Aviation First Consulting, LLC 

December 20, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition of Aviation First Consulting, LLC for Exemption from Certain Federal Aviation 

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of 

the FAA Modernization and Reform Act 

Dear Sir or Madam: 

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14C.F.R. part 11, 

Aviation First Consulting, LLC ("AFC") hereby petitions the Federal Aviation Administration ("FAA") for 

exemption from 14C.F.R. §§ 61.23(a) and (c), 61.10l(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119( c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), and any 

other rules the FAA deems necessary, to enable AFC to operate unmanned aircraft systems ("UAS") for 

aerial data collection. Specifically, AFC seeks to operate UAS for aerial photography, videography, search 

and rescue, training and accident investigation using the DJI Phantom 3. Because this petition is similar in 

all material respects to previously-granted Section 333 petitions, AFC requests expedited approval pursuant 

to the FAA's summary grant process. 

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS 

AFC is a minority owned aviation consulting company specializing in all aspects of aviation operations. 

AFC' s primary owner is a former FAA Aviation Safety Inspector with over 25 years of aviation experience. 

AFC is thoroughly familiar with the Federal Aviation Regulations as they pertain to U AS operations. AFC 

has over 5,000 hours of aircraft experience operating in the NAS with both fixed wing and hot air balloons. 

The objective of AFC aerial operations is the following: 

1. Special Event Coverage 

2. Aid Federal Authorities in aircraft accident investigations. 

3. Private and governmental training. 

4. Aerial photography and videography 

5. Search and rescue 

AFC will adhere to stringent operating conditions in conformance with past grants of exemption. These 

conditions ensure that AFC will operate safely in the national airspace, mitigate the risks of harming other 

aircraft or people or property on the ground, and present no threat to national security. Adhering to these 

parameters, AFC will be able to safely and effectively operate its UAS to the benefit of its clients and the 

general public. 

II. THE UAS 

AFC requests an exemption to operate the DJI Phantom 3, which is below 55 pounds including payload. 

Through the Section 333 exemption process, the FAA has previously authorized use of the aforementioned 

UAS for which exemption is requested herein. 

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30214 N 48th Place, Cave Creek, AZ 85331 
m. REQUEST FOR SUMMARY GRANT 

Because this petition is similar in material respects to previous petitions the FAA has granted, AFC requests 

that the FAA issue a summary grant of exemption pursuant to the agency's expedited summary grant 

process. Specifically, the public interest and safety benefits AFC's operations will achieve are materially 

similar to those recognized in previous Grants of Exemption Nos. 11062, 11109, 11112 and 13966. AFC 

will adhere to the same operating parameters and level of safety the FAA currently requires in its grants of 

exemptions. 

IV. APPLICANT INFORMATION 

The name and contact information of the applicant is: 

Mirlo E. Ochoa 

Owner, Aviation First Consulting, LLC 

30214 N 48th Place 

Cave Creek, AZ 85331 

14 C.F.R. §§ 61.23(a) and (c); 

14 C.F.R. §§ 61.101(e)(4) and (5); 

14 C.P.R.§ 61.113(a); 

14 C.F.R. § 61.315(a); 

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.121; 

14 C.P.R.§ 91.151(a)(l); 

14 C.F.R. § 91.405(a); 

14 C.P.R. § 91.407(a)(l); 

14 C.F.R. §§ 91.409(a)(l) and (2); 

14 C.F.R. §§ 91.417(a) and (b). 

V. OPERATING PARAMETERS 

AFC will adhere to the following operating parameters and any additional FAA requirements when 

operating UAS pursuant to a grant of the requested exemption: 

1. Operations will be conducted using the Dll Phantom 3. 

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour), at an altitude 

greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 

500 feet below or 2,000 feet horizontally from a cloud and during daylight conditions. 

3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization 

("CO A''). 

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the UAS 

will remain within the visual line of sight (VLOS) of the PIC or the VO at all times. The PIC will 

maintain VLOS capability and the ability to communicate verbally with the VO at all times. 

