1 | Page UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETI TION FOR EXEMPTION OF: RUDY CASTILLO III

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF F EDERAL REGULATIONS SECTIONS 61.113(a) & ( b), 91.7(a), 91.121, 91.151(b), 91.405(a) , 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIA L OPERATION OF ZERO 1600 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on March 15, 2016

Rudy Castillo III 5202 Ferrington Dr San Antonio, TX 78223 210-334-8709 Rudycastillo.amg@gmail.com2 | Page TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS.................................................. ...................................................3

SUMMARY........................................................

............................................................... ..4

INTRODUCTION AND INTERES TS OF PETITIONER....................... ..........................4

BACKGROUND....................................................... .........................................................5

BASIS FOR PETITION.......................................................

............................................................... .....5

NAME AND ADDRESS OF PETITIONER................................. .....................................7 THE SPECIFIC SECTIONS OF 14 C.F. R. FROM WHICH RUDY CASTILLO III SEEKS EXEMPTION................................................ .........................................................8 THE EXTENT OF RELIEF RUDY CASTILLO III SEEKS AND THE REASON RUD Y CASTILLO III SEEKS THE RELIEF ..................................... .......................................11 THE REASONS WHY GRANTING RUDY CA STILLO III’S REQUEST WOULD BE IN THE PUBLIC INTEREST .......................................... ...............................................14 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.................................................. ..........................................................17 CONCLUSION..................................................... .............................................................303 | Page GLOSSARY OF ABBREVIATIONS AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Avi ation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernizati on and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Ai rcraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 | Page SUMMARY Rudy Castillo III seeks exemption f rom the requirements of 14 C .F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to opera te an Unmanned Aircraft Sy stem pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). Thi s exemption will permit Rudy Castillo to operate a n Unmanned Aircraft System (UA S) for the commercial purpose of conducting public and/o r private aerial video and ph otography of to be used in television/cinematography, public o r private events, real estat e, architecture, land surveying, inspection of residenti al and commercial structures.

INTRODUCTION AND INTERESTS OF THE PETITIONER My name is Rudy Castillo III, I am 34 years old. My areas of i nterests include amateur radio flying, photogra phy and video editing with Adobe Design software’s. I offer professional services in m edia and graphic designs for bu sinesses looking to

advertise. The objective of Rudy Castillo III’s Video and Photography Serv ices is to provide high quality imaging for a variet y of commercial and public use s, specifically targeting:

 Video Imaging for Real Estate properties

 Inspection of commercial or residential structures

 Landscape aerial imaging

 Video for News and Traffic reporting

 Coverage of Sporting events5 | Page BACKGROUND

Unmanned Aircraft S ystems: Zero 1600 UAS Rudy Castillo III seeks an exemption to operate Zero 1600 syste m for compensation or hire within the NAS. The Zero 1600 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) w ith a Ground Control Station (GC S) utilizing electronic tablet or smart phone systems. The Zero 1600 has a m aximum gross weight of approximately 2.65 pounds, while having a length of 14 inches w idth of 14 inches, height of 7 inches, and a maximum speed of approximately 8 meters a se cond or 16 knots. The Zero 1600 UAS is equipped with four main rotors; drive n by Lithium Polymer battery powered electric motors.

The Zero 1600 UAS that will be operated by Rudy Castillo III wi ll be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION Petitioner, Rudy Castillo III, pursuant to the provisions of th e Federal Aviation Regulations (14 C.F.R. § 11.61) and t he FAA Modernization and R eform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to c ommercially operate the Zero 16 00 UAS in the National Airspace System (NAS), and for an exemption from the requiremen ts of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, w eight, size, and limited operat ing area associated

with the unmanned aircraft a nd its operation, Rudy Castillo III operation of Zero 1600

UAS meets the conditions of FMR A Section 333 and therefore, wil l not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.6 | Page Accordingly, Rudy Castillo III reque sts relief from Sections 91 .405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2 ), and 91.417(a) & (b), as th ese sections set forth requirements for maintenance th at only apply to aircraft with a n airworthiness certificate. Rudy Castillo III submits that the requested relief is proper s ince an equivalent level of safety will be ensure d. Rudy Castillo III will use exp erienced personnel or technicians to perform maintena nce, alterations, or preventive maintenance on the UAS using the methods, techniques, a nd practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and Zer o 1600’s Instruction Manual). F urthermore, Rudy

Castillo III will document and mai ntain all maintenance records for the Zero 1600 UAS. Relief from certain requireme nts of Section 61.113(a) and (b), entitled Private pilot privileges and limita tions: Pilot in command , is requested by Rudy Castillo III to the extent necessary to allow aPilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, an d who has demonstrated, by meeting minimum flight- hour and c urrency requirements, that th e PIC is able to safely operate the Zero 1600 UAS in a manne r consistent with this exem ption, including evasive and emergency maneuvers and maintaining appropriate distances f rom people, vessels,

vehicles and structures. Rudy Castillo III seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the Zero 1600 UAS do not require an airworthiness cer tificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, Rudy Cas tillo III submits that he will ensure that the Zero 1600 UAS are in an airworthy conditio n, prior to every flight, by determining that the UAS are i n compliance with the operating d ocuments (i.e., Monthly Maintenance Log, and Zero 1600 Instr uction Manual), and that th e aircraft are in a condition for safe flight. Rudy Castillo III also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Zero 1600 UAS wi ll not have a typical barometric altimeter onboard. However, altitude information of the Zero 1600 UAS will7 | Page be provided to the PIC via Global Positioning System (GPS) equi pment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. T his altitude information, combi ned with Rudy Castillo III’s operation of the Zero 1600 UAS within visual line of sigh t, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121

