September 17, 2015

Exemption No. 12902

Regulatory Docket No. FAA−2015−2686

Mr. Alejandro Araya

dba AA FLYDRONESFL LLC

5900 NE 2 Terrace

Oakland Park, FL 33334

Dear Mr. Araya:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated June 1, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Mr. Alejandro Araya dba AA FLYDRONESFL LLC (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct photography, surveying, and videography for real estate, construction, and 

utility inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a 3D Robotics Solo.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Alejandro Araya dba AA FLYDRONESFL LLC is 

granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and 

(2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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perform aerial data collection. This exemption is subject to the conditions and limitations 

listed below.

Conditions and Limitations

In this grant of exemption, Mr. Alejandro Araya dba AA FLYDRONESFL LLC is hereafter 

referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the 3DRobotics Solo

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
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documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
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government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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June 1, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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

Part 11 of the Federal I Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 C.F.R. Part 11, Alejandro Araya dba AA FLYDRONESFL.llc, 

the operator of small Unmanned Aircraft Systems ("sUAS"), seeks an exemption 

from the Federal Aviation Regulations ("FARs") listed below and discussed in 

Appendix A. Attached as Appendix B is a summary of this request.

The requested exemption would permit commercial operation of Alejandro Araya dba 

AA FLYDRONESFL sUAS's, which weigh approximately 10 lbs. And performs 

aerial surveys and videography that consists of still photographs and 

videography taken by on board cameras. The sUAS's takes a series of high 

quality, still digital images and video that are used to promote real estate sales

and survey in South Florida. Additional aerial inspections/survey applications 

may include construction jobsite monitoring, pipeline inspection and precision 

topological surveys. Use of the sUAS for aerial inspections and surveys reduce 

the need to utilize conventional manned aircraft, manned lifting devices or 

manned climbing for the same purpose and provides very high quality imagery at 

a fraction of the cost. These savings result in enhanced safety, efficiency and 

productivity for the affected activities, as well as environmental benefits.

Operations under the exemption will be subject to strict operating requirements 

and conditions to ensure at least an equivalent level of safety to currently

authorized operations using manned aircraft and under conditions as may be 

modified by the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize 

commercial operations of aerial photos and inspections or surveys using the 

sUAS's, which weigh less than 10 lbs. and are small in size. (See attached O&M 
2

manuals for the 3DR SOLO). The sUAS's will be operated under controlled 

conditions at low altitude in airspace that is limited in scope, as described more 

fully herein; it will have automated control features as described

below and in the O&M manuals. The sUAS also will be operated by an individual 

who has FAA Private Pilot License. Finally, the airspace in which the sUAS will 

operate will be Class G airspace or airspace approved by the FAA in

advance.

Alejandro Araya dba AA FLYDRONESFL respectfully submits that because these 

small, unmanned aerial vehicles will be used in lieu of comparatively hazardous 

operations now conducted with fixed wing and rotary conventional aircraft or 

other manned means of inspections, the FAA can have confidence that the 

operations will achieve at least the equivalent level or greater level of safety. 

Approval of the exemptions would thereby enhance safety and fulfill the 

Secretary of Transportation's (the FAA Administrator's) responsibilities under 

Section 333(c) of the Reform Act to "establish requirements for the safe operation 

of such aircraft systems in the national airspace system."

The name and address of the applicant are:

Alejandro Araya dba AA FLYDRONESFL 

Att: Alejandro Araya

Ph: 954-661-7469

Email: alexawl@bellsouth.net

Address: 5900 NE 2 Terr

 Oakland Park, FL 33334

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133 (a);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14C.F.R. 91.109(a);

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);
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14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2};

14 C.F.R. 91.417(a) & (b).

Appendix A discusses each rule listed above and explains why exemptions 

pursuant to the proposal set forth in this letter are appropriate, provide an 

equivalent level of safety, and are in the public interest.

The Applicable Legal Standard under Section 333

Alejandro Araya dba AA FLYDRONESFL submits that grant of this exemption 

application for use of the proposed UAS's in precision aerial inspections will 

advance the Congressional mandate in Section 333 of the Reform Act to 

accelerate the introduction of UASs into the national airspace system ("NAS") if it 

can be accomplished safely. This law directs the Secretary of Transportation to 

consider whether certain UASs may operate safely in the NAS before completion 

of the rulemaking required under the Section 332 of the Reform Act. In making 

this determination, the Secretary is required to determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national 

security in the light of the following:

• The UAS's size, weight, speed and operational capability;

• Operation of the sUAS in closed proximity to airports and populated 

areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act §333{a)(1). If the Secretary determines that such vehicles "may

operate safely in the national airspace system, the Secretary shall establish 

requirement for the safe operation of such aircraft in the national airspace 

system." ld. §333(c) (emphasis added). 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil 

aircraft, as the term is defined under §40101 of the Act, from the requirement that 

all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from. a requirement of a regulation
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prescribed under subsection (a) or (b) of this section or any of the sections 

44702-44716 of this title if the Administrator finds the exemption is in the public 

interest.

Applicant submits that this provision places a duty on the Administrator to not 

only process applications for exemptions under Section 333, but for the 

Administrator, if he deems the conditions proposed herein require modification in 

order to allow approval, to supply conditions for the safe operation of UAS. Todd 

Thomas dba Drone Pies welcomes the opportunity to consult with FAA staff in 

order to address any issues or concerns that this proposal may raise that they

believe may require modification.

49 U.S.C. §44701(f). See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. 

§91.203(a)(1). 

