7/14/2015

United States Department ofTransportation DocketOperations 1200New Jersey Ave.SE WestBuilding Ground Floor Room W12-140 Re:Exemption RequestPursuant To Section 333 ofthe FAA Reform Act of2012,and March 23,2015,`Blanket" CoA

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of2012 (the "Reform Act")and Blanket COA,of March 23,2015 and the procedures contained in 14• C.F .R. 11,to requestthatRichard Alvarado,owns and operates a DJIPhantom 2Vision iJNMANNED AIRCRAFT SYSTEM (UAS),and a transportable ground station.
Richard Alvarado is petitioning for exemption to operate a series of UAS platforms that have been previously approved by exemption.Namely: DJIPhantom 2-Exemption 11398 DJIPhantom 2Vision -Exemption 11310 DJIPhantom 2Vision+ -Exemption 11398 DJIInspire -Exemption 11398 DJIPhantom 3Professional -Similarto Exemption 11310 DJIPhantom 3 Advanced -Similar to Exemption 11398
This submission does not include the Operating Manuals for each model requested above, as they have been reviewed by the Administrator in granting previous exemptions. Copies ofall Operating Manuals for the individual models listed will be submitted on request. It should be noted, that while the FAA has not previously granted an exemption for the DJI Phantom 3 series, it is an upgraded version of the DJI Phantom 2 including components pioneered byDJIwith the Inspire 1.
These are referred to as quad-copters with the maximum gross weight not exceeding 15 pounds.It is equipped with four rotors that are driven by electric motors powered by batteries. These quad-copters have a maximum airspeed of 45 knots and to be exempted from the Federal Aviation Regulations(FAR's)listed below.
The exemption is needed in order to operate a small lightweight unmanned aircraft system (UNMANNED AIRCRAFT SYSTEMS (UAS)commercially in airspace regulated by the Federal Aviation Administration (FAA). These operations will be conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.§ 11.81. The following aspects ofSection 333 ofthe FAA Modernization and Reform Actof2012should be considered.
The following information is submitted to meetthe requirementofthe above act. 1.Name and address: a.Richard Anthony Alvarado b.22907Wilderness Rd,Edmond OIC,73025 c. Office:405-812-4354 d.Email:pdra0969@yahoo.com
2.The Specific Sections ofTitle 14 ofthe Code ofFederal Regulations fi•om which Richard Alvarado Requests Exemption are:

14. CFR21; 14. C.F.R.45.23(b); 14. CFR 61.113 (a)&(b); 14. C.F.R.91,et seq.; 14 CFR 407(a)(1);14. CFR 409(a)(2);and, 14. CFR 417(a)&(b).
3.The extent ofreliefyou seek,and the reason you seek relief:
Richat•d Alvarado, respectfully submits this request in harmony with the Reform Act, 112 P.L. 95 §~ 331-334•, pursuing reprieve from any currently applicable FARs operating to preclude me,Richard Alvarado's intended use is saleable aerial cinematography in video or still format within the Greater Oklahoma region to provide information for intended parties that enhances real estate listings or any legal business that provide supplementary tool adding a greater degree offlexibility which supplements the present abilities obtainable by manned aircraft inside the national airspace system.
The Reform Act in Section 332 provides for such incorporation ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Richard Alvarado's quad-copter small iJNMANNED AIRCRAFT SYSTEMS (UAS),meets the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of my ultra-light weight UNMANNED AIRCRAFT SYSTEMS (UAS) is expressly considered by the Reform Act.Richard Alvarado would like to operate his UNMANNED AIRCRAFT SYSTEMS (UAS),prior to the time period,by which the Reform Actrequires the FAA to broadcast rules governing such craft. The Reform Act guides the Secretary in defining the types ofUNMANNED AIRCRAFT SYSTEMS (UAS)'s that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UNMANNED AIRCRAFT SYSTEMS (UAS)'s; whether the L1i~IMANNED AIRCRAFT SYSTEMS (UAS) will be operated near airports or heavily populated areas; and, Whether the i.JNMANNED AIRCRAFT SYSTEMS (UAS)will be operated by line ofsight.My T_TNMANNED AIRCRAFT SYSTEMS (UAS) operates four (4) counter-rotating propellers for stability, conhol and steadiness. My iJNMANNED AIRCRAFT SYSTEMS (UAS)is equipped with GPS and auto return safety technology. Weighing less than ten (10)pounds far below the maximum 55 pound limit); including camera with gimbal. Operation ofthe UNMANNED AIRCRAFT SYSTEMS (UAS)preceding flight and post flight must be operated in a check list format and that safety is paramountwith each flight. My i_JNMANNED AIRCRAFT SYSTEMS (UAS) are designed to hover in place via GPS and operate in less than a 45 knot wind.Richard Alvarado will operate these UNMANNED AIRCRAFT SYSTEMS (UAS)with in mind that safety, stability and fear of detrimental financial loss,I will not fly in winds exceeding 13 knots (15 mph).Built in safety systems include a GPS mode that allows my UNMANNED AIRCRAFT SYSTEMS (UAS)to hover in place when radio controls are released. This is the safest, most dependable and unwavering mode to prevent accidents and haza►•ds. When pilot communication is lost these T_TNMANNED AIRCRAFT SYSTEMS (UAS)are designed to slowly descend to point of origination, the UNMANNED AIRCRAFT SYSTEMS (UAS) has a function that instantaneously video records once communication is lost.I do not and will not operate my LJ~VMANNED AIIZCRAFT SYSTEMS (UAS)near airports, Hospitals or helipads,and do not operate near areas where the general public is one hundred (100)yards depending on location, conditions and weather.Richard Alvarado is constantly and vigilantly on alert for any manned aircraft and prepared to either avoid and shall yield the right-of-way to all aircraft and operate in a mannerto avoid any type of collision hazard with respect to persons on the ground or property and to land/terminate instantly to the nearby and safest ground point should a manned aircraft approach my location or should I suspect manned ait•craft may approach near my location. My UNMANNED AIRCRAFT SYSTEMS (UAS) are capable of vertical and horizontal operations, and are flown only within my line of sight. As the Remote controlled pilot, the iJNMANNED AIRCRAFT SYS'T`EMS (UAS) is operation under the power of a battery power rather than combustible fuels, flights generally last between ten (10) and fifteen (15) minutes, with an altitude under two hundt~ed (200)feet, conducted during daytime, visual flight rules (VFR)condition and within visual line of sight (VLOS)ofme.Iwill follow FAA guidelines ofoperation 5 NM from an airporthaving an operational control tower 3NM from an airport with a published instrument flight procedure,but not an operational tower or 2NM from an airport without a published instrument flight procedure or a operational tower or 2 Nm from a heliport with an instrumentflightprocedure.

4.Ho~v RequestWillBenefitthe Public As A Whole:In-flight videography for topographical awareness and real estate marketing or any legal business utilizing aerial

photographs for video has been around for an extensive period oftime done with manned fixed wing aircraft and helicopters. For the small budget businessperson the expense of such aet•ial Videography is an enormous fee and cost prohibitive. Depriving, many of the smaller businesspersons from exploiting a valuable advertising tool. Manned aircraft exposes a superior hazard to the public through conceivable cataclysmic crash causing loss to property and or life, iJNMANNED AIRCRAFT SYSTEMS (UAS)pose no such hazards due its size, speed and nonexistence offlammable fuel significantly reduces any potential threatto the public.
5.Reasons Why Exemption Will Not Adversely Affect Safety or How the Exemption Will Provide a Level ofSafety At LeastEqual To Existing Rule: Richard Alvarado's safety protocols will enhance safety; exemption will not adversely affect safety. In addition, I submit the following t•epresentations ofenhancements to current aerial videography and photography for real estate or any legal business requiring photographic images:
Richard Alvaradds UAS weigh less than 15 pounds complete with DJIFactory installed camera: The listed UAS,firmware are programmed for maximum 300 feet above ground level and 1000 feet radius distance are limited distance for maintaining Visual sight line ofoperation. Most intended operation will only requires range of25-125 above ground level and less than 200 feet lateral distance from Pilot in command.
Currentfirmware upgrades tor:
➢ Main Controller ➢ GPS ➢ Receiver ➢ Battery ➢ Zen IMLJ

