P. (787) 644-2917

F. (787) 293-1008

A. PMB 163 Suite 101

 220 Western Auto Plaza 

 Trujillo Alto, PR 00976

info@MicroCopterPro.com 

December 30, 2014

US Department of Transportation and

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: AMENDMENT to Request of Exemption

by the US Congress PL 112-95, 2012, FAA 

Modernization and Reform Act, for safe and 

responsible commercial use of UAS.

Docket Id. FAA-2014-0557

Dear US DOT and FAA Officials:

This document is an AMENDMENT to our original  ̈Request of Exemption ̈ submitted on August 

1st, 2014. On October 8 we received a letter from the FAA (Docket Id: FAA-2014-0557-0006) in 

which we were informed that beginning September 25, 2014, the DOT-FAA requires Requesters 

to comply with the  ̈Public Guidance for Requests for Exemption Filed under Section 333. ̈

We are including all the credentials of our certified pilots with their appropriate airman certificate 

as prescribed by 14 CFR 61 for the proposed operation.

We believe our original Request meets all the requirements established by the US Congress in 

PL 112-95. Nevertheless, this AMENDMENT provides additional proof of our compliance with 

the current  ̈Public Guidance ̈ and will facilitate the FAA’s evaluation.

Following the recommendation from the  ̈Public Guidance ̈, we have adopted some arguments 

from the Astraeus’ Request that we believe pertain to our case.

Also to facilitate the evaluation of the FAA, we have reorganized the content of our Request

including the following manuals and documents:
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 2

a. “UAS Flight Operations and Procedures Manual” (FOPM) Appendix A

• “UAS Commercial Flight Register” (UCFR) Appendix A-1

• “Permission to Operate Form” (POF) Appendix A-2

• “UAS Plan of Activities” (UPA) Appendix A-3

• “UAS Request of Authorization to ATC” (URAA) Appendix A-4

• “UAS Safety Flight Checklist” (USFC) Appendix A-5

• “UAS Crew Flight Log” (UCFL) Appendix A-6

• “Liability Release and Consent Form” Appendix A-7

b. “UAS Inspection and Maintenance Manual” (UIMM) Appendix B

Forms:

• “UAS Maintenance and Repair LogBook” (UMRL) Appendix B-1

• “UAS Fleet Specs and Manufacturers’ Manuals” Appendix B-2

c. “UAS Training Manual” (UTM) Appendix C

Form:

• “UC Training Log” (UTL) Appendix C-1

d. UAS Crew (UC) Members Personal Data Appendix D

The DOT-FAA should use this AMENDMENT as its main point of reference in regards to our 

Request as it includes the most important aspects of our original  ̈Request of Exemption.” 

Furthermore, This amendment includes additional information required to better comply with the 

Public Guidance’s specific requirements and suggestions.

Congressional mandate PL 112-95, FAA Modernization and Reform Act, February 14, 2012, 

Subtitle B-Unmanned Aircraft Systems, integrates Unmanned Aircraft Systems (UAS) into the 

NAS by way of special rules.

US Congress used the term "Integration" in distinguishing UASs as flying objects that are 

different from conventional aircraft. Congress resolved that UAS integration into NAS must be 

done by establishing operational and security focused special rules for UAS that are distinct 

from those applied to conventional aircraft. These rules should be both reasonable and 

proportional in recognizing UAS’ characteristics.

It is common knowledge that some UASs have capabilities that resemble those of conventional 

aircraft. These capabilities include, but are not limited to; some unmanned aircraft’s operational 

and flying capacities outside of the pilot’s visual line of sight, its abilities to reach great altitudes 

and high speeds, and its significant size and weight. These types of UASs have a significantly 

more important and active presence in air traffic. Our UASs DOES NOT possess those 

capabilities, therefore these types of concerns do not apply to either our Request or to our 

proposed commercial use.

Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 4

Note to US DOT-FAA Docket Administrator:

For obvious reasons, we ask the US DOT-FAA to keep the information presented on this application,

owned by our company, as strictly CONFIDENTIAL. The information that we consider CONFIDENTIAL is 

the following:

1) “UAS Flight Operations and Procedures Manual” (FOPM) Appendix A

Including all related documents and forms

2) “UAS Inspection and Maintenance Manual” (UIMM) Appendix B

Including all related documents and forms

3) “UAS Training Manual” (UTM) Appendix C

Including all related documents and forms

4) UAS Crew (UC) Members Personal Data Appendix D

Including all related documents and forms
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 5

AMENDMENT to Request of Exemption

by the US Congress PL 112-95, 2012,

FAA Modernization and Reform Act, 

for safe and responsible commercial use of UAS.

Docket Id. FAA-2014-0557

MicroCopter Professional Services Inc.

(MicroCopter Pro)

December 30, 2014

MicroCopter Professional Services Inc. (MicroCopter Pro) is submitting this Request as follows:

1. General Request of Exemption: That, taking into consideration that:

a) all of our operations will be subject to FAA supervision and regulations, and will 

never interfere with air traffic and/or any other government activity;

b) we are committed to comply rigorously with the FAA’s safety measures, the 

protection of third party rights, and the procedures that are part of this Request

including the manuals and risk mitigation procedures;

c) aforementioned security measures as well as our comprehensive manuals are 

equivalent to conventional aircraft regulations, and therefore mitigate proportional

and reasonable air and ground safety in what pertains to these small devices;

d) our flights would only take place under 400 feet (AGL), during daytime, far away from 

airports and congested or populated areas, following strict security measures, within 

the PIC visual line of sight (VLOS), with written authorization from the owners of the 

property in which the activity is taking place and/or written authorization from a 

government agency. Due to the nature of the services we will offer, most of our 

flights will take place between 100 and 200 feet (AGL);

e) our services benefit the public interest as a whole;

f) we have FAA certified pilots and trained specialists with expertise in the maintenance

of UASs, and we have a workshop specialized in the repair, maintainance, and 

programming of UAS-Model Aircrafts and other R/C devices;

g) in order to address the NAS and national security concerns, all our staff has with 

necessary credentials and experience to perform their respective tasks;

h) we are hereby providing all the specifications for each and every one of our devices 

that are already acceptable in the national market as Model Aircrafts; and
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 6

i) we will offer commercial and professional services in a safer, more cost-effective,

and accessible way than other conventional methods, which are used for these 

services...

...the DOT-FAA grants us authorization to offer professional and commercial services 

using the UASs specified herein, subject to what is included in this Request and any 

other conditions which the US DOT-FAA understands must be amended or included.

2. Commercial Activities: That, within the conditions described in this Request and any 

others the US DOT-FAA understands must be included, authorization be granted to us to 

use UASs, as described herein, which are equipped with cameras and sensors, in order to 

engage in the following professional and commercial activities:

(a) Video filming and photography by air for public and private purposes, including: 

television, cinematography, advertising and promotions, only with the written

authorization of the owners or producers.

(b) Video filming and photography by air to support professional operations in 

engineering, land surveying, architecture, real estate and other related professional 

activities, only with the written authorization of the owners.

(c) Video filming and inspections by air of agricultural areas only under contract with the 

owners or with a government entity.

(d) Video filming and inspections by air of infrastructure such as bridges, highways, 

electrical installations, dams, aqueducts, photovoltaic power stations, pipelines and 

wind farms, only under contract with the owners or with a government entity.

(e) Video filming and inspection by air of land and residential, commercial and industrial 

structures, only under contract with the owners or with any government authority.

(f) Inspections by air to detect sources of pollution, gas emissions and leaks, under 

contract with the owners of the properties involved or with a government entity.

(g) Provide support to search and rescue operations and reconnaissance in cases of 

need, law enforcement operations, emergency or natural disasters and only when 

government authorities have requested it by contract or donation.

