Adriano	B agner	Sanchez 2319	Crotona	Ave	Apt	2B Bronx,	NY	10458

718

- 733

- 5567/917406

- 3310 bagnerbee@me.com

Mielle	Ezra

2345	East	69 th street Brooklyn,	NY	11234

917

- 406

- 3310 Mielleezra@yahoo.com

August	13 th ,	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	 p ursuant	 to	 Section	 333	 of	 the	 FAA	Modernization	 and	 Reform
Act,	 I Adriano	 Bagner	 Sanchez and Mielle	 Ezra operator s 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 clie nts	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	 / G eo

- fencing	 technology	 and	 a	 return	 to

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

controlled	conditions	in	our National A ir s pace	S ystem	which would	be	a)	limited	b) controlled	c)	predetermined	and	d)	will	provid e	safety	enhancements	to	the	already safe	 operations	 in	 the	 industry	 presently	 using	 conventional	 aircraft.	 Ap proval	 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	op eration	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

ar e	 in	 our	 professional	 endeavors, the	 more	 trust	 can	 be	 gained	 f rom	 the	 public

. Appl ying	 for	 this	exemption	makes	us	responsible	individuals	willing	 to	coopera te with	any	form	of future legislation ,	although	this	request does	not	exonerate	us	from taking	the	necessary	precautions	of	operating	such	aircraft. The	contrary i s	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	 s ubmitting	 this exemption	 request ,	 we	 adhere	 to	 the	 importance	 of	 safety	 operational	 p rotocols, regardl ess of	 operation recreation al	 or	 commercial ,	 we	 take	 the	 necessary precaution s	to	avoid	accidents

. For	further	consideration,	the	following	information

should	be	noted:

1.Our	UAS	weights	less	than	5	pounds.

2.We	conduct ext ensive	preflig ht	inspections	to	constantly	improve	safety	protocols.

3.We	 assess	 the	 locations	 used	 before	 flying	 and	 prior	 to	 l anding.	 Away	 from airports	and N o	Fly	Z one areas.

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

dis tance	of	300	feet	from	the	c ontroller	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	 batte ry level	warning	has	been	alerted.

7 .We will	 obtain	 verbal/written	 consent	 of	 all	 person s	 involv ed	 with	 the	 planned operation	and	ensure		that	only	consenting	persons	will	be	allowed	within	100	feet of	the	flight	operation

.In	 conclusion	 g iven	 the	 size,	 weight,	 speed,	 and	 limited	 operating area	 associated

with	 the YUNECC	 Typhoon 500 ,	 I	 believe an	 ex emption	 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	pa rt	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	 d ifficult	 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,	a lthough	helpful,	a	pilot’s	license	w ill	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	act ivities	outlined	in 14	CFR

61 .	We feel	the	operation	and	limitations	set	forth	in	the	FOM	will	e quate	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	experie nce	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

lo wer,	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.	T here 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	withou t	an	airworthiness	 certificate.	S ince	 there	is	 currently	 no	 cer tificate 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: t his	 regulation	 requires	 each	 pilot	 in	 command	 to	 take	 certain	 actions before	flig ht	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	 aircraftperformance data	 before	initiation	 of	 flight. We seek	exemptio n	 to	 this	 regulation, although.	 We believe	 in	 all	 above	 precautionary	 measures	 to	 av oid	 any	 pitfalls before	flight	operation.

We request	an	exemption	from **§** 91.109: because	by	design	this	aircraft	has	no	f ully functional	 dual	 controls.	 It	 is	 build	 to	 be	 controlled	 by	 an	 operator	 via	 a	 ground

based	 remote. The	 FAA	 has	 approved	 exemptions	 for	 flight	 training	 without	 fully functional	 dual	 controls	 for	 a	 number	 of	 aircraft	 and	 for	 flight	 instruction	 in experime ntal	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	 4 00	 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	 i n	 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	 u tilizes	 electron ic	 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	docume nts,	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),	 91.4 07(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 T he YUNECC	Typhoon500	user	manual.

We	appreciate	your	time	and	consideration

Sincerely

Adriano	B	Sanchez

Mielle	Ezra