. Additionally, Rudy Casti llo III seeks an exemption from the req uirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Rudy Castillo III submits that safety will not be affected by operation of th e Zero 1600 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of i ntended landing and, assuming no rmal cruising speed, to fly

after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Rudy Castillo III provide s the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Pe titioner and point of contact is: Rudy Castillo III 5202 Ferrington Drive San Antonio, TX 78223 210-334-8709 Email: rudycastillo.amg@gmail.com8 | Page B. The Specific Sections Of 14 C .F.R. From Which Rudy Castillo III Seeks Exemption. 1. Rudy Castillo III Seeks Exempt ion From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitatio ns: Pilot in command , subsections (a) and (b) prescr ibe the following, in relevant pa rt: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property fo r compensation or hire; nor may that person, for c ompensation or hire, act as PIC of an aircraft. (b) A private pilot may, for co mpensation or hire, act as PIC o f an aircraft in connection with any business or employment if— (1) The flight is only incident al to that business or employmen t; and (2) The aircraft does not carry p assengers or property for comp ensation or

hire. 2. Rudy Castillo III Seeks Exemptio n From The Requirements Of S ection 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civ il aircraft unless it is in an a irworthy condition. 3. Rudy Castillo III Seeks Exemptio n From The Requirements Of Sect ion 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), st ates the following, in part: (a) Each person operating an aircr aft shall mainta in the cruisi ng altitude or flight level of that aircraft, as th e case may be, by reference to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altim eter setting of a station along t he route and within 100 nautical miles of the aircraft; (ii) If there is no station withi n the area prescribed in parag raph (a)(1)(i) of this section, the current reported altimeter setting of an appr opriate available station; or (iii) In the case of an aircraf t not equipped with a radio, the elevation of the departure airport or an appr opriate altimeter setting avail able before departure. 4. Rudy Castillo III Seeks Exemptio n From The Requirements Of Sect ion 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions ,9 | Page subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather c onditions) there is enough fuel to fly to the first point of intended landi ng and, assuming normal cruising speed, to fly after that for at least 20 minutes. 5. Rudy Castillo III Seeks Exemptio n From The Requirement Of Secti on 91.405(a). Section 91.405, entitled Maintenance required , subsection (a) , states the following: Each owner or operator of an aircraft— (a) Shall have that aircraft i nspected as prescribed in subpart E of this part and shall between required inspecti ons, except as provided in parag raph (c) of this section, have discrepancies repa ired as prescribed in part 43 o f this chapter[.] 6. Rudy Castillo III Seeks Exemptio n From The Requirements Of S ection 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any air craft that has undergone maint enance, preventive maintenance, rebuild ing, or altera tion unless-- (1) It has been approved for return to service by a person auth orized under § 43.7 of this chapter[.] 7. Rudy Castillo III Seeks Exemptio n From The Requirements Of S ections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragr aph (c) of thi s section, no per son may operate an aircraft unless, within the preced ing 12 calendar months, it ha s had -- (1) An annual inspection in acco rdance with part 43 of this cha pter and has been approved for return to s ervice by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issu ance of an airworthiness certific ate in accordance with part 21 of this chapter. 8. Rudy Castillo III Seeks Exemptio n From The Requirements Of S ections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator sha ll keep the following records f or the periods specified in paragraph ( b) of this section: (1) Records of the maintenance , preventive maintenance, and alt eration and records of the 100-hour, annual , progressive, and other require d or10 | Page approved inspections, as appropria te, for each aircraft (includ ing the airframe) and each engine, propell er, rotor, and appliance of a n aircraft. The records must include-- (i) A description (or reference to data acceptable to the Admin istrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certi ficate number of the person appro ving the aircraft for ret urn to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, eac h propeller, and each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last ove rhaul of all items installed on th e aircraft which are required to be overhauled on aspecified time basis. (iv) The current inspection statu s of the aircraft, including t he time since the last inspection required by t he inspection program under wh ich the aircraft and its applia nces are maintained. (v) The current status of applic able airworthiness directives ( AD) and safety directives including, for each, the method of compliance , the AD or safety directive number and revisi on date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms pres cribed by § 43.9(d) of this chapte r for each major alteration to the airframe and currently installed engine s, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records fo r the periods prescribed: (1) The records specified in pa ragraph (a)(1) of this section s hall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in pa ragraph (a)(2) of this section s hall be retained and transferred with the aircraft at the time the aircraft is s old. (3) A list of defects furnishe d to a registered owner or operat or under § 43.11 of this chapter shall be retai ned until the defects are repaire d and the aircraft is approved for return to service. C. The Extent Of Relief Rudy Cas tillo III Seeks And The Reason Rudy Castillo III Seeks The Relief. 1. Extent Of Relief Rudy Castillo III Seeks And The Reason Rudy Castillo III Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113( a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent n ecessary to allow a PIC holding a private pilot or higher level certificate, as well as a curre nt and valid airman medical11 | Page certificate, and who has met certa in flight-hour and currency r equirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Sec tion 61.113(a) and (b) state that a private pilot may, for compensation or hire, act a s PIC of an aircraft in connection with any business or emp loyment if: (1) The flight i s only incidental to that business or employment; and (2) The aircraft does not carry pas sengers or property for compensation or hire. As set forth more fully below , Rudy Castillo III submits that a n equivalent level of safety will be maintained becau se no PIC will be allowed to operate the Zero 1600

