Section 333 Exemption Petition

Mark W. Garza

Excelsior Springs, 

Missouri, 64024

Phone: 254-535-3329

Email: GarzaMW@yahoo.com

01/26/2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 CFR 407 (a) 

(1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 14 CFR Part 21; 14 CFR 45.23 (b); 14 CFR 

45.27 (a); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 

91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.203 (a) & (b); 14 CFR 

91.405 (a); 8900.227 §16 (c) (4) and §16 (e) (1)

Dear Sir or Madam, I, Mark W. Garza, am writing pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Mark 

W. Garza, an owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations (“FARs”) listed below so that I, Mark W. Garza, may operate my small ultra 

lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal 

Aviation Administration (“FAA”). 

Following exemption and approval by the FAA, I, Mark W. Garza, will primarily use my 

professionally built (DJU Inspire 1, DJU Phantom 3, AGRAS MG-1, DJI Matrice 100) UAS 

equipped with cameras for the following applications: Closed-Set Film Operations on Film and 

Television Productions, as well as aerial videography/cinematography to safely enhance films 

and commercials; augmentation of real estate listing videos; education, Aerial Data Collection to 

include agricultural inspections and building and construction zone inspections. Inspection on

towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, 

wind generators, power stations and substations, and buildings. Golf Courses, Special Events, 

Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster 

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Animal 

tracking, Forestry & logging, Insurance Assessments, Surveys, Mining, Traffic monitoring, and 

sporting events
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Mark W. Garza’s, exemption request would permit the operation of ultra lightweight, unmanned 

(i.e. piloted by remote control) UAS’s for the development of community and government use 

videos, permissible within property boundaries for individual homeowners and within in tightly 

controlled, limited airspaces predetermined in areas away from the general public, airports, 

heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally 

operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent 

catastrophe. Furthermore, it is my intent to assist future FAA safety protocols and regulations 

exclusive to lightweight UAS's for specific video and photography usage by sharing information 

with the FAA as I, Mark W. Garza, record flight data and other pertinent information gained 

through permitted flight operations. 

In addition, granting my, Mark W. Garza’s, exemption request will comply with the Secretary of 

Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for real estate/Realtor purposes, educational videos, Search and Rescue, 

land/trusts inspections, agricultural field monitoring, film/video productions, closed-set motion 

picture film operations and television, and structure inspections, to aid state and local agency’s. 

Further I, Mark W. Garza, will conduct my operations in compliance with the protocols described 

herein or as otherwise established by the FAA. For the reasons stated below, I, Mark W. Garza, 

respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote 

controlled UAS’s to facilitate commerce and raise awareness of the beneficial uses of small 

unmanned air systems. A grant that will ultimately allow UAS’s to play a more positive role in 

our local community by increasing employment opportunities, heightening security measures 

and decreasing government expenditures by reducing the need for heavier manned aircraft, 

containing costly, combustible fuel- a potential public hazard in and of itself. 

I. Contact Information:

Mark W. Garza

Excelsior Springs, Missouri 64025

Phone: 254-535-3329

Email: garzamw@yahoo.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Mark W. Garza Requests Exemption are: 

14 CFR 21; 

14 CFR 61.113 (a) & (b); 

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); 

14 CFR 417 (a) & (b). 

14 CFR 45.23 (b) 

14 CFR 45.27 (a) 

14 CFR 91.7 (a) 
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14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.105 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

8900.227 §16 (c) (4) and §16 (e) (1)

III. The Extent of relief Mark W. Garza Seeks and the Reason He Seeks Such Relief: 

I, Mark W. Garza, 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 me Mark W. 

Garza, contemplated commercial cinematic, academic 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 public’s interest to do 

so. My, Mark W. Garza’s, ultra lightweight UAS meets the definition of “small unmanned aircraft” 

as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly 

contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that can be 

administered uniformly to all 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: The weight, size, speed and overall capabilities 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 reflect in favor of an exemption for me, Mark W. Garza. My UAS’s utilize 

eight (8) or less rotating propellers for balance, control and stability. My UAS’s are equipped 

with the following via video and data telemetry:

1) Altimeter 

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 
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12) Auto safety or RTL ( Return To Launch) 

13) Auto landing technology. 

Each UAS weighing less than thirty (35) pounds (far below the maximum 55 pound limit); 

Including camera(s) with or without gimbal (a camera stabilizer). I, Mark W. Garza, considers 

safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, 

circle in a specific place or loiter via GPS and can be operated in winds up to 30.4 knots 

(35mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 21.7 

knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle 

in place or land when radio controls are released. 

