Adriano	Bagner	Sanchez	

2319	Crotona	Ave	Apt	2B

Bronx,	NY	10458

718-733-5567/917406-3310

bagnerbee@me.com

Mielle	Ezra

2345	East	69th street	

Brooklyn,	NY	11234

917-406-3310

Mielleezra@yahoo.com

August	13th,	2015

Re:	 Exemption	 Request	 Pursuant	 to	 Section	 333	 of	 the	 FAA	 Reform	 Act	 and	

Part	11	of	the	Federal	Aviation	Regulations	from:	14	CFR	21	subpart	H:

14	CFR	45.23(b)	

14	CFR	61.113(a)	and	(b)

14	CFR	91.7(a)	

14	CFR	91.9(b)(2)	

14	CFR	91.103	

14	CFR	91.109	

14	CFR	91.119(c)	

14	CFR	91.121	

14	CFR	91.151(a)	

14	CFR	91.203	(a)	and	(b)	

14	CFR	91.405	(a)	

14	CFR	91.407	(a)	(1)	

14	CFR	91.409	(a)(1)	and (2)	

14	CFR	91.417(a)	and	(b)

To	whom	it	may	concern:

We	 are	 writing	in	 pursuant	 to	 Section	 333	 of	 the	 FAA	Modernization	 and	 Reform	

Act,	 I	Adriano	 Bagner	 Sanchez and	Mielle	 Ezra operators of	Unmanned	Aircraft	

Systems	 (UAS),	 hereby	 apply	 for	 an	 exemption from	 the	 listed	 Federal	 Aviation	

Regulations	 (“FARs”)	 to	 allow	 commercial	 operation	 of	 designated	 UAS,	 provided	

such	operations	are	conducted	within	and	under	 the	conditions	outlined	herein	or	

as	may	be	established	by	the	FAA	as	required	by	Section	333.

We	seek	relief	 for	the	purpose	of	offering	our	services	to	commercial clients	in	the	

real	 estate,	 film	 and	 stock	 footage	 industries.	 We currently	 own	 the YUNECC	

Typhoon500	 /4k	camera;	equipped with	camera,	sensors, battery	level	warnings,	

a	 ground	 based	 control	 system	with	 GPS	 /Geo-fencing	 technology	 and	 a	 return	 to	

home	button.	
The	 requested	 exemption	 would	 permit	 the	 operation	 of	 such	 aircraft	 under	

controlled	conditions	in	our	National Airspace	System	which	would	be	a)	limited	b)	

controlled	c)	predetermined	and	d)	will	provide	safety	enhancements	to	the	already	

safe	 operations	 in	 the	 industry	 presently	 using	 conventional	 aircraft.	 Approval	 of	

this	 exemption	 would	 thereby	 enhance	 safety	 and	 fulfill	 the	 Secretary	 of	

Transportation’s	 (the	 FAA	 Administrator’s)	 responsibilities	 to	 “....	 establish	

requirements	for	the	safe	operation	of	such	aircraft in	the	national	airspace	system.”

We	 live	 in	 a	 fast	 paced	 world	 that	 demands	 technology	 advancements.	 These	

unmanned	 aircraft	 systems	 (Drones)	 are	 fast	 becoming	 part	 of	 our	 lives	 and	 our

space	ecosystem.	One	of	the	first	steps	to	implement	a	set	of	future	regulations	is	to	

educate	our	selves	in	regards	to	this	technology.	The	more	prepare	and	informed	we	

are	 in	 our	 professional	 endeavors, the	 more	 trust	 can	 be	 gained	 from	 the	 public.	

Applying	 for	 this	exemption	makes	us	responsible	individuals	willing	 to	cooperate	

with	any	form	of	future	legislation,	although	this	request does	not	exonerate	us	from	

taking	the	necessary	precautions	of	operating	such	aircraft. The	contrary	is	the	first	

step to	achieve	an	organized	structure	and	collect	information	on	who	is	operating	

these	 aircrafts. We fully	 support	 and	 respect	 the	 FAA and	 its	 ongoing	 efforts	 to	

guarantee the	safety	demands	the	public	deserves.