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30214 N 48th Place, Cave Creek_ AZ 85331 
V. OPERATING PARAMETERS (cont'd) 

5. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot certificate, 

as well as an FAA airman medical certificate or a valid U.S. driver's license. The PIC will meet 

the flight review requirements specified in 14 C.F .R. § 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate. 

6. AFC will ensure prior to operation that the PIC has demonstrated 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 will be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). 

7. AFC's operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. 

8. Prior to each flight, AFC will conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the UAS will not be operated until the necessary maintenance has been performed and the 

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

9. AFC will conduct all operations 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. If 

the UAS loses communications or loses its GPS signal, the UA will return to a pre-determined 

location within the private or controlled-access property 

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

characteristics, e.g., replacement of a flight critical component, will undergo a functional test 

flight prior to conducting further operations under this exemption. 

11. AFC will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and 

life limit requirements, as well as safety bulletins, for the aircraft and aircraft components. 

12. AFC will abort the flight in the event ofunpredicted obstacles or emergencies, and will yield to 

all manned aviation operations. 

13. AFC will not begin 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 5 minutes or with the reserve power recommended by the manufacturer if greater. 

14. AFC will register and mark its UAS in accordance with 14CFR part 47 and 14CFR part 45. 

VI. THE FAA'S AUffiORITY TO GRANT TIDS PETITION 

The FAA has authority to grant the exemption requested herein under the FMRA and the Federal Aviation 

Act. Section 333 of the FMRA deals specifically with integrating UAS into the national airspace, and directs 

the Secretary of Transportation to determine which UAS, "as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line of sight 

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30214 N 48fh Place, Cave Creek, AZ 85331 
' ' . 

VI. THE FAA'S AUTHORITY TO GRANT TIDS PETITION (coot' d) 

do not create a hazard to users of the national airspace system or the public or pose a threat to national 

security." Section 333 further directs the Secretary to "establish requirements for the safe operation of such 

aircraft systems in the national airspace system. The Federal Aviation Act authorizes the Administrator of 

the FAA to grant exemptions from regulations prescribed under certain provisions of the Act where such 

exemptions are in the public interest. Part 11 of the Federal Aviation Regulations governs the FAA's 

exemption process and requirements. The FAA has granted more than 1,100 exemptions to date pursuant 

to its Section 333 and exemption authority, enabling commercial UAS operations in a wide variety of 

industries. 

VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Should the FAA determine that publication in the Federal Register is required, AFC offers the following 

summary pursuant to section 11.81 of the FAA's rules: 

Petitioner: Aviation First Consulting, LLC 

Sections of 14 C. FR. Affected: 14C.F.R. 61.23(a) and (c); 14C.F.R. 61.101(e)(4) and (5); 14C.F.R. 

61.113(a); 14C.F.R. 61.315(a); 14C.F.R. 91.7(a); 14C.F.R. 91.119(c); 14C.F.R. 91.121; 14C.F.R. 

91.15l(a)(l); 14C.F.R. 91.405(a); 14C.F.R. 91.407(a)(l); 14C.F.R. 91.409(a)(l) and (2); 14 C.F.R. 

91.417(a) and (b). 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ 61.23(a) and 

(c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 

14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. §91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 

91.407(a)(1); 14 C.F.R. 91.409(a)(l) and (2); 14 C.F.R. 91.417(a) and (b) to operate unmanned aerial 

systems for aerial data collection, training, search and rescue and accident investigation. 

VIII. CONCLUSION 

As indicated above, granting this petition will further the public interest by allowing AFC to safely, 

efficiently and economically perform aerial video and photography of events, civic landscape and search 

and rescue over certain areas of the United States. In addition, the use of the Phantom 3 VAS will 

decrease congestion of the NAS, reduce pollution and provide significant benefits to the economy. 

AFC's petition satisfies the criteria of Section 333 of the FMRA and is substantially similar 

to previous petitions the FAA has granted, meriting a summary grant of exemption. AFC respectfully 

requests that the FAA grant this petition for exemption. 

Please contact me at 480-600-8004 or eddie@aviation-first.com with any questions about this filing. 

Sincerely, 

Mirlo E. Ochoa 

Owner 

Aviation First Consulting, LLC 

30214 N 48th Place, Cave Creek, AZ 85331 

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