With three (3) modes to choose from, I will fly with the modes safest to complete the videos for 

aerial videography/photography and have the ability to choose the safest, most reliable and 

stable mode to prevent accident and hazard. When pilot communication from the radio control is 

lost, UAS is designed to slowly descend to point of takeoff and or to land at point of 

launch after ascending to a pre-set altitude to ensure the UAS will clear any obstacles that may 

be between the takeoff point and the current position of the UAS. This failsafe altitude will not be 

set more than 200ft and is determined before each flight. 

I, Mark W. Garza, will not operate my UAS near airports, hospitals nor police heliports, and do 

not operate near areas where general public is within fifty to one hundred (50-100) yards 

depending on location, conditions and weather. I am 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 my location or I suspect manned aircraft 

may approach near my location. My UAS’s are capable of vertical and horizontal operations, 

and is flown only within my line of sight, as the remote control pilot. My UAS's are also flown 

with a second operator who aids in watching for any obstacles, including manned aircraft, within 

the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights generally 

last between three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (150) 

feet. (3 )Smart Mode includes, position hold, self-leveling, altitude command, GPS, return home 

feature, and safety control to return home or land in the event of communication interruption 

between RC transmitter and UAS.

I, Mark W. Garza, utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. I do 

not operate my UAS at or below manufacturer recommend 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. I do not believe in taking risk that may cause a crash that could create 

hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have 

clocked numerous practice flights in remote areas as a hobbyist simulating flights for future 
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commercial use to gain familiarization with the characteristics of this specific UAS's performance 

under different temperature and weather conditions. I also practice computerized simulated 

flights to maintain adequate skills and response reflex time. All for the sake of safety. 

I, Mark W. Garza, am extremely cautious when operating of my 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 my 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 Mark W. Garza’s 

UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to 

the general public or national security. 

IV. How Mark W. Garza’s Request Will Benefit the Public as a Whole: Aerial 

videography for geographical awareness, education, search and rescue, land management, 

structure inspections and for real estate marketing has been around for a long time through 

manned fixed wing aircraft and helicopters. For small budget companies, average homeowners 

and property owners the expense of such aerial videography is cost prohibitive. Only large 

companies and high end Realtors or luxury homeowners can afford to absorb such expense; 

depriving non-luxury owners and lower budget companies from a valuable marketing tool. Use 

of the UAS in lieu of a manned aircraft would also enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, 

carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce 

could lead to economic growth. Operations for this petition will enable service for property 

owners or their designees seeking an enhanced perspective for characteristics, amenities, and 

benefits of their desired photographic subjects that cannot be displayed through ground level 

videography/photography. Aerial photography is a valuable marketing tool that can lead to 

increased commerce and enhance personal photography. Crop surveying applications could 

lead to decreased use of pesticides and fertilizer and conservation of water as well as increased 

crop yields and decreased costs. Aerial surveying and inspections can increase work site

efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients 

with photographic data for these purposes on a ‘for hire’ basis acting as an independent 

contractor.

V. Reasons Why Mark W. Garza’s Exemption Will Not Adversely Affect Safety Or 

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: Mark W. 

Garza’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

permitting me, Mark W. Garza, to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow me to contribute to the innovation and implementation of 

new and novel, as of yet undiscovered safety protocols for Realtors, land and structured 

owners. For development in cooperation with the FAA. In addition I, Mark W. Garza, submit the 

following representations of enhancements to current aerial videography and photography: My 

UAS’s weigh less than fifteen (15) pounds complete with an integrated ultra-light weight camera; 

I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the 

FAA Modernization and Reform Act of 2012); My UAS only operate for 3-30 minutes per flight; I 

land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my 

UAS through remote control only by line of sight; and have live video feed for a secondary pilot 

to monitor video recording; I receive a live telemetry feed from my UAS during all flights which 
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include remaining battery voltage, distance, altitude, and any anomalies that may occur during 

flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz frequencies in 

accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz-5.875Ghz frequencies in accordance with CFR 47, 

Part 15.

