June 1, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

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

Act of 2012

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of

2012 (the “Reform Act”) and the procedures contained in 14 C.F.R. 11,

to request that Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day, the owners and operators of a small unmanned

aircraft, be exempted from the Federal Aviation Regulations (“FARs”)

listed below so that Manuel Lopez & Nicolas Soro, Sellers Door LLC,

d/b/a Drone of the Day, may operate their small unmanned aircraft /

lightweight unmanned aircraft systems (“UAS”) commercially in

airspace regulated by the Federal Aviation Administration (“FAA”); as

long as such operations are conducted within and under the conditions

outlined herein or as may be established by the FAA as required by

Section 333. The conditions identified and proposed by the applicant

are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8 – Issue a

Certificate of Waiver for Motion Picture and Television Filming.

As identified and described herein, Manuel Lopez & Nicolas Soro,

Sellers Door LLC, d/b/a Drone of the Day, are experienced and

recognized in the marketing media industry. Manuel Lopez & Nicolas

Soro have been providing marketing recreational media for the aerial

photography and cinematography industry for the past two years.

Manuel Lopez & Nicolas Soro have also been devoted and responsible

unmanned aerial vehicle, and/or drone, operators and photographers

for over 2 years with over 250 hours of combined operating time.

Manuel Lopez & Nicolas Soro own and operate various social media

accounts and websites consisting and in relation to unmanned aerial

vehicle, and/or drone, photography and cinematography, and have

been approached by many new potential clients pursuing to engage

their marketing media services. Manuel Lopez & Nicolas Soro, Sellers

Door LLC, d/b/a Drone of the Day, also promote the unmanned aerial

vehicle, and/or drone, photography and cinematography through their

social media accounts and website. As of June 10, 2015, Manuel Lopez

& Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day, have been

able to gather a following of over 25,000 unmanned aerial vehicle,
and/or drone, photography and cinematography enthusiasts and are

currently averaging over 4,000 visits to their unmanned aerial vehicle,

and/or drone, photography and cinematography website per week. 

Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of

the Day have been actively involved in the promotion of aerial

cinematography and photography with small, unmanned aircraft and

lightweight UASs. Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day have equipped their small unmanned aircraft for the

purpose of aerial photography and cinematography, primarily for use

in marketing materials and television broadcast, though given their

stability and maneuverability, they may be used for other

cinematography and photography, by law enforcement personnel,

search and rescue and by other first responders. 

To date, Manuel Lopez & Nicolas Soro have rejected all offers to

work with commercial television production companies, real estate

firms on locations within the United States, and private freelance offers

from customers, to ensure they are in compliance with any applicable

FARs. They, like other applicants, have done so despite Judge Patrick

G. Geraghty’s decision in the Raphael Priker matter and his reasoning

that no FARs prohibits the use of small-unmanned aircraft or

lightweight UASs like those flown by other peer companies. 

Manuel Lopez & Nicolas Soro’s exemption request would permit

the operation of lightweight, unmanned (remotely controlled in line of

sight) UASs in tightly controlled and limited airspace. Predetermined,

specifically marked areas of operation, cordoned off locations and

corresponding enhancements to current safety controls will allow

Manuel Lopez & Nicolas Soro to operate within current safety

parameters, and new ones, as they’re being implemented. Let it be

known, similar lightweight remote controlled UASs are legally operated

by amateurs with no flight experience, safety plan, or controls in place

to prevent catastrophe. Manuel Lopez & Nicolas Soro, Sellers Door

LLC, d/b/a Drone of the Day, will monitor, evaluate, and implement all

aerial photography and cinematography activities with a pre-flight

safety and flight plan system. This will act to further safety protocols

exclusive to lightweight UAS’s specific to landscape and real estate

video and photography usage, as Manuel Lopez & Nicolas Soro record

flight data and other information gained through permitted flight

operations to share with the FAA through any required FAA reports to

assist with future protocol and safety regulations.