UAS unless that PIC has met certa in flight-hour and currency re quirements, demonstrating that the PIC is a ble to safely operate either the Zero 1600 UAS in a manner consistent with the operations specifications as describ ed in this exemption, including evasive and emergency maneuvers, as well as maintaini ng appropriate distances from people, vessels , vehicles and s tructures. Further, Rudy Castillo III submits that all flights of the Zero 1600, conducted by the PIC pursuant to the grant of this Petition: (1) will be inc idental to Rudy C astillo III's business; and (2) will not carry passengers or property for com pensation or hire. 2. Extent Of Relief Rudy Castillo III Seeks And The Reason Rudy Castillo III Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow R udy Castillo III to determine tha t the Zero 1600 are in airworthy condition p rior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., th e Rudy Castillo III Aerial Ope rations Manual, Monthly Maintenance Log, and Zero 1600 Instruction Manual). Rudy Castillo III seeks the requested relief because the Zero 1 600 do not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Rudy Castillo III will ensure that the Zero 1600 UAS is in airw orthy condition based12 | Page upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and Zero 1600 Instruction Manual) prior to every flight, and furthe r, determine that the

aircraft are in condition for safe flight, as stated in the con ditions and limitations below. 3. Extent Of Relief Rudy Castillo III Seeks And The Reason Rudy Castillo III Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operation of the Zero 1600 UAS, which utilize a barometr ic pressure sensor, GPS equipment, and a radio communica tions telemetry data link to do wnlink altitude

information from the UA to the P IC at the ground control statio n (GCS). Since the FAA requires that any altitude inf ormation concerning UAS operation s be reported to air traffic control (ATC) in feet above ground level (AGL), Rudy Ca stillo III seeks the requested relief because the Zero 1600 UA altimeter may be set on the ground to zero feet AGL, rather than the local b arometric pressure or field al titude, before each flight. Considering the limited altit ude of the proposed operations, re lief from 14 CFR 91.121 is sought to the extent neces sary to comply with the app licable conditions and

limitations stated below. As more fully set forth herein, an eq uivalent level of safety will

be maintained since the Zer o 1600 UA is equipped with a baromet ric pressure sensor and GPS equipment, which automati cally ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with alt itude information of the UA on the heads-up display of the GCS. 4. Extent Of Relief Rudy Castillo III Seeks And The Reason Rudy Castillo III Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entit led Fuel requirements for fl ight in VFR conditions, is requested to the e xtent required to allow flight s of the battery powered Zero 1600 UA during daylight hours in visual meteorological conditio ns (VMC), under visual flight rules (VFR), for a tot al duration of 13.5 minutes to the first point of intended landing and, assuming normal crui sing speed, to fly after that for at least 4.5 minutes. Rudy Castillo III seeks the request ed relief because without anexemption from Section13 | Page 91.151(b), the flight time durati on of the battery powered Zero 1600 UA will severely constrain the practicality of a ny aerial video or still photo f light operations that Rudy Castillo III proposes to conduc t pursuant to this Petition. Significantly, as set forth below , the technical specifications of the Zero 1600 UA, the Zero 1600 UA operating docum ents, and Rudy Castillo III’s p roposed operating limitations, ensure that Rudy Castillo III will safely operate the battery powered Zero 1600 UA during daylight hours in visual meteorological conditio ns (VMC), under visual flight rules (VFR), with enough ba ttery power to fly for a tota l duration of 13.5 minutes to the first point of intende d landing and, assuming normal cru ising speed, to fly after that

for at least 4.5 minutes. 5. Extent Of Relief Rudy Castillo III Seeks And The Reason Rudy Castillo III Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with a n airworthiness certificate, R udy Castillo III requests

relief from these Sections because the Zero 1600 UA does not re quire airworthiness

certificates. As set forth mor e fully below, the Zero 1600 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certifi cate. Accordingly, Rudy

Castillo III will use trained technicians to perform maintenanc e, alterations, or preventive maintenance on the UAS using the methods, techniques, and pract ices prescribed in the UAS operating documents (i.e., the Rudy Castillo III Aerial Ope rations Manual, Monthly Maintenance Log, and Zero 1600 Instr uction Manual). Furthermore , Rudy Castillo III

will document and maintain all maintenance records for the Zero 1600.

D. The Reasons Why Granting Rud y Castillo III Request Would Be In The Public Interest; That Is, How It Would B enefit The Public As A Whole.