We look	 forward	 to	 enhance	 and	innovate	 safety	 practices	 and	 by	 submitting	 this	

exemption	 request,	 we	 adhere	 to	 the	 importance	 of	 safety	 operational	 protocols,	

regardless of	 operation	 recreational	 or	 commercial,	 we	 take	 the	 necessary	

precautions	to	avoid	accidents. For	further	consideration,	the	following	information	

should	be	noted:

1.Our	UAS	weights	less	than	5	pounds.

2.We	conduct extensive	preflight	inspections	to	constantly	improve	safety	protocols.	

3.We	 assess	 the	 locations	 used	 before	 flying	 and	 prior	 to	 landing.	 Away	 from	

airports	and	No	Fly	Zone areas.

4.Flights	will	be	operated	at	an	altitude	not	exceeding	400 feet	and	within	a	radius

distance	of	300	feet	from	the	controller	to	aid	in	direct	line	of	visual	line	of	sight.

5.Flight	data,	battery	levels,	wind	conditions	will	be	analyzed	 to	constantly	update	

and	 enhance	 safety	 protocols. We	 always	land the	 aircraft	 as	 soon	 as	 first	 battery	

level	warning	has	been	alerted.

7.We	will	 obtain	 verbal/written	 consent	 of	 all	 persons	 involved	 with	 the	 planned	

operation	and	ensure		that	only	consenting	persons	will	be	allowed	within	100	feet	

of	the	flight	operation.
In	 conclusion	 given	 the	 size,	 weight,	 speed,	 and	 limited	 operating area	 associated	

with	 the YUNECC	 Typhoon 500,	 I	 believe	 an	 exemption	 from	 14	 CFR	 part	 21,	

Subpart	 H (Airworthiness	 Certificates)	 and	 §	91.203(a)	 and	 (b)	 (Certifications	

required),	subject	to	certain	conditions	and	limitations,		is	warranted	and	meets	the	

requirements	for	an	equivalent	level	of	safety	under	14	CFR	part	11	and	Section	333	

of	P.L.	112-95	(Section	333).

We request	an	exemption	from	§	45.23 Marking	of	the	aircraft	because	the	UA	will	

not	have	a	cabin,	cockpit	or	pilot	station	on	which	to	mark	certain	words	or	phrases.	

Further,	 the	 two-inch	 lettering	 is	 difficult	 to	 place	 on	 such	 a	 small	 aircraft	 with	

dimensions	smaller	than	the	minimal	lettering	requirement.	

We request	 an	 exemption	 from	 61.113 because	 our small	 UAS	 do	 not	 carry	 any	

pilots	or	passengers	nor	property,	although	helpful,	a	pilot’s	license	will	not	ensure	

remote	control	piloting	skills.	The	 risks	attendant	 to	 the	operation	of	small	UAS	is	

far	less	than	the	risk	levels	inherent	in	the	commercial	activities	outlined	in	14	CFR	

61.	We feel	the	operation	and	limitations	set	forth	in	the	FOM	will	equate	to	the	safe	

operation	of	the	small	UAS.		The	safe	operation	and	control	of	the	UAS	as	described	

in	this	application	does	not	depend	on	the	type	of	FAA	license	held	by	the	PIC.	That	

knowledge	can	be	and	is	gained	primarily	through	practice	and	experience	and	not	

through	 flight	 training	 in	 fixed	 wing	 or	 rotor	 aircraft,	 nor	 is	 it	 dependent	 on	 the	

acquisition	 of	 a	 commercial	 or	 private	 pilot’s	 certificate.	 Those	 certificates	

demonstrate	 knowledge	 of	 the	 factors	 and	 skills	 needed	 for	 the	 safe	 operation	 of	

those	types	of	aircraft	(fixed	wing	or	rotorcraft).	It	cannot	be	assumed	that	any	type	

of	 pilot,	 approved	 to	 operate	 a	 helicopter	 or	 fixed	 wing	 aircraft,	 has	 the	 skill	 or	

ability	 to	 safely	 operate	a	 small	unmanned	aerial	 vehicle,	 operating	at	400	AGL	 or	

lower,	within	strictly	controlled	pre-approved	airspace.	From	a	practical	standpoint,	

there	are	relatively	few	licensed	full-scale	aircraft	pilots	who	are	also	qualified	to	fly	

the	type	of	UAS	that	are	utilized	for	infrastructure	image- capture	operations.	There	

are	 even	 fewer	 pilots	 that	 can	 fly	 these	 UAS	 – to	 the	 point	 that	 to	 do	 both	 is	

considered	rare.