Granting Manuel Lopez & Nicolas Soro’s request comports with

the Secretary of Transportation’s (FAA Administrator) responsibilities to
not only integrate UASs into the nation airspace system, but to “. . .

establish requirements for the safe operation of such aircraft systems

[UASs] in the national airspace system” under Section 333(c) of the

Reform Act. Further, Manuel Lopez & Nicolas Soro, Sellers Door LLC,

will conduct its operations in compliance with the protocols described

herein or as otherwise established by the FAA.

Manuel Lopez & Nicolas Soro, Sellers Door LLC, respectfully

request the grant of an exemption allowing it to operate lightweight,

remote controlled UAS’s.

Name and Address of the Petitioners:

Manuel Lopez 

8931 SW 114th Street

Miami, Florida 33176

(305) 796-5314

droneoftheday@gmail.com

Nicolas Soro

1268 Partridge Avenue

Miami, Florida 33166

(786) 395-2486

droneoftheday@gmail.com

The Specific Sections of Title 14 of the Code of Federal 

Regulations, Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a 

Drone of the Day Requests Exemption are:

14 CFR 21; 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)

Exemption Request Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 

21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 

91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 

91.409(a)(2); 91.417(a) & (b).

The Extent of Relief Manuel Lopez & Nicolas Soro, Sellers Door 

LLC, d/b/a Drone of the Day Seeks and the Reason it Seeks 

Such Relief:

Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day,

submit this application in accordance with the Reform Act, 112 P.L. 95

§§ 331-334, seeking relief from any currently applicable FARs operating

to prevent Manuel Lopez & Nicolas Soro from pursuing contemplated
commercial cinematic, academic, research, and other flight operations

within the national airspace system. The Reform Act in Section 332

provides for such integration of civil unmanned aircraft systems into

our national airspace system as it is in the publics interest to do so.

The DJI Phantom 3 Professional quadcopter drone, operated by Manuel

Lopez & Nicolas Soro, is an ultra light weight UAS and meets the

definition of “small unmanned aircraft” as defined in Section 331;

therefore, the integration of Manuel Lopez & Nicolas Soro’s ultra

lightweight UAS is expressly contemplated by the Reform Act. Manuel

Lopez & Nicolas Soro would like to operate their ultra-lightweight UAS

prior to the time period by which the Reform Act requires the FAA to

proclaim rules governing such craft. Thereby, providing direct

experience and valuable information for formal regulation that can be

administered uniformly to all real estate and media marketing related

UAS aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS’s

that may operate safely in our national airspace system.

Considerations include: weight, size, speed, and overall capability of

the UAS’s; whether the UAS will be operated near airports or heavily

populated areas; and whether the UAS will be operated by line of sight.

112 P.L. 95 § 333(a). Each of these items reflects in favor of an

exemption for Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day. 

Manuel Lopez & Nicolas Soro’s UAS utilizes four (4) counter-rotating

propellers for extreme balance, control, and stability. The UAS is

equipped with a 3-axis gimbal that has a 4k camera mounted on and

has a unique beginner mode, which allows an operator to fly the UAS

within a limited distance and altitude from the operator, protecting the

UAS and operator and making the UAS stay inside the operators

desired limits. Manuel Lopez & Nicolas Soro’s UAS is also equipped with

DJI Lightbridge image transmission technology that is used by

professional cinematographers and photographers allowing the

operator to view the drones first person point of view adding to even

safer flying and operating of the UAS. Manuel Lopez & Nicolas Soro’s

UAS weighs less than ten (10) pounds (well below the maximum 55

pound limit), including the camera with gimbal. 

Manuel Lopez & Nicolas Soro consider safety as foremost important

factor with each flight. The small-unmanned aircraft is designed to

hover in place via GPS, and vision technology, and is operated in less

than 24 knot wind. For safety, stability, and fear of financial loss

Manuel Lopez & Nicolas Soro will not fly in winds exceeding 16 knots or

10 miles per hour. Built in safety systems in the UAS include a GPS

mode that allows the UAS to hover in place when radio control inputs
are released. With three modes to choose from, Manuel Lopez &

Nicolas Soro utilizes the Smart Mode1 for aerial

videography/photography. This is the safest, most reliable and stable

mode to prevent an accident and hazard. When pilot communication is

lost, the UAS is designed to slowly descend to the point of take off via a

return to home location (RTH) option which is set before every flight.