Granting the present Petition wil l further the public interest by allowing Rudy Castillo III to safely, efficien tly, and economically perform a erial video and photography14 | Page of construction sites, real esta te, and landscape over certain areas of the United States. Additionally, use of the Zero 1600 UAS will decrease congestion of the NAS, reduce pollution, and provide signi ficant benefits to the econo my. Notably, the benefits of Rudy Castillo III’s propose d operation of the Zero 1600 UAS will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS

. The Zero 1600 UA is battery power ed and serve as a safe, effici ent, and economical alternative to the manned aircraft traditionally uti lized to obtain aerial imagery. By reducing the amount of manned aircraft needed to pe rform aerial acquisitions, an exemption allowing the use of a Zero 1600 UAS would reduce the

amount of manned aircraft in the NAS, reduce noise and air poll ution, as well as increase the safety of life and proper ty in the air and on the ground. Furthermore, by reducing the number of manned aircraft operatin g in the NAS, congestion around airports cause d by arriving and departing air craft will be reduced. The Zero 1600 UA does not require an a irport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aer ial video and photography mission s would result in fewer aircraft that must be handled by a ir traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of Th e Zero 1600.

Conducting aerial acquisitions with the Zero 1600 UAS, instead of manned aircraft, will greatly benefit the public by drastically reduci ng the levels of air and noise pollution generated during traditio nal aerial video and still p hotography flight operations. By using battery power and elect ric motors, the Zero 1600 produ ce no air pollution, and

is the most viable environmenta lly conscious alternative to the cabin class, six cylinder internal combustion engine aircra ft that are typically utilized for aerial video and photography, while burning approxima tely 20-30 gallons per hour of leaded aviation fuel.15 | Page The Zero 1600 UA, while reduci ng the carbon footprint of aerial acquisitions, also eliminates noise pollution, a s the UA is propelled by battery p owered electric motors,

rather than an interna l combustion engine. By using the Zero 1600 UAS to perform aerial acquisitions, the substantial risk to life and property in the air a nd on the ground, which is usuall y associated with traditional manned aircraft flight operations , will be substantially reduce d or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Zero 1600 UA (weighing approximately 2.65 re spectively, at its maximum gr oss weight with lengths of 14 inches and 14 inc hes respectively, and with no fu el on board), has less physical potential for collateral damage to life and property o n the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Phot ography Operations With The Zero 1600 UAS Will Benefit The Economy.

In addition to being safe and effi cient, the Zero 1600 UAS is a lso an economical alternative to using manned air craft to conduct similar aerial operations. As such, operation of the Zero 1600 will allo w United States based compa nies, like Rudy Castillo III, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviati on fuel and the Environmental Pro tection Agency (“EPA”) regulatory actions phasing out l eaded aviation fuels, U.S. owne d and operated companies must adopt new and alternative technology in order to remain co mpetitive. Operating the battery powered Zero 1600 UAS is one such technology that not o nly allows companies greater operational flexibility c ompared to manned aircraft, bu t provides such flexibility without the high operational cost of a traditional manned aircr aft. By operating the Zero 1600, companies such as Rudy Castillo III , can remain competitive and profitable, and therefore, provide greater job stability to employees and16 | Page contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the Zero 1600 UAS, provides a stable workforce that increases consumer spendi ng; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain c ompetitive both in the United S tates and abroad. 4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Rudy Castillo III’s pr oposed operation of the Zero 160 0 UA will not implicate any privacy issues. Specifically, the Zero 1600 UA will be oper ated only in compliance with operating documents (i.e., the Rudy Castillo III Aerial Op erations Manual, Monthly Maintenance Log, and Zero 1600 UAS I nstruction Manual) which re quires property

owner involvement as well as loc al law enforcement notification , and in accordance with the Federal Aviation Regulations, including the minimum altitud e requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely A ffect Safety, Or How The Exemption Would Provide A Level Of Safety At Least E qual To That Provided By The Rule From Which Rudy Castillo III Seeks Ex emption. 1. Reasons Why The Zero 1600 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size , weight, speed, and limited operat ing area associated

with the unmanned aircraft a nd its operation, Rudy Castillo III ’s operation of the Zero

1600 UA meet the conditions of F MRA Section 333, and will not r equire an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without air worthiness certification and sets forth requi rements for considering wheth er a UAS will create a hazard to users of the NAS or the public, or otherwise pose a t hreat to national security. Specifically, FMRA Section 333 sta tes the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, and not17 | Page later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if cer tain unmanned aircraft systems may operate safely in the nati onal airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary s hall determine, at a minimum-- (1) which types of unmanned aircraft sy stems, if any, as a result of their size, weight, speed, operational capa bility, proximity to airports and populated areas, and operation within vi sual line of sight do not create a hazard to users of the national ai rspace system or the public or pose a threat to nati onal security; and (2) whether a certificate of waiver , certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for th e operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--I f the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft syst ems in the national airspace system.

In seeking this exemption, Rudy Castillo III submits that the Z ero 1600 UAS can operate safely in the NAS pursu ant to FMRA Section 333, as demo nstrated by: (a) the

characteristics of the Zero 1600 UAS; (b) the pilot certificati on requirement; and (c) the specific operating limitations. a. The Specifications Of The Zero 1600 UAS Demonstrate Its Safe Characteristics.

The Zero 1600 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to nationa l security considering its si ze, weight, speed, and operational capability. i. Technical Specifications Of The Zero 1600 UAS.

The technical specifications of the Zero 1600 UAS are set forth by the Zero 1600 UA Specifications and Data Sheet , attached hereto as Exhibit A. ii. The Zero 1600 Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A D efined Operational Area.

