June 17, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Victor Ramos

2682 Indian Pass Road

Port St. Joe, Fl 32456

850-340-1216

Email: Vic@VicRamos.com

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

From 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2);

91.103(b);91.109; 119.121;91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2);

91.417(a)&(b)

Dear Sir or Madam,

I am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

Procedures contained within 14 C.F.R. 11, to request that I, Victor Ramos, owner and operator of a 

small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARS”) listed 

below so that I, Victor Ramos, may operate my small unmanned aircraft system (“UAS”) 

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

Victor Ramos is an aerial photographer within the State of Florida; I have bee a commercial 

photographer and Florida Licensed Real Estate practitioner and Realtor for 25 years. I have added 

a semi-pro DJI Inspire 1 with intent for aerial videography/photography to enhance academic 

community awareness for those individuals and companies unfamiliar with the geographic area of 

The Forgotten coast of Florida and augment real estate listings videos; following exemption and 

approval by the FAA. 

My Exemption, (Victor Ramos) request would permit operation of quad copter unmanned (piloted 

by remote control) and comparatively inexpensive UAS (s) in tightly controlled and limited 

airspace. Predetermined in areas away from general public, airports, helicopters and vehicular 

traffic for community videos and within property boundaries for individual homeowner real estate 
listing video/photos. Currently, similar lightweight, remote controlled UAS’s are legally operated 

by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe.

I, Victor Ramos, have personally instilled safety protocols and controls to avoid and prevent public 

hazard, as well as manned aircraft hazard catastrophe. This will act to further safety protocols 

exclusive to light weight UAS’s specific to real estate video and photography usage. Also I, Victor 

Ramos, record all flight data and other information gained through permitted flight operations to 

share with the FAA through required FAA reports to assist with future protocol and safety

regulations.

Granting My (Victor Ramos) request comports with the Secretary of Transportation’s (FAA 

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

airspace system, but to “...establish requirements for the safe operation of such aircraft systems 

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

use of UAS’s for real estate/Realtor purposes. Further I will conduct my operations in compliance 

with the protocols described herein or as otherwise established b the FAA.

For the reasons stated below I, Victor Ramos, respectfully request the grant of an exemption 

allowing me to operate ultra light weight, remote controlled UAS’s for academic community

awareness to benefit/stimulate attraction to the Forgotten Coast of Florida areas and to enhance 

real estate listing videos/aerial photography for homeowners who cannot afford expensive manned 

aircraft for the same purpose. Both of which will promote local economic growth through 

increased employment and increased tax base. With public safety in mind by keeping heavier 

manned aircraft containing combustible fuel that poses potential public hazard. 

The Specific Sections of Title 14 of the Code of Federal Regulations From which Victor Ramos 

requests exemptions are:

14 C.F.R. 21;

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91, et seq.;

14 C.F.R. 407 (a) (1) ;

14 C.F.R. (a) (2); 

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

The extent of relief and the reasons for relief:

I, Victor Ramos, submit this application in accordance with the Reform Act, 112 P.L. 95 § §

331-334, seeking relief from any currently applicable FARs operating to prevent me, Victor 

Ramos, contemplated commercial cinematic, academic and other flight operations within the 

national airspace system. The Reform Act in section 332 provides for such intergration of civil 

unmanned aircraft systems into our national airspace system as it in the public’s interest to od so. 
My, (Victor Ramos), ultralight weight UAS meets the definition of “small unmanned aircraft” as 

defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly

contemplated by the Reform Act. I would like to operate my ultra light weight UAS prior to the 

time period by which the Reform act requires the FAA to promulgate rules governing such aircraft.

There by, providing direct experience and valuable information for formal regulation that can be 

administered uniformly to all real estate related UAS aerial video and photography. The Reform 

Act guides the Secretary in determining the types of UAS’s that my operate safely in our national 

airspace. Considerations include: weight, size, speed and overall capabilities of the UAS’s; 

Whether the UAS will be operated near airports or heavily populated areas; and whether the UAS 

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

exemption for me (Victor Ramos). My UAS utilizes four (4) counter-rotating propellers for 

balance control and stability. My UAS is equipped with GPS and auto return safety technology. 