In addition to the remote control pilot, Manuel Lopez & Nicolas Soro

use a spotter, such that, at a minimum, two (2) personnel govern the

safe flight of the UAS, and/or drone. 

Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day,

do not operate their UAS near airports, hospitals, police heliports, or

any areas where the general public is within fifty to one hundred (50-

100) yards depending on location, conditions, and weather. The UAS

operating software and GPS navigation systems do not allow Manuel

Lopez & Nicolas Soro’s UAS to operate near airports or restricted fly

zones. The failsafe software will disable the UAS from taking off and

also limit the UAS systems from operating within specific GPS preset

no-fly zones. Manuel Lopez & Nicolas Soro are constantly on alert for

any manned aircraft (police, medical, helicopters, etc.) and prepared to

land/abort immediately to the nearest and safest ground point should a

manned aircraft approach the location or Manuel Lopez & Nicolas Soro,

Sellers Door LLC, d/b/a Drone of the Day, believe that a manned

aircraft may approach near the location. The UAS is capable of vertical

and horizontal operations, and are flown only within line of sight, as the

remote control pilot. Utilizing batter power rather than combustible

fuels, flights generally last between eighteen (18) and twenty (20)

minutes, with an altitude under one hundred and fifty (150) feet.

Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day,

utilize a fresh fully charged battery with each flight as a safety

precaution; full flight time limit for each battery is eighteen (18) to

twenty (20) minutes as tested. Manuel Lopez & Nicolas Soro, Sellers

Door LLC, d/b/a Drone of the Day, will not operate the UAS at or below

manufacturer recommended minimum charge levels for operation,

preferring to remain well within a safe operating range to insure

adequate communication 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. Manuel Lopez & Nicolas Soro are risk averse and do not

believe in taking risks that may cause a crash that could create hazard

1 Smart Mode includes GPS Geofence radius for operation, position 

hold, self-leveling, altitude command, return home feature or land in 

the event of communication interruption between RC transmitter and 

UAS. See Appendix A.
to the public, property, and/or manned aircraft. Manuel Lopez &

Nicolas Soro have clocked over 250+ hours of hobby level recreational

flights for hopes of future commercial use to gain familiarization with

the characteristics of this specific UAS’s performance under different

temperature and weather conditions. Manuel Lopez & Nicolas Soro are

extremely cautious when operating their UAS/ ultra-lightweight

unmanned aircraft and will not “create a hazard to users of the

national airspace system or the public.” 112 P.L. 95 § 333(b). Given

the small size and weight of the UAS, it falls well within Congress’s

contemplated safety zone when it promulgated the Reform Act and the

corresponding directive to integrate UAS’s into the national airspace

system. The UAS, used in hobby flight, has a demonstrable safety

record and does not pose any threat to the general public or national

security.

How Manuel Lopez & Nicolas Soro’s Request Will Benefit the 

General Public

Granting Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of

the Day, exemption request furthers the public interest. Manuel Lopez

& Nicolas Soro own and operate various social media accounts and

websites consisting and in relation to unmanned aerial vehicle, and/or

drone, photography and cinematography, and have been approached

by many new potential clients pursuing to engage their marketing

media services. Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day, also promote the unmanned aerial vehicle, and/or

drone, photography and cinematography through their social media

accounts and website. As of June 10, 2015, Manuel Lopez & Nicolas

Soro, Sellers Door LLC, d/b/a Drone of the Day, have been able to

gather a following of over 25,000 unmanned aerial vehicle, and/or

drone, photography and cinematography enthusiasts and are currently

averaging over 4,000 visits to their unmanned aerial vehicle, and/or

drone, photography and cinematography website per week. Manuel

Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day, also

want to promote FAA regulations and rules through their social media

marketing accounts, as well as their websites, to ensure other

recreational and professional UAS operators are practicing safe flights. 

Aerial photography and cinematography for real estate and personal

property marketing has been around for a long time through manned

fixed wing aircraft and helicopters. However, for small budget real

estate companies, average homeowners, and small videography

companies the expense of such aerial videography is cost prohibitive.