The Zero 1600 UAS may be operate d in both manual and fully auto nomous flight modes. A complete description of the flight and navigational mo des of the Zero 160018 | Page UAS is provided of the Zero 1600 UAS User Manuals, attached her eto as Exhibit B. iii. The Zero 1600 Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Zero 1600 UA will remain sta tionary, in flight, for 3 seconds or more. If, a fter 15 seconds, the Zero 1600 UA d o not reacquire control link data from the GCS, the UAs w ill assume that the Control Li nk is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the F ailsafe Functions of the Zero 16 00 UAS are set forth in the Zero 1600 User Manual, attached hereto as Exhibit B. iv. The Zero 1600 GCS And Its Operation.

A complete description of the operation and specifications of t he Zero 1600 GCS and flight control software is provided. Zero 1600 User Manuals are attached hereto as

Exhibits B. b. Flight Operations Of Zero 1600 A re Limited To The Line Of Si ght Of A Certificated Pilot in Comma nd With A Safety Observer.

Rudy Castillo III will only utili ze certificated pilots who pos sess a current and

valid airman medical certificate to act as a pilot in command ( PIC) of the Zero 1600 UAS. Additionally, a safety observe r will assist all pilots dur ing flight time. c. Flights Of Zero 1600 UA Will Be Conducted Pursuant To Specif ic Operating Limitations.

In seeking this exemption, Rudy Cas tillo III proposes to commer cially operate Zero 1600 for the special purpose of conducting aerial video an d photography over

certain areas of United States , pursuant to the following speci fic operating limitations: 1. Operations authorized by this grant of exemption will be lim ited to the following aircraft described in t he operating documents, rotorc raft UAS weighing less than 55 pounds maxim um gross weight: Zero 1600 Unmanned Aircraft Systems. Proposed opera tions of any other aircraft wil l require a new petition or a petition t o amend this grant. 2. UAS operations under this exemption will be limited to condu cting operations19 | Page for the purpose of aerial video and photography. 3. The UA may not be flown at a n indicated airspeed exceeding 2 0 knots. 4. The UA must be operated at a n altitude of no more than 400 f eet above ground level (AGL), as indicated by the pr ocedures speci fied in the op erating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UA must be operated within vi sual line of sight (VLOS) o f the PIC at all times. This requires the PIC to be able to use human vision una ided by any device other than corrective le nses, as specified on the PIC’s FAA-issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety obse rver (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO m ay be used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before t he flight and cannot transfer hi s or her designation for the duration of t he flight. The PIC must ensure that the SO can perform the functions prescrib ed in the operating documents. 8. The SO must not perform any ot her duties beyond assisting th e PIC with seeing and avoiding other air traffi c and other ground based obstacles /obstructions and is not permitted to operate the camera or other instruments

. 9. The operating documents and the g rant of exemption must be a ccessible during UAS operations and made available to the Administrator upon req uest. If a discrepancy exists between the conditions and limitations conta ined in the grant of exemption and the pro cedures outlined in the operating documents, the conditions and limitations containe d in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the p rocedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the ope rator’s responsibility to tra ck such revisions and present updated and re vised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to t he grant of exemption. If the op erator determines that any update or rev ision would affect the basis u pon which the FAA granted the exemption, then t he operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-8 0) may be contacted if questions arise reg arding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a conditio n that affects the safe operation of the UAS, the air craft is prohibited from oper ating until the necessary maintenance has bee n performed and the UAS is found t o be in a condition for safe flight. The Ground Control Station must be i ncluded in the preflight inspection. All mainten ance and alterations must be p roperly documented in the aircraft records.20 | Page 11. Any UAS that has undergone mai ntenance or alterations that affect the UAS operation or flight characteristi cs, e.g. replacement of a flig ht critical component, must undergo a functiona l test flight. The PIC who c onducts the functional test flight must make an entry in the aircraft recor ds. 12. The pre-flight inspection mus t account for all potential di screpancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/co mponent, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, a nd record keeping requirements, in accordance with the operating documents. Maint enance, inspection, alterations, and status of replacement/overhaul com ponent parts must be noted in the aircraft reco rds, including total time in service, description of work accomplished, and the signature of the auth orized person returning the UAS to service. 15. Each UAS operated under this e xemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must mak e an entry in the aircraft re cord of the corrective action taken against d iscrepancies discovered betwee n inspections. 17. The PIC must possess at least a private pilot certificate a nd at least a current third- class medical certificate. 18. The operator may not permit any PIC to operate unless the P IC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operate d under the exemption, including evasive and em ergency maneuvers and mainta ining appropriate distances from pe rsons, vessels, vehicles and struc tures. PIC qualification flight hours must be logged in a manner consisten t with 14 C.F.R. § 61.51(b). Flights for the purposes of training the ope rator’s PICs are permitted under the terms of the exemption. However, training o perations may only be conducted during dedicated t raining sessions. During tr aining, proficiency, and experience-build ing flights, all persons not e ssential for flight operations are considered nonpart icipants, and the PIC must ope rate the UA with appropriate distance from nonparticipants in accordance wi th 14 C.F.R. § 91.119. 19. UAS operations may not be c onducted during night, as define d in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorologic al conditions (VMC). If flight at night is requ ired, a special request will b e made at the FAA office closest to propose d area of operations. Flights unde r special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airpor t reference point as denoted on a current FAA-publis hed aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the o peration is conducted in accordance with a NOTAM as required by the operato r’s COA. The letter of agreement with the airport management must be mad e available to the Administrator upon request.21 | Page 21. The UA may not be operated les s than 500 feet below or less than 2,000 feet horizontally from a cloud or whe n visibility is less than 3 sta tute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location with in the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted o bstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (consi dering wind and forecast weather conditions) there is enough power to fly at no rmal cruising speed to the intended landi ng point and land the UA with 25% ba ttery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Aut horization (COA) prior to conductin g any operations under the grant of exemption. This COA will also req uire the operator to request a Notice t o Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the AT O issued COA including class of airspace , altitude level and potential t ransponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) mark ings in accordance with 14 C.F.R . part 45, Subpart C. Markings must be a s large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS a ny time the UAS is operating. These documents m ust be made available to the Administrator or any law enfor cement official upon request. 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activitie s at all times. 30. The UAS may not be operated by t he PIC from any moving devi ce or vehicle. 31. Flight operations must be c onducted at least 500 feet from all nonparticipating persons (persons other than the P IC, SO, operator trainees or e ssential persons), vessels, vehicles , and structures unless: a. Barriers or structures are pr esent that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ens ure that nonparticipating person s remain under such protection. If a situation arises where22 | Page nonparticipating persons leave suc h protection and are within 5 00 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near ve ssels, vehicles or structure s where the owner/controller of such vessels, v ehicles or str uctures has gr anted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does n ot present an undue hazard, and; c. Operations nearer to the PIC , SO, operator trainees or essen tial persons do not present an undue hazard to those persons per § 91.119(a)