(h) Offer consultancy, demonstrations, and training to private and public entities, which 

are interested in the DOT-FAA authorization for the use of UASs like ours. In our

staff is included a FAA certified Pilot-Instructor. This activity of professional services

–consulting, demonstrations and training- does not imply that Microcopter Pro can

issue certificates or permits of any kind.
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 7

3. Applicant’s information:

MicroCopter Professional Services Inc. (MicroCopter Pro):

President: Sergio Montañez

Email: sergio@MicroCopterPro.com

Address: PMB 163 Suite101

220 Western Auto Plaza

Trujillo Alto, Puerto Rico 00976

MicroCopter Professional Services Inc. (MicroCopter Pro) is a registered company on 

the Registry of Corporations of the Department of Sate in San Juan, Puerto Rico, under 

No. 339370 and Employer Identification Number: XX-XX-2686. Its commercial purpose 

is to consolidate activities of Hobby Shop and offer Professional and Commercial 

Services with UASs:

a. Hobby Shop - the sale of these small and light-weight devices, primarily multi-rotor 

(microcopters), for recreational purposes; 

b. Workshop for Maintanance, repairs and programming of UASs and other R/C 

devices; and

c. Professional and Commercial Services - with our own and specialized devices for 

conducting aerial filming and inspections under contract with industries, private and 

public sectors, including air filming services for commercial and television purposes.

DJI Innovations recognize our workshop as the only one Technical Support and Repair 

Center in Puerto Rico.

Our headquarters and facilities are located in San Juan, Puerto Rico and consist of the 

following: Hobby Shop, Workshop, Executive offices, Editing Room, Warehouse, and 

Conference Rooms. So far the only performed activity is Workshop.
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 8

4. Specific sections of 14 CFR from which MicroCopter Pro is seeking exemptions:

14 CFR Part 21, Subpart H Airworthiness Certificates

14 CFR 91.7 Civil aircraft airworthiness

14 CFR 91.9 (b) (2) Civil aircraft flight manual, marking, and placard 

requirements

14 CFR 91.103 Preflight action

14 CFR 91.109 (a) and Flight instruction

14 CFR 91.319 (a) (1) Simulated instrument flight and certain flight tests

14 CFR 91.119 Minimum safe altitudes: General

14 CFR 91.121 Altimeter settings

14 CFR 91.151 (a) Fuel requirements for flight in VFR conditions

14 CFR 91.203 (a) (b) Civil aircraft: Certifications required

14 CFR 91.405 (a) Maintenance required

14 CFR 91.407 (a) (1) Operation after maintenance, preventive 

maintenance, rebuilding or alteration

14 CFR 91.409 (a) (2) Inspections

14 CFR 91.417 (a) Maintenance records

14 CFR 45.23 (b) Display of marks; general 

14 CFR 45.29 Size of marks

14 CFR 61.113(a) (b) Certification: pilots, flight instructors, and ground 

instructors

5. Extent and the reason of relief:

a. 14 CFR Part 21, Subpart H Airworthiness Certificates

Section 91.203 (a) (1) requires all civil aircraft to have a certificate of airworthiness. Part 

21, 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 of our UAS (less than 25 lbs.) and the limited operating area 

associated with its operation, it is unnecessary to go through the certificate of 
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 9

airworthiness process under Part 21 Subpart H to achieve or exceed current safety 

levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 

11 and Section 333 of the Modernization and Reform Act. The Federal Aviation Act and 

Section 333 of the Modernization and Reform Act both authorize the FAA to exempt 

UAS from the requirement of an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of 

the UAS involved. 

In this case, an analysis of these criteria demonstrates that all of our UASs included in 

this Request of Exemption operated without an airworthiness certificate, under the 

conditions proposed herein, are safer than or as safe as a conventional aircraft with an 

airworthiness certificate. 

All of our UASs weigh less than 25 lbs. when fully loaded. They do not carry pilots,

passenger, commercial goods or flammable fuels, and will be operated exclusively within 

an area predetermined and in compliance with the conditions set forth herein. 

Operations under this exemption will be tightly controlled and monitored by the operator, 

pursuant to the conditions set forth above. Documented permission and knowledge prior 

to the operation of the land or property owner and/or responsible governmental 

authorities, planning of the operations and the characteristics of our UAS -size, absence

of flammable fuel, and the fact that they are deployed at the location and not flown there 

all establish the equivalent level of safety. Our UASs provide a greater or equal level of 

safety in the types of operations proposed when compared to a conventional aircraft.

b. 14 CFR 91.7 Civil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation of 

the UAS included in this Request to fly without an airworthiness certificate, no standard 

will exist to determine their airworthiness. Given the size of our UASs and the 

requirements that have already been met in the approval process (“UAS Inspection and 

Maintenance Manual” (UIMM), “UAS Flight Operations and Procedures Manual” 