My UAS’s have a GPS controlled flight controller- a flight safety feature whereby it hovers or 

circles and then lands at the GPS takeoff point if communication with the remote control pilot 

is lost; I actively record and analyze flight data through the DJI Inspire 1, DJI phantom 3 , DJI 

AGRAS MG-1, DJI Matrice flight controller app to constantly update and enhance safety 

protocols; I only operate in reasonably safe environment that are strictly controlled, are away 

from power lines, elevated lights, airports and actively populated areas; I conduct extensive 

preflight inspections and protocol, during which safety carries primary importance; I always 

obtain all necessary permissions prior to operation; and, I have procedures in place to abort 

flights in the event of safety breaches or potential danger. My, Mark W. Garza’s, safety 

protocols 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 real estate, 

structured inspections, land management and search and rescue. 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 to operate a battery powered ultra lightweight 

UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I 

only operates my UAS 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 my UAS allow me to remotely pilot away from and 

avoid hazards quickly and safely. Lastly, given its small size and weight, even when close 

enough to capture amazing images, my 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, my UAS has been experimentally operated for familiarization/competency and will 

continue to operate at and above current safety levels. 

VI. 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 requirements for 

procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The 

size, weight and enclosed operational area of my, Mark W. Garza’s, UAS permits exemption 

from Part 21 because my 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 
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to areas such as airports and dense populations. My, Mark W. Garza’s, current and projected 

UAS's meet or 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's, 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. 

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 CFR 91.103: Preflight Action

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

safety of flight. An exemption is needed from this requirement as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery requirements, 

checking takeoff and landing distances, and all other actions in the Preflight Checklist in the 

Manual. These actions will provide an equivalent level of safety.

14 CFR 91.105: Flight crewmembers at stations

This regulation defines the obligations of the flight crewmembers during takeoff and landing, and 

while en route. This part is not applicable due to the sUAS is not carrying any flight

crewmembers. Mark W. Garza will not operate the aircraft unless someone is at the controls at 

all times. Each flight will be manual, with the exception when the sUAS goes into emergency

mode like return-to-home. This will achieve an equivalent level of safety to 14 CFR.

91.105, because the flight crew will be at their stations at all times during the flight. The stations 

will not be on the aircraft but on the ground.

14 CFR 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. By design, sUASs and remotely piloted aircraft 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 previously approved exemptions for aircraft 

without fully functional dual controls. See Exemption Nos.5778K & 9862A. The equivalent level 

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

the ability to control the sUAS via radio signals from the controller, and by the size and speed of 

the aircraft.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 

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 
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of safety will be achieved by maintaining any such required certifications and registrations by 

me, Mark W. Garza. 

14 CFR 45.23 (b): Marking of the Aircraft and 14 CFR 45.27 (a): Location of marks; 

nonfixed-wing aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or lightsport

category aircraft to be marked with letters between 2 inches and 6 inches high "limited," 

"restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit, 

or pilot station. Even though the sUAS will have no airworthiness certificate, an exemption may 

be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the 

word "Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be 

impossible. The equivalent level of safety will be provided by having the sUAS marked with the 

word "Experimental" will be placed one of the arms of the sUAS in compliance with45.29 (f) and 

on both sides of the UAS in compliance with 45.27 (a) where the pilot, observer and others 

working with the sUAS will see the identification of the sUAS as "Experimental." The FAA has 

issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and 

10167A.

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

61.113 (a) & (b), private pilots are limited to non-commercial operations. I, Mark W. Garza, The 

sUAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. The 

PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC 

is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

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. My UAS will never operate at an altitude greater than 300f close AGL; safely below 

the standard of 400 AGL. I, Mark W. Garza, will however operate my 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 my UAS, an 

equivalent or higher level of safety will be achieved.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions.

Our sUAS is limited to operations in sterile and controlled environments as outlined in the

Manual, and has a limited range and flight time which require an exemption from 14 CFR

91.151 (a).The battery powering the sUAS provides approximately 25 minutes of powered flight. 

To meet the 30 minute reserve requirement in 14 CFR 91.151, sUAS flights would not be 

possible to perform. Given the limitations on the sUAS's proposed flight area and the location of 

its proposed operations within a predetermined area, a longer time frame for flight in daylight is 

reasonable. Mark W. Garza believes that an exemption from 14 CFR 91.151 (a) falls within the 

scope of prior exemptions. See Exemption 11191 (allowing Singer’s Creation to operate without 

compliance with FAR 91.151 (a)). Operating the sUAS, 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 sUAS.

The sUAS calculates battery reserve in real time. The sUAS has two levels of low battery 

capacity warning that are presented on the monitoring system. The first appears when the 
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battery has less than 30% power and the second appears when it has less than 15% power. 