. 32. All operations shall be conduc ted over private or controlle d-access property with permission from the land owner/ controller or authorized re presentative. Permission from land owner/contro ller or authorized representat ive will be obtained for each flight to be conducted. 33. Any incident, accident, or flig ht operation that transgress es the lateral or vertical boundaries of the opera tional area as defined by the a pplicable COA must be reported to the FAA's U AS Integration Office (AFS-80) w ithin 24 hours. Accidents must be reported t o the National Transportatio n Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. 2. Reasons Why An Exemption From T he Requirements Of Section 61 .113(a) And (b) Would Not Adversely Affect Safety.

Rudy Castillo III submits that the equivalent level of safety e stablished by Section 61.113(a) and (b) will be maintained because no PIC will be all owed to operate the Zero

1600 UAS unless that PIC has demo nstrated, by meeting minimum f light-hour and currency requirements, that the PIC is able to safely operate t he Zero 1600 UAS in a manner consistent with the exemp tion, including evasive and eme rgency maneuvers and maintaining appropriate distan ces from people , vessels, vehicle s and structures. Considering Rudy Castillo III’s proposed area of operations, an d the operating limitations set forth-above; the parallel nature of private pil ot aeronautical knowledge requirements to those of commerc ial pilot requirements (See Exe mption No. 11062); and the airmanship skills necessa ry to safely operate the Zero 1600 UAS, Rudy Castillo III submits that the additional manned airmanship experience of a c ommercially certificated pilot would not correlate to the airmanship skills necessary fo r Rudy Castillo III’s specific proposed flight operations.23 | Page The FAA has previously grant ed relief from Section 61.113(a) an d (b) specific to UAS, in circumstances similar, i n all material respects, to tho se presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Rudy Castillo III will not allow any PIC to operate the Zero 16 00 UAS unless that PIC has demonstrated, by meeti ng minimum flight-hour requiremen ts or the Zero 1600 UAS training and currency requireme nts, that the PIC is able to safely operate the Zero

1600 UAS in a manner consistent w ith this exemption, including evasive and emergency maneuvers and maintaining appropr iate distances from people, ve ssels, vehicles and

structures. Specifically, the PIC must have accumulated and logged, in a ma nner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS roto rcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings i n the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in com pliance with applicable regu lations will ensure an equivalent level of safety dur ing Rudy Castillo III’s proposed operations. The Administrator has held that pr ior documented flight experience that was obtained in compliance with applicable regul ations would ensure safe operat ions, stating as follows: In Exemption No. 11062, the FAA requi red that prior to conducti ng operations for the purpose of motion picture fi lming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.5 1(b), 25 hours of total time as a UAS rotorcr aft pilot including at least 10 h ours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exempti on No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and mode l of UAS to be used for operati ons under the exemption. For clarification, the F AA considers these minimum h our requirements to be inclusive r ather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and th e 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addit ion to the hour requirements, the PIC must accomplish 3 takeoffs and landings i n the preceding24 | Page 90 days (for currency purposes). The FAA finds that at a minimu m, the flighthour requirements in Exempti on No. 11062 are appropriate to pra ctice and build proficiency in the skills nece ssary to safely c onduct the petit ioner’s proposed operations. The FAA also finds t hat prior documented flight exp erience that was obtained in compliance with appl icable regulations would satisf y this requirement. Training, proficien cy, and experience-building fli ghts can also be conducted under the grant of exe mption to accomplish the requir ed flight time. During training, proficiency, and e xperience-buil ding flights t he PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, Rudy Castillo III wi ll ensure safe operations by n ot allowing any PIC to operate the Zero 1600 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency r equirements, that the PIC is able to safely operate the

Zero 1600 UAS in a manner consistent wit h the exemption, including evasiv e and emergency maneuvers and maintain ing appropriate distances from people, vessels,

vehicles and structures. 3. Reasons Why An Exemption From T he Requirements Of Section 91 .7(a) Would Not Adversel y Affect Safety.