(FOPM), “UAS Safety Flight Checklist” (USFC), “UAS Training Manual” (UTM)), and 

other mitigation procedures included in this Request, an equivalent level of safety will be 

achieved prior, during and after each flight.

c. 14 CFR 91.9 (b) (2) Civil Aircraft Flight Manual, Marking, and Placard 

Requirements

This section requires an aircraft flight manual in the aircraft. As there are no pilots, crew

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

equivalent level of safety will be achieved by maintaining a “UAS Flight Operations and 

Procedures Manual” (FOPM) at PIC’s Ground Control Station (GCS) during any 

operation. The FAA has previously issued exemptions to this regulation in Exemption 
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 10

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

32827. 

d. 14 CFR 91.103 Preflight Actions

Prescribes that each PIC shall, before beginning a flight, become familiar with all 

available information concerning that flight. An equivalent level of safety will be achieved 

by the PIC taking all preflight actions as set forth in our FOPM, including reviewing 

weather, flight battery requirements, landing and takeoff distances, and UAS 

performance data before initiation of flight. Additionally, MicroCopter will offer a briefing 

prior to each flight regarding planned UAS operations, and all personnel who will be 

performing duties within the boundaries of the Safety Perimeter will be required to 

attend.

e. 14 CFR 91.109 (a) Flight Instruction; and 14 CFR 91.319 (a) (1): Simulated 

Instrument Flight and Certain Flight Tests

These regulations provide 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. All UASs in our Request are remotely operated and by design

do not have fully functional dual controls. Flight control is accomplished through the use 

of a Radio Control (R/C) that communicates with the UAS via radio communications. If 

instruction is accomplished through a training program, as set forth in our “UAS Training 

Manual” (UTM), an equivalent level of safety will be assured. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft 

and for flight instruction in experimental aircrafts. See Exemption Nos. 5778K & 9862A. 

The equivalent level of safety will be achieved by our training program and the use of 

experienced and FAA certified pilots.

f. 14 CFR 91.119 Minimum Safe Altitudes: General

Establishes safe altitudes for operation of civil aircrafts. Specifically, 91.119 (c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the 

ground, except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle or structure. 

As set forth herein, our UAS will never operate at higher than 300 feet AGL at congested 

or populated areas. In the majority of cases our flights will be between 100 and 200 feet 

(AGL) due to the nature of the services that we will offer. Actually, we will never need to 

fly at more than 300 feet (AGL). Because our operations must be accomplished at 

relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from 

Section 91.119(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed and material 

with which our UAS are built. Also, no flight will be taken without the permission of the 

land or property owner, those who control it, or a governmental authority. Because of the 

advance notice to the owners, all affected individuals will be aware of the flights. 
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 11

Compared to aerial operations conducted with aircraft or rotorcraft weighing far more 

than 25 lbs. and carrying flammable fuels, any risk associated with these operations will 

be far less than those currently allowed with conventional aircraft operating at or below 

500 feet AGL. Indeed, the low-altitude operations of the UAS will maintain separation 

between these operations and the operations of conventional aircraft that must comply 

with Section 91.119.

g. 14 CFR 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 PIC, pursuant to the “UAS Safety 

Flight Checklist” (USFC), confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. Our R/C Transmitter box have Telemetry monitor with all 

of the information needs to fly UAS safely: altitude, flight speed, distance, direction and 

other.

h. 14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

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 our UAS provide approximately 30 minutes of powered flight. To 

meet the 30 minutes reserve requirement in 14 CFR 91.151, UAS flights would be 

limited to 0 (zero) minutes. 

Our maximum total flight time for each operational flight will be 20 minutes. Flights will 

be terminated at 33% minimum battery power reserve. We will never make flight 

operations at night.

