June 17, 2015

U.S. Department of Transportation Docket Management Sy stem 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 sy stem (“UAS”) commerciall y in airspace regulated b y the Federal Aviation Administration (“FAA”).

Victor Ramos is an aerial photographer with in the State of Florida; I have bee a commercial photographer and Florida L icensed Real Estat e practitioner and Realtor for 25 years. I have added a semi

- pro DJ I Inspire 1 with intent for aerial videograph y/photograph y 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 b y the FAA.

My Exemption, (Victor Ramos) request would permit operation of qu ad copter unmanned (piloted by remote control) and comparativel y inexpensive UAS (s) in tightl y controlled and limited airspace. Predetermined in areas away from general public, airports, helicopters and vehicular traffic for community

videos and within pr opert y boundaries for individual homeowner real estatelisting video/photos. Currently , similar lightweight, remote controlled UAS’s are legally operated by unmonitored amateur hobbyists with no safet y plan or controls in place to prevent catastrophe.

I, Victor Ramos, have personally instilled safet y 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 M y (Vi ctor 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 sy stem, but to “...establish requirements for the safe operation of such aircraft sy stems (UAS’s) in the national airspace s ys tem” under Section 333 (c) of the Reform Act specific to the use of UAS’s for real estate/Realtor purposes. Further I will conduct m y 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 photograph y for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic growth through increased emplo ym ent an d increased tax base. With public safet y 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 exe mptions 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 applicatio n 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 s ys t em. The Reform Act in section 332 provides for such intergration of civil unmanned aircraft s ys tems into our national airspace s ys tem 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 b y the Reform Act. I would like to operate m y ultra light weight UAS prior to the time period by

which the Reform act requires the FAA to promulgate rules governing such aircraft. There b y, providing direct experience and valuable information for formal regulation that can be administered uniforml y to all real estate related UAS aerial video and photograph y. The Reform Act guides the Se cretary

in determining the t ypes of UAS’s that my operate safel y 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 whe ther the UAS will be operated b y 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 . M y UAS is equipped wi th GPS and auto return safet y 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. M y small unmanned aircraft is designed to hover in p lace via GPS and operate in less than 24 kph (15mph) wind. For safet y, stability and fear of finacil loss Iwill not fly in winds exceeding 16 kph (10 mph). Built in safet y sy stems 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 desi gned to slowl y descend and return to the point of take off. I do not operate m y UAS near airports, hospitals, high voltage wires, heliports. I do not operate around the general public when closer than 100 y ards 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 m y lo cation. M UAS is capable of vertical and horizontal operations, and are flown onl y within my line of sight, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generall y 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 st art the descend and return home, again for the greatest margin of safet y. I do not operate m y UAS at or below manufacture recommended minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communicat ion 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/propert y/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobb yi st simulating flights for future commercial use to gin familiarization with ch aracteristics of this specific UAS’s performance under different temperature and weather conditions. Ialso practice computerized simulated flights to maintain adequate skills and respon se reflex time. Safety

is number one.

I (Victor Ramos), am extremel y cautious when operating my UAS/ ultra

- light unmanned aircraft and will not “create a hazard to users of the national airspace s ys tem or the public.” 112 P.L . 95 

### §333 (b). Given the small size and weight of m y UAS it fall well within Congress’s contemplat ed

safet y zone when it promulgated the Reform act and the corresponding directive to integrate UAS’s into the national airspace s ys tem. Victor Ramos UAS, used in hobby flight, has demonstrable safet y record and does not pose an y threat to the general publi c or national security

.



### The Benefits of this request to **t he public as a whole.** 

Aerial photograph y/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 s ize and lack of combustible fuel alleviates any potential threat to the public.

Congress has alread y proclaimed that it is in the public’s interest to integrate commerciall y flown UAS’s into the national air space s ys tem, hence the passing of the Reform A ct. Granting m y (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 m y ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heav y contain combustible fuel and can cause catastrophic devastation to the public.

The public’s inter est is furthered b y minimizing ecological and crash threat by permitting aerial video/photo capture through m y battery operated ultra light weight UAS’s. Permitting me, Victor Ramos, to immediately

fly within national air space further economic growth. Gr anting 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 exem ption 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 safet y 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, Isubmit the following representations of enhancements to current aerial vide ography 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 strictl y 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 safet y. 5. I operate in reasonabl y safe environments, away from airports, populated areas and power lines. 6. UAS has GPS features whereb y it will hover and return home if communications with remote control is lost. 7. Flight data is routinely analyzed and updated to enhance safet y protocols. 8. I alway s obtain necessary permissions prior to operation and all concerned parties. 9. Procedures h ave been placed to abort flights in the event of safety breaches or potential dangers.

These safet y 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 airs pace s ys tem, helicopters are the primary means for aerial photography and videography

for communit y awareness and real estate. While the safety

record of these helicopters is remarkable, there have been accounts of loss of life and extensive propert y damag e; 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 peopl e on board. 3. The small size and weight make the UAS very maneuverable and allows for quick inter vention in the event of hazards.

I have operated m y UAS experimentally for familiarization and competency and continue to operate at and above current safety le vels.



### 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 m y 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 airwo rthiness 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, maneuv erability , and proximity to populated areas and airports. M y 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 b e 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 Regu lation is inapplicable. An equivalent level of safet y will be achieved b y m aintaining safet y flight manual delineating areas of where safet y can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737 , 8738, 929 9, 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 airc raft 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. Beca

use 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 b y 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: PI C

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 en sure remote control piloting skills. The risks attended to the operation of m y 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 m y UAS and meet and exceed current saf ety 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 wi ll not therefore apply to m y UAS. However, as a safet y precaution Iinspect 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. §§ 61.1 13 (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 commerciall y operate m y 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 ae rial videograph y/photograph y rel y primarily on the use of larger aircraft using combustible fuels posing potential risk to persons and propert y. Granting this request for exemption will reduce those risks and enhance safety

.

I respectfully

request that the FAA grant m y 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