CurrentPhysical upgrades:

➢ DJIfactory Prop Guards

I. I for one always obtain all essential permissions prior to operation and post a warning sign reading "Attention Use of Quad RotorDrone for AerialPhotography in progress-Remain Bacic 125 feet' ; 2. I for one will conduct operations under strict personal and flight safety protocols and constantly strive to update and enhance safety protocols; 3. I for one conduct extensive pre-flight inspections and protocol, during which safety carries principal importance; 4. No payloads other•than gimbaled camera; 5. I for one only operate in reasonably sate environment that are strictly conh•olled, are away from power lines,elevated lights, airports and actively populated areas; 6. I for one, pilot my iINMANNED AIRCRAFT SYSTEMS (UAS)through t•emote control only by line of sight; 7. I for one,only operate my iJNMANNED AIRCRAFT SYSTEMS (UAS)with a height limitation set for a maximum of200 feet ABOVE GROiJND LEVEL and during the day (Operating -50% inside the 200 foot permissible ceiling setby the FAA Modernization and Reform Actof2012); 8. I for one,T_JNMANNED AIRCRAFT SYSTEMS (UAS)only operate for 3-7 minutes per flight, well with in tolerances issued by the manufacture; 9. I for one will land my UNMANNED AIRCRAFT SYSTEMS (UAS)prior to manufacturer recommended minimum level of battery power;10. I for one will employ the GPS the flight safety feature whet~eby it hovels and then slowly lands if

communication with the remote control pilot is lost and continues to record flight as per manufacture settings; 11. I for one will maintain records specific to retain until the work is repeated or superseded by other work for one year after the work is performed; 12. Ifor one will maintain records,shall retain and transferred with the aircraft atthe time the aircraft is sold; 13. I for one will list or denote in records a list ofdefects furnished to a registet•ed owner or operator shall be retained until defects are repaired and the aircraft is approved for return service; 14. I for one will use Visual flightrules (VFR)condition and within visual line ofsight(VLOS)ofme. 15. I will nothave flights within 5NM from an airporthaving an operational conhol tower. 16. I will not have flights within 3 NM from an airport with a published inshumentflight procedure,but notan operationaltower 17. I will not have flights within 2NM from an airpo~~t without a published instrument flight procedure or an operational tower or 2 Nm from aheliportwith an instrumentflightprocedure.
Richard Alvarado's operating procedures exceeding existing rules.First,the possible loss oflife is lessened because iJNMANNED AIRCRAFT SYSTEMS (UAS)'s carry no pilots or• passengers on board and I only operate my iJNMANNED AIRCRAFT SYSTEMS (UAS)safely in the direct detailed areas ofoperation versus fixed wing or helicopter which requires travel to the region of need. Second, there is no fuel on board an UNMANNED AIRCRAFT SYSTEMS (UAS)and thus the probability for fire or explosions is significantly diminished.Lastly,the small size and exh•emely maneuverability of my LJ~IMANNED AIRCRAFT SYSTEMS (ETAS) allow me to remotely pilot away from hazards quickly and safely.

6.A Summary The FAA May Publish in the FederalRegister:
14 C.F.R.21 and ll• C.F.R.91:Airworthiness Certificates,Manuals and the Like.
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, weight and enclosed operational area of my,Richard Alvarado's iJNMANNED AIRCRAFT SYSTEMS (UAS)permits exemption from Part 21 because my i.JNMANNED AIRCRAFT SYSTEMS (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 the airworthiness certificate requirement under both the Act(49U.S.C. § 44701 (fl)and Section 333 ofthe Reform Act. Both pieces of legislation permit the FAA to exempt UNMANNED AIRCRAFT SYSTEMS (UAS)'s from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Richard Alvaradds current and projected IJNi~1ANNED AIRCRAFT SYSTEMS (UAS)'s meet or exceed each ofthe details.
14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs,this Regulation is 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 given the size of the LnVMANNED AIRCRAFT SYSTEMS (UAS)'s, this Regulation is inapplicable.An equivalent level ofsafety will be achieved by maintaining safety/flight manual delineating areas of where safety can be defined.(See Enclosed) The FAA has previously issued exemptions to this regulation in ExemptionNos.8607,8737,8738,9299,92i19A,9565,9565B,10167,101fi7A, 1OG02,10700 and:J2827.
14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my LTI~IMANNED AIRCRAFT SYSTEMS(UAS)utilizes electronic global positioning systems with a barometric sensor•. 14 C.F.R. § 91.203 (a)and (b)provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level ofsafety will be achieved by maintaining any such required certifications and registrations by me,Richard Alvarado.
14 C.F.R. §45.23:Marking ofthe Aircraft.Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My