Operating the UAS in controlled areas where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 20 minutes of 

flight operation time, does not give rise to the type of risks that Section 91.151 (a) was 

intended to alleviate particularly given the size and speed of the UAS.

i. 14 CFR. 91.203 (a) (b) Civil Aircraft: Certifications Required

This section provides for the carrying of civil aircraft certifications and registrations. They 

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

will be achieved by maintaining such certifications and registrations at the PIC’s Ground 

Control Station (GCS) box during any operation.
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 12

j. 14 CFR 91.405(a) Maintenance required

14 CFR 91.407(a) (1) Operation after maintenance, preventive 

maintenance, rebuilding or alteration

14 CFR 91.409(a) (2) Inspections

14 CFR 91.417(a) (b) Maintenance records

Section 91.405 (a) requires 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...” Section 91.407 similarly makes reference to 

requirements in Part 43; Section 91.409 (a)(2) requires an annual inspection for the 

issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or company operator to keep records showing 

certain maintenance work that has been accomplished by certificated mechanics, under 

Part 43, or licensed pilots and records of approval of the aircraft for return to service. 

Maintenance of the UAS included in this Request will be accomplished by MicroCopter 

Pro pursuant to the “UAS Inspection and Maintenance Manual” (UIMM) and “UAS 

Maintenance and Repair Log” (UMRL). An equivalent level of safety will be achieved 

because UAS are small in size, will operate only in restricted predetermined areas, and 

is not a complex mechanical devise. As provided in our “UAS Inspection and 

Maintenance Manual” (UIMM) and the “UAS Safety Flight Checklist” (USFC), the PIC

and our maintenance crew will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and will keep a log of any maintenance, repair or 

replacing parts that is performed. Moreover, the PIC is the person most familiar with the 

UAS and is best suited to maintain the aircraft in an airworthy condition and to ensure an 

equivalent level of safety.

MicroCopter Pro has a workshop -of daily operation- offering repair, maintenance and 

programming services for UAS as Model Aircrafts and others R/C devices.

k. 14 CFR 45.23 (b) Display of marks; general 

14 CFR 45.29 Size of marks

These regulations require aircrafts to be marked according to certain specifications. Our 

UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. 

All our UAS authorized for these commercial activities will have, to firmly adhere to the 

surface of the most resistant part of their structure, a light-weight plate on which is 

engraved -not written in ink- the code or information which the FAA will require on the 

authorization notice to our company.

The FAA has previously issued exemptions to this regulation through Exemptions 8738, 

10167, 10167A and 10700.
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 13

l. 14 CFR Part 61.113 (a)(b) Certification: Pilots, Flight Instructors, and Ground 

Instructors

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot’s license rather than a commercial pilot’s license to operate this 

UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is 

remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the “UAS 

Flight Operations and Procedures Manual” (FOPM). The level of safety provided by the 

requirements included in the FOPM exceeds that provided by a single individual holding 

a commercial pilot’s certificate operating a conventional aircraft. The risks associated 

with the operation of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations 

of the UAS as requested with a private pilot as the PIC exceeds the present level of 

safety achieved by 14 CFR §61.113 (a) & (b).

6. Reasons That Benefit the Public Interest as a Whole:

Cost-effectiveness and safety for the public interest as a whole

a. Our proposed filming and air inspection services are conventionally offered by manned 

aircrafts and climbers. The preceding may incur in elevated costs and pose a greater 

risk to persons and properties, therefore increasing the threat to air and ground safety. 

Conventional manned aircrafts also have a greater environmental footprint, and 

therefore harm the environment on a scale that far exceeds that posed by a UAS.

b. The use of manned aircrafts also greatly reduces the flexibility in the variety and angles 

of the images sought by contracting parties. That is, it is not possible to obtain with the 

same detailed, close-up images with the use of a conventional aircraft.

c. The use of our UAS dramatically reduces the costs and risks related to ground and air 

safety. Even in situations where accidents occur, the consequences are minimal when 

compared with those caused by manned aircrafts.

d. The proposed commercial use of UAS would reduce both the risks and costs that many 

persons, professionals and companies would incur if our services were not available. By 

hiring our services, persons, professionals and companies would be contributing to 

technological innovations and promote economic activity in a new line of services.

e. Our UASs are also much more accessible, safe and effective resource to support 

government authorities in their operations of reconnaissance, search and rescue and in 

cases of emergency or natural disasters.

f. Studies forecast the UAS industry to have a $13.6 billion impact on the first three years 

after clearance to operate in the NAS is granted. The same studies predict that the US 
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 14

economy will lose $10 billion per year if the UAS integration into the NAS is 

unreasonably limited or delayed. 

g. Studies also predict that more than 70,000 new jobs will be created in the first three 

years of UAS integration.