The equivalent level of saf ety established by Section 91.7(a) w ill be maintained because prior to every flight, R udy Castillo III will ensure th at the Zero 1600 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents

and as stated in the conditi ons and limitations herein. Additionally, the FAA has previous ly granted relief from Sectio n 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From T he Requirements Of Section 91 .121 Would Not Adversel y Affect Safety.

The equivalent level of saf ety established by Section 91.121 wi ll be maintained

because the altitude information of the Zero 1600 UA will be provided to the PIC via GPS equipment and a radio commu nications telemetry data link, w hich downlinks from

the UA to the GCS for active m onitoring of the flight path and altitude. This altitude25 | Page information, combined with Rudy C astillo III’s operation of the Zero 1600 UA within visual line of sight, at or below 400 feet AGL, will ensure a l evel of safety equivalent to

Section 91.121. The altitude infor mation will be generated by G PS equipment installed

onboard the aircraft. Prior to e ach flight, a zero altitude ini tiation point is automatically established by the UAS at ground level. The FAA has previously grant ed relief from Section 91.121 speci fic to UAS, in circumstances similar, in all mate rial respects, to those prese nted herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11 112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From T he Requirements Of Section 91 .151(b) Would Not Adversel y Affect Safety.

A grant of this exemption would e nsure an equival ent level of s afety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Zero 1600 UA; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Acco rdingly, Rudy Castillo III will ensure that it will safely operate the battery powered Zero 1600 UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minute s to the first point of intended landing and, assuming normal cruising speed, to fly af ter that for at least 4.5

minutes. Here, as in Exemption No. 11109, the technical specifications o f the Zero 1600 UAS; the limitations on the pr oposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety establish ed by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Zero 1600 UAS provide audible and visual warnings to the PIC at the GCS when the UA experienc es low battery voltage, the first warning occurring at approximately 33% remaining batt ery power, and again at approximately 10% remaining battery power. At the critically lo w battery level, the Zero 1600 UAS will descend and land automatically.26 | Page Significantly, previous exemptions granted by the FAA concernin g Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less tha n the minimums prescribed in Sec tion 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has pre viously granted relief from Section 91.151 specifi c to UAS, in circumstances si milar, in all material respects, to those presente d herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From T he Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Rudy Castillo III submits that the e quivalent level of safety with regard to the regulat ory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Rudy Castillo III wil l use trained technicians to p erform maintenance, alterations, or preventive main tenance on the UAS using the met hods, techniques, and practices prescribed in the opera ting documents (i.e., the Rudy Castillo III Aerial Operations Manual, Monthly M aintenance Log, and Zero 1600 UA In struction Manual). Furthermore, Rudy Castillo III wi ll document and maintain all m aintenance records for

the Zero 1600 UA.

Since the Zero 1600 UAS will be ins pected as prescribed by the operating documents, Rudy Castillo III will main tain the equivalent level of safety es tablished by Sections 91.405(a), 91.409(a)(1 ), and 91.409(a)(2). A copy of t he Zero 1600 User

Manuals are attached hereto as Exhibit B. Likewise, the exemption sought wil l not adversely affect safety because Rudy

Castillo III will use trained technicians to perform maintenanc e, alterations or preventive maintenance on the UAS using the methods, techniques, and pract ices prescribed by the27 | Page operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), becaus e all maintenance of the Zero 1600 UAS will be performed by t rained technicians. Mainten ance will be documented and maintained utilizing the monthly maintenance log

. Significantly, previous exemptions granted by the FAA concernin g Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics an d operating limitations of

the UAS are considered. In consideration of Rudy Castill o III’s proposed operating limi tations, the operating documents, and the techni cal aspects of the Zero 1600 UA, Rudy Castillo III submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) an d (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relie f specific to UAS in circumstan ces similar, in all material respects, to those pres ented herein (e.g. Exemption No s. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operatio n. In accordance with Section 333 of t he FAA Modernization and Ref orm Act of 2012 (FMRA) and 14 C.F.R. § 21.16 ent itled Special Conditions, Rudy Castillo III requests that the FAA prescribe sp ecial conditions for the inte nded operation of the Zero 1600 UA, which contain such safety standards that the Administr ator finds necessary to establish a level of safety equi valent to that established by 1 4 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 9 1.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special condit ions will permit safe operation of the UA for the lim ited purpose of conducting aeria l video and photography

over certain areas of the United S tates for compensation or hir e. FMRA Section 333 sets28 | Page forth the requirements for considering whether a UAS will creat e a hazard to users of the NAS or the public, or otherwise pos e a threat to national secur ity; and further, provides the authority for such UAS to ope rate without airworthiness cer tification in accordance with any requirements that must be established for the safe ope ration of the UAS in the

NAS. Likewise, the Administrator ma y prescribe special conditions pu rsuant to 14