Only large companies and high end realtors or luxury homeowners can

afford to absorb such expenses. Accordingly, the majority of

homeowners and realtors are deprived from a valuable marketing tool.
Manned aircraft pose a threat to the public through potential

catastrophic crashes that the community has experienced in the past

with military, medical and news/tourism helicopter crashes within the

city of Miami, resulting in loss of life, and with combustible fuel that

exploded and burned on impact. The UAS’s operated by Manuel Lopez

& Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day, pose no such

threat because the size and lack of combustible fuel alleviates any

potential threat to the public. 

Congress has already proclaimed that it is in the public’s interest to

integrate commercially flown UAS’s into the national airspace system,

hence the passing of the Reform Act. Granting the exemption request

of Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the

Day, furthers the public interest through visual awareness of the

geographical benefits in and around the South Florida area and

promotes small business growth and competitiveness in the area.

Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day,

also have many social media followers, including UAS operators and

enthusiasts, from different locations among the United States. Manuel

Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day, believe

it will benefit the FAA to grant them the exemption under Section 333,

to lead by example and promoting UAS safety to their followers, fellow

drone enthusiasts, and the general public. Manuel Lopez & Nicolas

Soro, Sellers Door LLC, d/b/a Drone of the Day, will also be able to

provide additional jobs related to photography, videography, and

cinematography editing and shooting. The ultra lightweight UAS is

battery powered and creates no emissions that can harm the

environment. The consequence of the ultra lightweight UAS crashing is

far less than a full size helicopter or fixed wing aircraft; which are

heavy, contain combustible fuel and can cause catastrophic

devastation to the public. 

The public’s interest is furthered by minimizing ecological and crash

threats by permitting aerial video/photo capture through a battery

operated ultra lightweight UAS. Permitting Manuel Lopez & Nicolas

Soro, Sellers Door LLC, d/b/a Drone of the Day, to immediately fly

within national air space furthers economic growth. Granting our

exemption request substantially furthers the economic impact for the

South Florida community for companies looking to relocate or build in

the South Florida area as well as individuals looking to relocate for

career advancement. Granting the exemption serves as a stimulus to

the community.

Reasons Why Manuel Lopez & Nicolas Soro, Sellers Door LLC, 

d/b/a Drone of the Day Exemption Will Not Adversely Effect 
Safety and How the Exemption Will Provide a Level of Safety at

Least Equal to the Existing Rule:

The exemption for Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day will not adversely affect safety. Quite the contrary,

for the reasons stated Manuel Lopez & Nicolas Soro will be allowed to

log more flight time in FAA controlled airspace, with communication

with the FAA, allowing Manuel Lopez & Nicolas Soro, Sellers Door LLC,

d/b/a Drone of the Day, to contribute to the innovation and

implementation of new and novel, as of yet undiscovered safety

protocols for UAS pilots that can be embraced for development in

cooperating with the FAA. In addition, Manuel Lopez & Nicolas Soro

submits the following representations of enhancements to current

aerial videography and photography:

 Manuel Lopez & Nicolas Soro’s UAS weighs less than 10 pounds 

complete with a small ultra light weight high definition camera;

 Manuel Lopez & Nicolas Soro’s UAS is operated below 300 feet 

(well within the 400 ft. permissible ceiling set by the FAA 

Modernization and Reform Act of 2012);

 Manuel Lopez & Nicolas Soro’s UAS is only operated for 18-20 

minutes per flight;

 Manuel Lopez & Nicolas Soro’s UAS is landed prior to 

manufacturer recommended minimum level of battery power;

 Manuel Lopez & Nicolas Soro’s UAS is piloted through remote 

control by line of sight;

 Manuel Lopez & Nicolas Soro’s remote control pilots have video 

backup should they somehow lose sight of the UAS;

 Manuel Lopez & Nicolas Soro’s UAS has a GPS and flight safety 

feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost;

 Manuel Lopez & Nicolas Soro’s flight data is actively analyzed to 

constantly update and enhance safety protocols;