7. Reasons why granting the Exemption would not adversely affect safety, or how the 

Exemption would provide a level of safety at least equal to that provided by the Rules 

from which we are seeking Exemptions:

All human activities in the operation of equipment entail risks. But this does not mean 

that all devices which entail risks must be prohibited or regulated to the extreme degree 

of imposing a prohibition in practical terms. Under this premise, nearly everything would 

have to be prohibited: planes, helicopters, spacecraft, cars, bicycles, and even kitchen 

knives. Similar kinds of prohibitions would never occur to anyone, despite the fact that 

the equipment described above entail more risks and have produced more accidents, 

injuries and deaths than those which have been produced or which could be produced 

by the UAS which we plan to include in our commercial activities.

We all know that what makes a particular piece of equipment hazardous or dangerous is 

not whether money is charged for using it. In the final analysis, it would be irrelevant, 

from a preventive, security or investigative perspective or with the intention of serving 

the ends of justice, whether or not some person, criminal or terrorist had used an UAS 

irresponsibly in exchange for money. His crime would be to have caused hazards or 

damages. And, in order to commit a crime, he would have to use an aircraft -- whether 

manned or not -- that is regulated by the FAA, a car, a bicycle, and even his own hands.

In reality, what defines whether a piece of equipment is feasibly and reasonably safe 

are: its specifications, its operating features and the safety controls applied during its 

use.

Our staff has accumulated decades of experience in the operation and maintenance of 

these UASs as Model Aircrafts. We have never been involved in accidents in which 

individuals, properties or aircrafts were harmed. We have always followed air and 

ground security rules and regulations, even though we have not been engaged in 

commercial activity and were not under FAA supervision. If this Request is accepted, we 

would put ourselves under FAA supervision and regulations, adding an extra layer of 

security to our potential future activities.

US Congress PL 112-95, 2012, FAA Modernization and Reform Act,  ̈Subtitle B –

Unmanned Aircraft Systems ̈ establish a physical and operational equivalence between 

what is considered a small “Unmanned Aircraft ̈, as defined in Sections 331 and 333, 

and a  ̈Model Aircraft ̈, as defined in Section 336. The only difference between the 

aforementioned devices is that if a  ̈Model Aircraft ̈ is given commercial use, it becomes 

a small “Unmanned Aircraft ̈ for DOT-FAA regulatory purposes. The regulation of small 

“Unmanned Aircraft ̈ as mentioned in this Request is done by way of special rules, as 

established by Congress. If a potential small “Unmanned Aircraft ̈ is used for 
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 15

recreational, non-commercial purposes – like a hobby – then it becomes a  ̈Model 

Aircraft ̈ that is not subject to DOT-FAA regulations.

For decades and as of today, without the need of any DOT-FAA authorization,  ̈Model 

Aircrafts ̈ are used freely in the NAS, as per Congressional decision. The operators of 

 ̈Model Aircrafts ̈ hold varying degrees of skills and ranks. These flights are carried out 

in, or near, populated areas, with absolutely no proof of their ability to do so safely. 

Congress and the DOT-FAA allow this activity to take place based on the mere 

assumption that  ̈Model Aircraft ̈ operators follow a security guidance promoted by some 

community organizations with links to these types of activities.

Our commercial activity involved this type of UASs which are physically equivalent to 

Model Aircrafts will not pose any greater threat to the NAS or air traffic as those posed 

currently by Model Aircrafts. On the contrary, to submit us to the supervision and

regulations of the DOT-FAA, including the adoption of equal regulations or mitigation

procedures, a safer operation is guaranteed.