We request	 an	 exemption	 from	 §	 91.7(a),	 which	 prohibits	 the	 operation	 of	 an	

aircraft	without	an	airworthiness	 certificate.	Since	 there	is	 currently	 no	 certificate	

applicable	to	our	operation,	this	regulation	is	inapplicable.

We	 request	 an	 exemption	 from	 §	 91.9(b)(2) which	 requires	 an	 aircraft	 flight	

manual	in	the	aircraft,	however	since	there	are	no	pilots	or	passengers	on	board	the	

aircraft	and	given	its	size,	this regulation	is	inapplicable.	I	believe	an	equivalent	level	

of	 safety	 will	 be	 achieved	 by	 maintaining	 a	 safety/flight	 manual	 with	 the	 UAS	

ground	station.

§	 91.103: this	 regulation	 requires	 each	 pilot	 in	 command	 to	 take	 certain	 actions	

before	flight	to	insure	the	safety	of	flight.	FAA	approved	rotorcraft	flight	manuals are	

not	 available	 for	 this	 type	 of	 aircraft. We will	 take	 all	 actions	including	 reviewing	

weather,	 flight	 battery	 requirements,	 landing	 and	 takeoff	 distances	 and	 aircraft	
performance data	 before	initiation	 of	 flight. We	 seek	exemption	 to	 this	 regulation,	

although.	 We believe	 in	 all	 above	 precautionary	 measures	 to	 avoid	 any	 pitfalls	

before	flight	operation.

We	request	an	exemption	from	§91.109: because	by	design	this	aircraft	has	no	fully	

functional	 dual	 controls.	 It	 is	 build	 to	 be	 controlled	 by	 an	 operator	 via	 a	 groundbased	 remote.	 The	 FAA	 has	 approved	 exemptions	 for	 flight	 training	 without	 fully	

functional	 dual	 controls	 for	 a	 number	 of	 aircraft	 and	 for	 flight	 instruction	 in	

experimental	aircraft due	to	its	size	and	speed	of	the	aircraft.

We request	an	exemption	from	§	91.119	(c) which	prescribes	safe	altitudes	for	the	

operation	of	civil	aircraft,	but	it	allows	helicopters	to	be	operated	at	lower	altitudes

in	 certain	 conditions.	We	 will	 not	 operate our	 UAS	 above	 the	 altitude	 of	 400	 feet	

above	 ground	 level	 (AGL)	 and	 will	 also	 only	 operate	 in	 safe	 areas	 away	 from	 the	

public	 and	 traffic,	 thus	 “providing	 a	level	 of	 safety	 at	least	 equivalent	 to	 or	 below	

those	 in	 relation	 to	 minimum	 safe	 altitudes.”	 Given	 the	 size,	 weight,	

maneuverability,	and	speed	of	the	UAS,	an	equivalent	or	higher	level	of	safety	will	be	

achieved.

We request	 an	 exemption	 from	 §	 91.121 Altimeter	 settings,	 as	 it	 is	 inapplicable	

since	 the	 UAS	 utilizes	 electronic	 GPS	 with	 a	 barometric	 sensor	 and	 Geo	 fencing	

technology.

We	 request	 an	 exemption	 from	 §	 91.151(a) Fuel	 requirements	 for	 flight	 in	 VFR	

conditions.		The	UAV	is	100%	electric	and	two	low	battery	alerts	are	issued	- per	the	

operating	documents,	the	UAV	will	be	landed at	the	first	alert.	Also,	our	 flights	will	

last	only	15-20	minutes	each,	and	the	UAS	has	an	automated	function,	which	results	

in	immediate	landing	when	a	low	battery	is	detected.	

We request	 an	 exemption	 from	 §§	 91.405(a),	 91.407(a)(1),	 91.409(a)(2)	 and	

91.417(a)	 and	 (b) Maintenance	inspections	since	 they	only	apply	 to	aircraft	with	

an	 airworthiness	 certificate.	 However,	 as	 a	 safety	 precaution	 we	 will	 perform	 a	

preflight	 inspection	 of	 the	 UAS	 before	 each	 flight	 as	 outlined	 in	 the	 attached	

operating	documents.

Please, see	attached The YUNECC	Typhoon500	user	manual.

We	appreciate	your	time	and	consideration

Sincerely	

Adriano	B	Sanchez

Mielle	Ezra