 Manuel Lopez & Nicolas Soro’s UAS is operated only in a 

reasonably safe environment that is strictly controlled and away 

from power lines, elevated lights, airports, and actively 

populated areas;

 Manuel Lopez & Nicolas Soro perform extensive pre-flight 

inspections and protocols are conducted;

 Manuel Lopez & Nicolas Soro obtain permission prior to operating

 Manuel Lopez & Nicolas Soro have procedures in place to abort 

flights in the event of safety breaches or potential danger

 Manuel Lopez & Nicolas Soro's equipment currently operates on

radio frequency 2.400 GHz-2.483 GHz.
The safety protocols implemented by Manuel Lopez & Nicolas Soro,

Sellers Door LLC, d/b/a Drone of the Day, provide a level of safety

equal to or exceeding existing rules. It is important to note that absent

the integration of commercial UAS into our national airspace system,

helicopters are the primary means of aerial video and photography for

community awareness and marketing of real estate, aerial

photography and cinematography, and personal property. While the

safety record of such helicopters is remarkably astounding, there has

been local incident involving loss of life as well as extensive property

damage; it is far safer for the general public, to operate a battery

powered ultra lightweight UAS instead of a helicopter or plane.

First, the potential loss of life is diminished because UAS’s carry no

people on board and only operate in specific areas away from mass

populations. Second, there is no fuel on board a UAS and thus the

potential for fire or explosions is greatly diminished. Third, the small

size and extreme maneuverability of the UAS allows the pilot to

remotely avoid hazards quickly and safely. Finally, given its small size

and weight, even when close enough to capture amazing images, the

UAS need not be so close to the objects they are focused on through

the technology and use of post editing software allowing pan and

zoom.

Accordingly Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone

of the Day, have operated the UAS experimentally for

familiarization/competency and will continue to operate at and above

current safety levels.

A Summary the FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 & 14 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 Manuel Lopez & Nicolas Soro, Sellers Door LLC,

d/b/a Drone of the Day’s UAS permits exemption from Part 21 because

the 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 (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 the weight,

size, speed, maneuverability and proximity to areas such as airports
and dense populations. Manuel Lopez & Nicolas Soro, Sellers Door LLC,

d/b/a Drone of the Day’s current and projected UASs’ meet and exceed

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. 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

UAS, this regulation is inapplicable. An equivalent level of safety will be

achieved by maintaining a safety/flight manual delineating areas of

where safety can be defined.2 The FAA has previously issued

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738,

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. 91.121 regarding altimeter settings inapplicable insofar as the

UAS utilizes electronic global positions systems with barometric sensor.

14 C.F.R. 91.203(a) and (b) provides for the carrying of civil aircraft

certifications and registrations. They are inapplicable for the same

reasons described above. The equivalent level of safety will be

achieved by maintaining any such required certifications and

registrations by Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day.

B. 14 C.F.R. § 45.23: Marking the Aircraft

Applicable codes of federal regulation require aircraft to be marked

according to certain specifications. The UAS operated by Manuel Lopez

& Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day, is by

definition, unmanned. The UAS does not have a cabin, cockpit or pilot

station on which to mark certain words or phrases. Further, two-inch

letters is difficult to place on such small aircraft with dimensions

smaller than the minimal lettering requirement. Regardless, Manuel

Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day will

mark its UASs in the largest possible lettering by placing the word

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29(f) so

that the pilot, or anyone assisting the pilot as a spotter with the UAV

will see the markings. The FAA previously issued exemptions to this

regulation through Exemptions Nos. 8738, 10167, 10167A, and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC

2 Appendix ___ - Safety/Flight Manual
Pursuant to 14 C.F.R. §§ 61.113(a) & (b), private pilots are limited to

non-commercial operations Manuel Lopez & Nicolas Soro, Sellers Door

LLC, d/b/a Drone of the Day, can achieve an equivalent level of safety

as achieved by current regulations because its UAS does not carry any

pilots or passengers. Further, while helpful, a pilot license will not

ensure remote control piloting skills. The risks related to the operation

of the UAS is far less than the risk levels inherent in the commercial

activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing Manuel Lopez

& Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day to operate its

UAS to meet and exceed current safety levels in relation to 14 C.F.R. §§

61.113(a) & (b).