Weighing 6.5 lb / 2.9 kg less than the maximum 55lb. limit including battery, camera and gimbal.

I, (Victor Ramos) consider safety as foremost with each flight. My small unmanned aircraft is 

designed to hover in place via GPS and operate in less than 24 kph (15mph) wind. For safety, 

stability and fear of finacil loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety 

systems include GPS mode that allows the UAS to hover in place when radio controls are released. 

The aircraft has three flight modes to choose from, F,A and P modes, P mode being the safest 

using vision and GPS. This is the safest, most reliable and stable mode to prevent accident and 

hazard. When pilot communication is lost UAS is designed to slowly descend and return to the 

point of take off. I do not operate my UAS near airports, hospitals, high voltage wires, heliports.

I do not operate around the general public when closer than 100 yards depending on location, 

conditions and weather. I am constantly on alert for any manned aircraft (police, medical 

helicopters, etc.) and prepared to land/abort immediately to the nearest safest ground point should 

a manned aircraft approach my location or I suspect a manned aircraft may approach my location. 

M UAS is capable of vertical and horizontal operations, and are flown only within my line of sight, 

as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally 

last from 5-10 minutes with an altitude under 200ft. I, Victor Ramos, always use a fresh fully

charged battery for each and every flight as a safety precaution; full flight time for each battery is 

18 minutes. Further I have programmed the controller to alert me when there is 30% power 

remaining to start the descend and return home, again for the greatest margin of safety. I do not 

operate my UAS at or below manufacture recommended minimum charge levels for operation; 

preferring to remain well within a safe operating range to insure adequate communication between 

radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries 

are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not 

believe in taking risk that may cause a crash, that could create hazard to public/property/manned 

aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in 

remote areas as a hobbyist simulating flights for future commercial use to gin familiarization with 

characteristics of this specific UAS’s performance under different temperature and weather 

conditions. I also practice computerized simulated flights to maintain adequate skills and response 

reflex time. Safety is number one.

I (Victor Ramos), am extremely cautious when operating my UAS/ ultra-light unmanned aircraft 

and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 §
333 (b). Given the small size and weight of my UAS it fall well within Congress’s contemplated 

safety zone when it promulgated the Reform act and the corresponding directive to integrate 

UAS’s into the national airspace system. Victor Ramos UAS, used in hobby flight, has 

demonstrable safety record and does not pose any threat to the general public or national security.

 

The Benefits of this request to the public as a whole.

Aerial photography/videography for geographical awareness and for real estate marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. For small budget real 

estate companies and average homeowners the expense of such aerial photography/videography is 

cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to 

absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a 

valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic 

crash with combustion engines and fuel tanks that can explode. Battery powered UAS’s pose no 

such threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown 

UAS’s into the national air space system, hence the passing of the Reform Act. Granting my 

(Victor Ramos) exemption request furthers the public interest through academic/ visual awareness 

of the geographical benefits in and around the Florida Panhandle.

My ultra light-weight UAS is battery powered and creares no emissins that can harm the 

environment. The consequence of my ultra light weight UAS crashing is far less than a full size 

helicopter or fixed wing aircraft; which are heavy contain combustible fuel and can cause 

catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through my battery operated ultra light weight UAS’s. Permitting me, Victor 

Ramos, to immediately fly within national air space further economic growth. Granting my

exemption request substantially furthers the economic impact for companies looking to relocate for 

career advancement through academic and geographical awareness. Both of which serve as a 

stimulus to the community.

Reasons why Victor ramos exemption will not adversely affect safety and 

how the exemption will provide a level of safety equal to existing rule:

Allowing Victor Ramos to contribute to the innovation and implementation of new and novel 

undiscovered safety protocols for Realtors that can be embraced by the National Association of 

Realtors, and The Realtors Association of Franklin & Southern Gulf County for development in 

cooperation with the FAA. In Addition, I submit the following representations of enhancements to 

current aerial videography and aerial photography for real estate.
1. Operate UAS below 400ft and mostly under 200ft which is well below the 400ft 

permissible ceiling set by the FAA Modernization and Reform Act of 2012.

