Sabrina Natalia Casas

Sabrina Casas Studio

26527 Marble Point Ln,

Katy, TX, 77494

October 17, 2015

U.S. Department of Transportation

Docket Management System 1200

New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 

CFR 91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 

CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Sabrina 

Natalia Casas and Emilio Fernando Castro, owners of Sabrina Casas Studio, hereby applies for an

exemption from the listed Federal Aviation Regulations to allow commercial operation of a small UAS, so

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, for all operators of small Unmanned Aerial Systems

(UAS) working for Sabrina Casas Studio.

Commercial operation small UAS, as described herein, which are equipped with cameras and sensors,

would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, and cinematography.

3. Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

4. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

As described fully below, the requested exemption would permit the operation of small UAS under

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using conventional

aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation's (the FAA Administrator's) responsibilities to " .... establish requirements for the safe
operation of such aircraft systems in the national airspace system."

The name, phone, email and address of the applicant:

Name: Sabrina Casas Studio and Emilio Fernando Castro

Phone: (281) 665 3868

Email: photo@sabrinacasasstudio.com

Address: 26527 Marble Point Ln,

Katy, TX 77494

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113(a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

The small UAS's we will be using are multi-rotor craft weighing no more than 55lbs. including payload.

Under normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and have the

ability hover and move along a vertical and horizontal plane simultaneously. They will operate in line of

sight only and by the exempted persons only obeying all other local and federal laws.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will

further enhance the safety of the persons and/or property using conventional aircraft. These limitations 

and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The small UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated

at 20% battery power reserve or 20 minutes of flight time whichever occurs first.

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and

not more than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC) and the

Visual Observer (VO), who will also act as Camera Operator.

6. A briefing will be performed regarding the planned small UAS operations prior to each day's

flight consisting of all the days' production activities.

7. The PIC will obtain verbal/written consent of all persons involved with the planned operation
and ensure that only consenting persons will be allowed within 30 feet of the flight operation.

8. The PIC and VO will have been trained in operation of small UAS and receive up-to-date

information for the particular small UAS to be operated as per the guidelines of the manufacturer.

9. The PIC and VO will be able to communicate by voice at all times.

10. If the small UAS loses communications or loses GPS signal, the small UAS will have the

capability to return to a pre-determined location within a designated location and land

autonomously.

11. The small UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 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

small UAS. In all cases, an analysis of these criteria demonstrates that the small UAS operated without

an airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The small UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and under the requirements and in compliance with 

local public safety requirements.

These safety enhancements provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21,

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to

national security posed by the small UAS, due to its size, speed of operation, location of operation, lack

of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the

small UAS will have no entrance to the cabin, cockpit or pilot station on which the word " Experimental"

can be placed. Given the size of the small UAS, two-inch lettering will be impossible. The word

"Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of

safety will be provided by having the small UAS marked on its fuselage as required by §45.29 (f) where

the pilot, observer and others working with the small UAS will see the identification of the small UAS as
"Experimental"

14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in

command of an aircraft that is carrying passengers or property for compensation or hire. Our small UAS

do not carry any pilots or passengers nor property therefore we are seeking an exemption to 14 CFR

61.113(a). Although helpful, a pilot's license will not ensure remote control piloting skills. The risks

attendant to the operation of small UAS is far less than the risk levels inherent in the commercial

activities outlined in 14 CFR 61. We feel the operation and limitations set forth in the FOM will equate to

the safe operation of the small UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for

maintenance and use of safety checklists prior to each flight an equivalent level of safety will be

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material,

markings, and placards, or any combination thereof. The small UAS, given its size and configuration has

no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on

board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent

level of safety will be maintained by keeping the flight manual at the ground control point where the

pilot flying the small UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption

will be needed. The operator and/or PIC will take all actions including reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that

is being used for flight instruction unless that aircraft has fully functioning dual controls. Small UAS and

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that communicates with the aircraft via radio

communications. The FAA has approved exemptions for flight training without fully functional dual

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the

size and speed of the aircraft.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption
is for a small UAS that is a helicopter and the exemption requests authority to operate at altitudes up to

400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption

may be needed to allow such operations.

As set forth herein, the small UAS will never operate at higher than 400 AGL with the exception that in 

circumstances where the small UAS is used to survey or photograph a structure whose height exceeds 

400 feet AGL, the small UAS will not be operated more than 100' above the highest point on the 

structure. It will however be operated in a restricted area where buildings and people will not be 

exposed to operations without their pre-obtained consent. The equivalent level of safety will be 

achieved given the size, weight, speed of the small UAS as well as the location where it is operated. No 

flight will be taken without the permission of the property owner or local officials.

Because of the advance notice to the property owner and participants in the filming activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the small 

UAS will ensure separation between these small- UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to

an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting

available before departure." As the small UAS may not have a barometric altimeter, but instead a GPS

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the

launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least

30 minutes; or {2} At night, to fly after that for at least 45 minutes. " The battery powering the small UAS

provides approximately 20 to 30 minutes of powered flight. To meet the 30 minute reserve requirement 

in 14 CFR §91.151, small UAS flights would be limited to approximately 10 minutes in length or less. 

Given the limitations on the small UAS's proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is 

reasonable.

Applicant believes that an exemption from 14 CFR §91.151{a) falls within the scope of prior exemptions.

Operating the small UAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does

not engender the type of risks that Section 91.151{a) was intended to alleviate given the size and speed

of the small UAS. Additionally, limiting small UAS flights to 10 minutes or less would greatly reduce the 

utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 20 minutes or 20% of battery power- whichever happens first. This

restriction would be more than adequate to return the small UAS to its planned landing zone from

anywhere in its limited operating area.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate 

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at

the cabin or cockpit entrance so that it is legible to passengers or crew. 

The small UAS fully loaded weighs no more than 55 lbs. and is operated without an on board pilot. As

such, there is no ability or place to carry certification and registration documents or to display them on

the small UAS. An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the small UAS will have immediate access to them; to the extent 

they are applicable to the small UAS.

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

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," 

and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the

applicant.

Maintenance will be accomplished by the operator pursuant to the flight manual and operating 

handbook. An equivalent level of safety will be achieved because these small UASs are very

limited in size and will carry a small payload and operate only in restricted areas for limited periods of

time. If mechanical issues arise the small UAS can land immediately and will be operating from no higher

than 400 feet AGL. The operator will ensure that the small UAS is in working order prior to initiating

flight and perform required maintenance. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level 

of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in

accordance with the small UAS Manufacturer's Manual. As provided in the FOM, the operator will 

ensure that the small UAS is in working order prior to initiating flight and perform required maintenance 

needed. 

Small UAS Information

Small UAS's to be used are as follows but not limited to providing they are within the scope of the

exemption granted by the FAA: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 UASs.

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The 

DJI Phantom 2, DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 11 ounces, while 

having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of 

approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length 

of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 

knots. The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 UAs are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors
Conclusion

Given the small size of the small UAS and the controlled environment provided, the proposed operations

will adhere to the Reform Act's safety requirements. The approval of this application presents no

national security issues. Regarding the level of safety surrounding the proposed operations and the

public benefit, reduction in environmental impacts, including but not limited to reduced emissions and

noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests

that the FAA grant the requested exemption with minimum delay.

Thank you for the consideration of these exemptions.

Sincerely,

Sabrina Natalia Casas & Emilio Fernando Castro

Owner I Operators

Sabrina Casas Studio