D. 14 C.F.R. § 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil

aircraft. It allows helicopters to be operated at lower altitudes in

certain conditions. The UAS will never operate at an altitude greater

than 300 AGL; safely below the standard of 400 AGL. Manuel Lopez &

Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day will however,

operate its UAS in safe areas away from public and traffic, 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 its UAS, an equivalent or higher level of safety will be

achieved.

E. 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 aircraft inspected as prescribed in

subpart E of this part and shall between required inspection, except as

provided in paragraph (c) of this section, have discrepancies repaired

as prescribed in part 43 of this chapter . . ..”

These regulations only apply to aircraft with an airworthiness

certificate. Therefore, they will not apply to Manuel Lopez & Nicolas

Soro, Sellers Door LLC, d/b/a Drone of the Day’s UAS. However, as a

safety precaution Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day inspects its UAS before and after each flight.

A summary the FAA May Publish in the Federal Register: 14 C.F.R. 21

and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14

C.F.R. 21, subpart H, entitled Airworthiness Certificates, sets forth

requirement for procurement of necessary airworthiness certificates in

relation to FAR § 91.203(a)(1). The size, weight, and enclosed

operations of its UAS permits exemption from Part 21, because Manuel
Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day’s UAS

meets 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 (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 weight, size, speed, maneuverability

and proximity to areas such as airports and dense populations. Manuel

Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of the Day’s UAS

meets or exceeds each of these elements. 14 C.F.R. § 91.7(a) prohibits

the operation of 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 pilots or

passengers, and given the size of the UAS, this regulation is

inapplicable. An equivalent level of safety will be achieved by

maintaining a manual. The FAA has previously issued exemptions to

this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A,

9565, 9565B, 10167, maintenance program that involves regular

software updates and curative measures for any damaged hardware.

Therefore, an equivalent level of safety will be achieved.

In summary, Manuel Lopez & Nicolas Soro, Sellers Door LLC, 

d/b/a Drone of the Day 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. 61.113(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 commercially operate

its small unmanned vehicle/lightweight unmanned aircraft vehicle to

promote community awareness and develop economic platforms and

marketing media for real estate and personal property owners,

marketing companies, and sales agents. It will enhance the South

Florida and the nations economy by providing and promoting safety

and new careers in the UAS industry. Currently, aerial

videography/photography relies primarily on the use of larger aircraft

running on combustible fuel which poses potential risk to the public.

Granting Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone of

the Day’s request for exemption will reduce current risk levels and

thereby enhance safety. Manuel Lopez & Nicolas Soro, Sellers Door

LLC, d/b/a Drone of the Day’s UAS does not contain or use potentially

explosive fuel, is smaller, lighter, and more maneuverable than

conventional video and photographic aircraft with much less flight

time. Furthermore, Manuel Lopez & Nicolas Soro, Sellers Door LLC,
d/b/a Drone of the Day operates at lower altitudes and in controlled

airspace eliminating potential public risk flying to and from established

air fields. Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a Drone

of the Day has been informally analyzing flight information and has

compiled safety protocols and implemented a flight operations manual

for UAS usage that exceeds currently accepted means and methods for

safe flight. Formal collection of information shared with the FAA will

enhance the FAA’s internal efforts to establish protocols for complying

with the FAA Modernization and Reform Act of 2012. There are no

personnel on board the UAS diminishing the likelihood of death or

serious bodily injury. Operation of the UAS, weighing less than 10

pounds and traveling at lower speeds within limited areas will provide

an equivalent level of safety as that achieved under current FARs.

Accordingly, Manuel Lopez & Nicolas Soro, Sellers Door LLC, d/b/a

Drone of the Day, respectfully requests that the FAA grant its

exemption request and agrees to cooperate in sharing information to

benefit the FAA, safety of manned aircraft, and the general public at

large.

Respectfully submitted,

 

Manuel Lopez & Nicolas Soro, 

Sellers Door LLC, d/b/a Drone of the Day.