C.F.R. § 21.16, for operation of the Zero 1600 UAS, since the airworth iness regulations of 14 C.F.R. Part 21 do not contain adequa te or appropriate safety st andards, due to the novel or unusual design features of t he aircraft. Section 21.16, enti tled Special Conditions, states the following: If the FAA finds that the airwor thiness regulations of this sub chapter do not contain adequate or appropriate s afety standards for an aircraf t, aircraft engine, or propeller because of a novel or unusual design feature of the a ircraft, aircraft engine or propeller, he prescri bes special conditions and amend ments thereto for the product. The special conditions are issued in accordance wi th Part 11 of this chapter and contain such safety s tandards for the aircraft, air craft engine or propeller as the FAA finds nece ssary to establish a level of sa fety equivalent to that established in t he regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special cond itions for Rudy Castillo III’s in tended operation of the Zero 1600 UA, which contain such saf ety standards that the Admi nistrator finds necessary to establish a level of safety equivalent to that est ablished by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Secti ons 61.113(a) & (b), 91.7(a), 91.1 21, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

 A Summary That Can Be Published In The Federal Register, stati ng: The Rules From Which Rudy Castillo III Seeks Exemption: Rudy Castillo III seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.40 5(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Natu re Of The Exemption Rudy Castill o III Seeks:29 | Page This exemption will permit Rudy Cast illo III to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain area s of the United States.

 Any Additional Information, Views , Or Arguments Available To Su pport Rudy Castillo III’s Request.

This Petition is made pursuant t o the FAA Modernization and Ref orm Act of

2012 (FMRA) Section 333, which directs the Secretary of Transportati on to determine if certain UAS may operate safely in the NAS. As such, Rudy Castil lo III’s request for exemption may be granted pursuant to the authority of FMRA Sect ion 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the req uirements for considering wh ether a UAS will create a hazard to users of the NAS or the public, or othe rwise pose a threat to national security; and further, p rovides the authority for such UAS to operate without

airworthiness certification. As discussed in detail above, Rudy C astillo III will operate th e Zero 1600 UA safely in the NAS, without crea ting a hazard to users of the NA S, or the public, or otherwise pose a threat to national security.30 | Page CONCLUSION As set forth herein, Rudy Castil lo III seeks an exemption pursu ant to 14 C.F.R. §

11.61 and Section 333 of the FAA Mode rnization and Reform Act o f 2012 (FMRA), which will permit safe operation of the Zero 1600 UAS commercia lly, without an airworthiness certificate, fo r the limited purpose of conductin g aerial video and photography over certain areas of t he United States. By grantin g this Petition, the FAA

Administrator will be fulfilli ng the Congressional mandate of t he FAA Modernization and Reform Act of 2012, while als o advancing the interests of t he public, by allowing Rudy Castillo III to safely, efficiently, and economically oper ate the Zero 1600 UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Rudy Cas tillo III respectfully requests that the Administrator gr ant this Petition for an exem ption from the requirements of 14 C.F.R Sections 61.113( a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2 ), and 91.417(a) & (b), and p ermit Rudy Castillo III to operate the Zero 1600 UAS commerc ially for the purpose of condu cting aerial video and photography over certain areas of the United States. Dated: March 15, 2016

Respectfully subm itted,

R udy Castillo III

_________________________ R udy Castillo III Rudy Castillo III 5202 Ferrington Dr San Antonio, TX 78223 210-334-870931 | Page Appendices: A – Zero 1600 UAS Specifications Data Sheet32 | Page APPENDIX – A

FEATURES Radio: Wi-Fi capable, 5.8GHZ transce iver with holder for iOS or Android Smartphone, dia ls for gimbal controls, Auto Take-Off/Landing button, Air craft Connection Indicator, Wi-Fi Connection Indicator , GPS Indicator and neck strap attachment point GPS: Return to Home, and Intelligen t Orientation Control mode Gimbal: 3 axis compatible with camera Motors: Brushless Safety Features in GPS Flight mode: When the Xplorer loses connecti on with the remote control, it returns to the last "connected" position. The Xplorer will try to recover the connectivity for 15 seconds before returning to the HOME point. Safety feature in Attitude Flight Mode: When the Xplorer loses connecti on with the Remote Control in Attitude flight mode, it migh t drift away, bu t will try to reconnect continuously. The Xplo rer will start to descend slowly when the battery power gets low. Low Battery Level Warning Function: The Xplorer will trigger the low battery warning on the Remote Control when battery capacity is low. Critical Low Battery Level: Xplorer in GPS mode: The rear flight indicators will b link red fast and the Xplorer will being to descend and land aut omatically if the distance between the Xplorer and Home point is more than 328' (100m). Th e Xplorer will return to Home poi nt if the distance is less than 328' (100m) Xplorer in Attitude mode: The rear flight indicators will b link red fast and the Xplorer will begin to descend to land automatically.

INCLUDES Xplorer Quadcopter Wi-Fi capable, 5.8GHz transceiver 3 axis gimbal with camera Two 3s, 5200mAh "Smart" LiPo batteries Intelligent chargers for Smar t battery pack and controller33 | Page Spare propellers and tools Instructions

SPECIFICATIONS Xplorer; Quad Size: 13.75" (350mm) diameter Weight: 2.65lbs (1202g) RTF Flight Time: About 25 minutes Prop Size: 9.4 (240mm) Flight Batteries: 3S 5200mAh LiPo Motors: Brushless Onboard Navigation Equipment: GPS and Compass Flight Modes: GPS and Attitude Transceiver; Receives: 5.8GHz Transmits: 5.8GHz LiPo Battery: 4000mAh 1S 3.7V Working Current/Voltage: 3.7v/450mAh Maximum Communication Distance: 1640' (500m) Operating Temperature: 14-122°F (-10 - 50°C)