2. My UAS is operated using remote control strictly by line of sight.

3. My UAS weighs 6.5 lbs/2.9kg with battery and camera.

4. I conduct thorough pre flight inspections and protocols to insure safety.

5. I operate in reasonably safe environments, away from airports, populated areas and power 

lines.

6. UAS has GPS features whereby it will hover and return home if communications with 

remote control is lost.

7. Flight data is routinely analyzed and updated to enhance safety protocols.

8. I always obtain necessary permissions prior to operation and all concerned parties.

9. Procedures have been placed to abort flights in the event of safety breaches or potential 

dangers.

These safety protocols that I have put in place provide a level equal to or higher than existing rules.

Without the integration of commercial UAS into the national airspace system, helicopters are the 

primary means for aerial photography and videography for community awareness and real estate. 

While the safety record of these helicopters is remarkable, there have been accounts of loss of life 

and extensive property damage; it is far safer to operate a battery powered ultra light weight UAS 

for these uses.

1. There is no fuel on board a UAS and the potential for fire or explosion is greatly

diminished.

2. Potential for loss of life is diminished because the UAS carries no people on board.

3. The small size and weight make the UAS very maneuverable and allows for quick 

intervention in the event of hazards.

I have operated my UAS experimentally for familiarization and competency and continue to 

operate at and above current safety levels.

Summary

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates and Manuals.

14 C.F.R. 21 Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size and 

weight and enclosed operational area of my UAS permits exemption from Part 21 because my

UAS meets and exceeds an equivalent level of safety pursuant to Section 333 of the Reform Act. 

The FAA is authorized to exempt aircraft from airworthiness certificate requirement under both the 

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

the FAA to exempt UAS’s from the airworthiness certificate requirement in consideration of size, 

weight, maneuverability, and proximity to populated areas and airports. My current and projected 

UAS’s meet or exceed each of these elements.
14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an air worthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation in 

inapplicable.

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

pilots or passengers, and the size and weight of the UAS’s, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining safety flight manual delineating areas of 

where safety can be defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 

32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes GPS 

with a barometric sensor.

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

registrations. They are inapplicable for the same reasons as described above. 

14 C.F.R. § 45.23: Marking the aircraft.

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

specifications. Because of the size of my UAS there is no room for such markings. Two inch 

lettering is not possible to place on an aircraft that is smaller than the required minimal lettering.

I will mark my UAS with the largest possible lettering by placing the word “EXPERIMENTAL” 

on its fuselage as required by 14 C.F.R. § 45.29 (f) so that I, the pilot and or anyone assisting me 

as a spotter will see the markings. The FAA has previously issued exemptions to this regulation 

thru Exemptions Nos. 8738, 10176, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC

Pursuant to 14 C.F.R. § 61.113 (a) & (b) private pilots are limited to non-commercial operations. 

My UAS does not carry pilots or passengers. A pilots license while helpful will not ensure remote 

control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels 

inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus allowing me to 

operate my UAS and meet and exceed current safety levels in relation to 14 C.F.R. § 61.113 (a) & 

(b).

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. My UAS will never 

operate at an altitude grater than 400ft AGL. My use of UAS is normally under 200ft AGL.
14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b) : Maintenance Inspections.

The above cited Regulations requires aircraft owners and operators to “have aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph © of this section, have discrepancies repaired as prescribed in part 43 of this chapter...”

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

apply to my UAS. However, as a safety precaution I inspect my UAS before and after each flight.

 

Summary:

Victor Ramos seeks an exemption from the following Regulations:

14 C.F.R. 21. subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a);

14 C.F.R. § 91.9 (b) (2); 14 C.F.R. § 91.103 (b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) & (b); 14 C.F.R. § 91.405(a) 14 

C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 91.417(a)&(b) to commercially 

operate my UAS and develop economic platforms for Real Estate and enhance the experience of 

those seeking to relocate to the Gulf County, Florida area. Currently, area awareness and Real 

Estate aerial videography/photography rely primarily on the use of larger aircraft using 

combustible fuels posing potential risk to persons and property. Granting this request for 

exemption will reduce those risks and enhance safety. 

I respectfully request that the FAA grant my exemption request and am willing to cooperate in 

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

Respectfully Submitted,

Victor Ramos

2682 Indian Pass Road

Port St. Joe, Fl 32456