In order to provide further guarantees of the security regulations and risk mitigation 

procedures that will be followed, we include in this Request:

a. “UAS Flight Operations and Procedures Manual” (FOPM) Appendix A

Forms:

• “UAS Commercial Flight Register” (UCFR) Appendix A-1

• “Permission to Operate Form” (POF) Appendix A-2

• “UAS Plan of Activities” (UPA) Appendix A-3

• “UAS Request of Authorization to ATC” (URAA) Appendix A-4

• “UAS Safety Flight Checklist” (USFC) Appendix A-5

• “UAS Crew Flight Log” (UCFL) Appendix A-6

• “Liability Release and Consent Form” Appendix A-7

b. “UAS Inspection and Maintenance Manual” (UIMM) Appendix B

Forms:

• “UAS Maintenance and Repair LogBook” (UMRL) Appendix B-1

• “UAS Fleet Specs and Manufacturers’ Manuals” Appendix B-2

c. “UAS Training Manual” (UTM) Appendix C

Form:

• “UC Training Log” (UTL) Appendix C-1

d. UAS Crew (UC) Members Personal Data Appendix D
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 16

8. UASs Physical and Technical Specifications: We describe those which pertain to our 

UASs and their components, which would be used by MicroCopterPro in its commercial 

activities authorized by the DOT-FAA. At a minimum, our equipment complies with the 

following features:

(a) The part of the UAS that states that the largest size shall not exceed 1.5 meter long 

and, in flight, the total weight of each UAS will not exceed 25 pounds, including all of

its components and equipment.

(b) When UASs, their equipment and components exceed the 15 pounds of weight at 

the time of the flight, they will use a system of parachute activated by Radio Control 

for the purpose of eliminating or minimizing possible damages during a potential

accident. Our system is: Mars Parachute for UAV’s. This system is capable of 

working on an aircraft of up to 25 pounds utilizing a high energy compression spring 

and a servo to deploy the chute and reduce the falling speed of craft in the event of a 

malfunction.

(c) The maximum speed capability in flight of these UASs will not exceed 50 knots 

(57.539 mph).

(d) All our UASs use lithium battery charge as fuel, are already authorized for sale in the 

United States as Model Aircrafts. Maximum total battery charge for each flight will be 

of 30 minutes. Flights will be terminated at 33% battery power reserve.

(e) All our UASs operate with Radio Control (R/C) systems, are already authorized for 

sale in the United States as Model Aircrafts, and meet all requirements related to the 

Federal Communications Commission (FCC).

(f) Its flight systems are supported electronically by GPS and the “Safe Return” 

mechanism to guarantee that, in the event of the loss of the radio control signal, the 

UAS can return to the point of take-off in an autonomous and safe way. The point of 

take-off and “Safe Return” are always located within the “Maximum Safety 

Perimeter”, as we define it in our UAS Flight Operations and Procedures Manual 

(FOPM).

(g) All our UASs operate with propellers. Only those manufactured from flexible 

materials, capable of breaking up upon impact with other objects, will be used. 

Propellers manufactured with any type of metal in the blades will never be used.

(h) All our UASs authorized for these commercial activities will have, to firmly adhered to 

the surface of the most resistant part of their structure, a light-weight plate a lightweight plate on which is engraved -not written in ink- the code or information which 

the FAA will require on the authorization notice to our company.
Exemption Request to FAA

Under Section 333, PL 112-95, 2014

AMENDMENT -Docket Id. FAA-2014-0557

December 30, 2014

Page: 17

9. Skilled personnel: We are describing the legal obligations, experience, skills, personal data

and medical condition of all our staff directly engaged with the commercial operation of the 

UAS, including FAA certified pilots as PICs, VOs and Maintenance Technicians (MT) of 

UAS.

10. Security and Operational Rules and Manuals: We are describing in our Manuals all the

regulations, rules and mitigation procedures that will be rigorously followed when performing 

our operations, including those applied before, during and after each flight. In addition to the 

safety standards described in this Request, the safety rules established by the FAA will also 

be rigorously followed. 

If this Request is authorized by the DOT-FAA, we recognize and agree that it will be 

strictly limited to legitimate commercial activities, the operating conditions, the safety 

rules, and the types of equipment, which are contained in said authorization. We also 

recognize and agree that any other element that is not specifically authorized by the 

FAA will require a new application for evaluation or the submission of another 

Request to amend the authorization previously granted.

11. Summary to publish in the Federal Register:

Amendment to Request for Exemption regarding to the new “Public Guidance for 

Requests for Exemption Filed under Section 333”, FAA- September 25, 2014 for safe 

and responsible commercial use of UAS.

Docket No.: FAA–2014–0557

Requester: MicroCopter Professional Services Inc. (MicroCopter Pro)