San Juan).
 Ferrer Video Productions

 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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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 next step will be to ask the client for an official written offer of service to 

be provided. We 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 start working for a written and/or verbal permission 

(flight permits) from country or city jurisdictions, including law enforcement, fire or other appropriate governmental 

agencies to obtain permission from the Civil Aviation Authority (CAA) before commencing a flight.

We also recognize 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 supply 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

Phone: 787-283-7309

Email: ferrervideo@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:

14 CFR Part 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 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

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)
 Ferrer Video Productions

 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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BACKGROUND

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 certified 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 control 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- 5.850GHz. 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 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 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 before 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 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.

• 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).
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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• 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 operator 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 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 file FAA Form 7711-1, or its equivalent, as modified 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 involved 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 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.

• The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as 

compared to similar 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 property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level videography/photography. Aerial photography is a valuable marketing 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 observer 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: 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. 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 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
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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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 by §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 privileges and limitations: Pilot in command

and 14 C.F.R. §61.315(a) What 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 conditions 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 to 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 maneuvers, 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 airmanship skills necessary for Ferrer Video Productions specific proposed 

operations.
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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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. 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 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 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. 
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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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 SSibs. 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."

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.
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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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....

(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 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.

A Summary The 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 time associated with
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 PO Box 363564

 San Juan, Puerto Rico 00936-3564

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additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services 

to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance 

their business 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 exemption 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. Further, 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 bodily 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. Accordingly, 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.pdf

B - DJI I1, P3 and P2 V Quadcopter Pre-Flight Checklist.pdf

C- Preflight.pdf

D- Phantom Logbook.xlsx

E- PHANTOM_Flying_Flowchart_v1.0_en.pdf