UNMANNED AIRCRAFT SYSTEMS (UAS)are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to marls certain words or phrases.Further,two-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its iJNMANNED AIRCRAFT SYSTEMS (UAS)s in the largest possible lettering by placing the word 'BXPERINIENTAL" on its fuselage as required by 14 C.F.R. §45.29 (fl so that I the pilot, or anyone assisting me as a spotter with the UA V will see the markings. The FAA has previously issued exemptions to this regulation through ExemptionsNos.8738,10167, 10 1G7A and\0700.

14 C.F.R. § 61113:Private Pilot Privileges and Limitations:PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. I, Richard Alvarado even though I currently hold a valid private pilot certificate, can achieve an equivalent level ofsafety as achieved by current Regulations because my UNMANNED AIRCRAFT SYSTEMS (UAS) does not carry any pilots or passengers.Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation ofmy UNMANNED AIRCRAFT SYSTEMS (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,Richard Alvarado,to operate my i.JNMANNED AIRCRAFT SYSTEMS (UAS)to 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 ofcivil ait•craft. It allows helicopters to be operated at lower altitudes in certain conditions. My UNMANNED AIRCRAFT SYSTEMS (UAS)will never operate at an altitude greater than 200 ABOVE GROiIND LEVEL; safely below the standard of 400 ABOVE GROUND LEVEL.I,Richard Alvarado,will however operate my iJNMANNED AIRCRAFT SYSTEMS (UAS)in safe areas away from public and traffic,providing a level ofsafety at least equivalentto or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UNMANNED AIRCRAFT SYSTEMS (UAS),an equivalentor higher level ofsafety will be achieved.

14 C.F.R. 91.405 (a);407(a)(1);409(a)(2);417(a)& (b):Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to "have [the] airct•aft inspected as prescribed in subpat~t E of this part and shall between required inspections, except as provided in paragraph (c)ofthis section,have discrepancies repaired as prescribed in pa~~t 1.3 ofthis chapter.... "
These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Richat•d Alvaradds iJNMANNED AIRCRAFT SYSTEMS (UAS). However, as a safeguard I inspect my UNMANNED AIRCRAFT SYSTEMS (UAS) beforehand and afterward each flight.

Summary the FAA May Publish in the FederalRegister: A.14 C.F.R.21 and 14

C.F.R. 91: Aii~vorthiness Certificates, Manuals and the Lilce. 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,weight and enclosed operational area ofmy iJNMANNED AIRCRAFT SYSTEMS (UAS) permit exemption from Part 21 because my, Richard Alvarado's UNMANNED AIRCRAFT SYSTEMS (UAS) meets an equivalent level of safety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (~)and Section 333of the Reform Act. Both pieces of legislation permit the FAA to exempt iJNMANNED AIRCRAFT SYSTEMS (UAS)'s from the airworthiness certificate requirement in consideration ofthe weight,size, speed,maneuverability and proximity to areas such as airports and dense populations. My UNMANNED AIRCRAFT SYSTEMS (UAS) meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 919 (b)(2)requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UNMANNED AIRCRAFT SYSTEMS (UAS)'s, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previouslyissued exemptions to this regulation in Exemption Nos. 8607,8737, 8738,9299,9299A,9565,9565B,and 10167,

maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore,an equivalent level ofsafety will be achieved.

7.There is no requestto exercise the privileges ofyour exemption outside the United States.

Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of gt•anting "blanket" COAs to applicants requesting exemptions from the Federal Aviation Regulations under Section 333 of the FAA Modernization and Reform Actof2012.
The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth in https:J/www.faa.gov/news/updates/?newsId=82245 upon approval ofUASI's exemption request

Respectfully submitted,

Richard Alvarado