The grant of the requested exemption is in the public interest based on the clear 

direction in Section 333 of the Reform Act; the additional authority in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations; and the significant public benefit, including enhanced 

safety and cost savings associated with transitioning to UASs for aerial 

inspections and survey photography and real estate photography. Accordingly, 

the applicant respectfully requests that the FAA grant the requested

exemption without delay.

Airworthiness of the sUAS

A critical element of the exemption application involves evidence of the 

airworthiness of the sUAS. The Federal Aviation Act (49 U.S. C. §44701 (f) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

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

areas of the particular sUAS. Our small UAS's will operate at low speed in a

controlled environment, at least five miles from an airport or densely populated 

area. An analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be a least as safe, or safer, than a conventional aircraft (fixed wing 

or helicopter) operating with an airworthiness certificate without the restrictions 

and conditions proposed.

Mandatory Operating Conditions (see O&M and Safety lists)
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Grant of the exemption to Alejandro Araya dba AA FLY DRONESFL will be subject 

to the following mandatory conditions, which are based upon operating 

conditions set forth for operation of sUAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to avoid congested or populated areas, which are depicted 

in yellow on VFR charts.

• Operations to be conducted over private or controlled-access property.

• Permission from land owner/controller required before commencing 

flight.

• Operations to occur during Visual Flight Rules Meteorological 

Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS). 

VLOS guaranteed with a cylinder of operation around operator of 1⁄2 

nautical miles (NM).

Cylinder walls may be expanded by observer with ability to control 

aircraft.

• Operations to occur during daylight hours.

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 

NM from

• centerline azimuth of runway centerline measured from runway 

thresholds

• All required permissions and permits will be obtained from territorial, 

state, county or city jurisdictions, including local law enforcement, fire, 

or other appropriate governmental agencies. 

Operator Requirements

Alejandro Araya dba AA FLYDRONESFL respectfully purposes that operator 

requirements should take into account the characteristics of the particular UAS. 

Certain UASs, such as the 3DR SOLO are characterized by a high degree of 

control and various built-in technical capabilities that limit the potential for 

operation outside of the operating conditions set forth above. Please see details 

in the attached O&M manuals.

Additional automated safety functions and safety enhancing features of the 

sUAS's include the following:
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• Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate return to aircraft take-off location ("home").

• Low power on the aircraft triggers escalating alarms at GCS.

• If the auto-pilot detects a lost-link to the GCS, landing procedure begins.

• Pause Button

• The Pause button/Panic, will freeze Solo mid-air and hover until given 

another command. This can be useful to stop Solo from hitting an 

obstacle or to re-orient Solo for navigation

Given these safety features, Alejandro Araya dba AA FLYDRONESFL proposes 

that operators of the sUAS should not be required to hold a commercial pilot 

certification. Instead, operators should be required to:

• Hold a private pilot license.

• Have completed the manufacturer's training program for operation of 

the sUAS's.

Alejandro Araya dba AA FLYDRONESFL notes that the FAA has found that safety

factors permitted operation of sUASs by operators with these qualifications in the 

case of operations pursuant to public COAs when the mandatory operating 

conditions specified above were present. See Federal Aviation Administration, 

Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 

20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to 

the requirements for and privileges associated with the grant of airmen's

certificates. 49 USC §44701 (f).

* * *

In summary, applicant seeks an exemption from the FARs set forth above in 

Appendix A to allow commercial operations of a sUAS's conducting precision 

aerial inspections or surveys and real estate photos.

Approval of the exemption allowing commercial operations of the sUAS for 

precision inspection, survey work, and real estate photos will enhance safety by

reducing risk. Conventional aerial inspection, survey operations, and real estate 

photos, using jet or piston powered aircraft present risks associated with 

vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry

large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft 

must fly to and from the survey location. Other conventional manned climbing or

manned lifts risk safety hazards associated with falls, electrical hazards, fuel 

related hazards, and inhalation associated with the structures being inspected. In

contrast, a sUAS weighing less than 15 lbs. and powered by batteries eliminates a 
7

portion of that risk given the reduced mass and lack of combustible fuel carried 

on board a manned aircraft and the lack of risks associated with manned lifts or 

manned climbing apparatus. The sUAS will carry no passengers or crew

and, therefore; will not expose any individuals to the risks associated with 

manned aircraft flights, manned lifts or climbing hazards. 

Additionally, no national security issue is raised by the grant of the requested 

exemptions. Given the size, load carrying capacity, speed at which it operates, 

and the fact that it carries no explosives or other dangerous materials, the sUAS 

poses no threat to national security. 

The operation of the sUAS, weighing less than 15 lbs ., for inspections, surveys, 

and real estate photos in accordance with the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting Alejandro Araya dba AA FLY DRONESFL

from the requirements of Part 21.

The sUAS's satisfaction of the criteria set forth in Section 333 of the Reform Actsize, weight, speed, operating capabilities, lack of proximity to airports and 

populated areas, operation within visual line of sight, and national security-and 

it’s showing of an equivalent level of safety as it may relate to the requirement for 

FAA training, provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of the sUAS in the

commercial aerial inspection, survey, and real estate photo business.

Very truly yours,

Alejandro Araya

Owner

AA FLYDRONESFL

Enclosures:

Appendix A: Exemption Request and Equivalent Level of Safety Showings under

Applicable Rules Subject to Exemption

Appendix B: Operation and Maintenance Manuals:

3DR SOLO Manual

Appendix C: Safety Checklists