The sUAS will return to its ground station with at least 15% battery power reserve should that 

occur prior to the 25 minute flight time. An equivalent level of safety can be achieved by limiting 

flights to 20 minutes, or enough battery reserve to ensure that the sUAS lands at the ground 

station with at least 15% of battery power (as determined by the onboard monitoring system and 

the pilot), whichever happens first. This restriction would be more than adequate to return the

sUAS to its planned landing zone from anywhere in its limited operating area. Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

10808 and 11191.

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

Manual. The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] 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. . . .”These Regulations only 

apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Mark W. 

Garza’s, UAS. However, as a safety precaution I inspect my UAS before and after each flight. 

8900.227 Paragraph 16 (c) (4) PIC Medical. and Paragraph 16 (e) (1) Observer

Medical. This policy provides that both the PIC and observer must have a valid FAA second 

class medical certificate issued under part 67 in order to perform as a pilot or observer.

Requiring the crew to meet the same medical requirements as commercial pilot

carrying passengers in a large aircraft is an unnecessary burden. We propose that the

minimum medical requirements be vision corrected to 20/20 and a valid, state-issued

driver's license. The risk of both the PIC and observer becoming incapacitated at the

same time and suddenly is very low. Further, since the sUAS is operating close to the

ground, it could be brought in for landing in a very short time if incapacitation was

suspected. Finally, the sUAS's that will be operated are equipped with an automatic return to 

home feature which would provide a final level of safety. We feel this would provide an 

equivalent level of safety.

A Summary The FAA May Publish in the Federal Register: A. 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 requirements for procurement of necessary airworthiness 

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

of my UAS permits exemption from Part 21 because my, Mark W. Garza’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 the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. My UAS 

meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft 

without an airworthiness certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an 

aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of 
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the UAS's, 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, Mark W. Garza seeks an 

exemption from the following Regulations: 14 CFR 21, subpart H; 14 C.F.R. 45.23(b); 14 CFR 

§§ 61.113 (a) & (b); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 14 CFR 

Part 21; 14 CFR 45.23 (b); 14 CFR 45.27 (a); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 

91.103; 14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 

14 CFR 91.203 (a) & (b); 14 CFR 91.405 (a); 8900.227 §16 (c) (4) and §16 (e) (1)

to commercially operate my, Mark W. Garza’s, small unmanned vehicle/lightweight unmanned 

aircraft vehicle for Closed-Set Film Operations on Film and Television Productions, as well as 

aerial videography/cinematography to safely enhance films and commercials; augmentation of 

real estate listing videos; education, Aerial Data Collection to include agricultural inspections 

and building and construction zone inspections. Inspection on towers, poles, pipelines, power 

lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power 

stations and substations, and buildings. Golf Courses, Special Events, Public Service- Primarily: 

Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, 

Floods, hurricanes, news broadcasting, and tornados. Animal tracking, Forestry & logging, 

Insurance Assessments, Surveys, Mining, Traffic monitoring, and sporting events. 

F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and 

limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) 

and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All 

altitudes reported to ATC must be in feet AGL.

4. The UAS 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 state driver’s license.
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5. All operations must utilize a visual observer (VO). 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.

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere 

in this operations manual, the conditions and limitations herein take precedence and 

must be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. 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. The Ground 

Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

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 in accordance with the operator's manual. The PIC who conducts 

the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance

requirements must be established and identified in the operator's manual. At a minimum, 

the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller 

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator
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10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a 

current state driver’s license. 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/her pilot 

certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single 

blade or multirotor). Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS 

to be utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing 

currency flights can be conducted under this grant of exemption to accomplish the required 

flight time and 90 day currency. During training, proficiency, experience-building, and take-off 

and landing currency flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from non-participants 

in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in

the operator’s manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

operator. A record of completion of this qualification process must be documented and made 

available to the Administrator upon request.
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14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical 

test standards that support a jurisdictional FAA FSDO evaluation and approval of company 

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface 

in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons 

must be essential to the closed-set film operations. Because these procedures are specific to 

participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is 

necessary for reductions to the distances specified in the petitioner’s manuals. This is 

consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 

Issue a Certificate of Waiver for Motion Picture and Television Filming.

17. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet 

if it would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of 

the filming production area to note terrain features, obstructions, buildings, safety barriers, 

etc. Such barriers may protect non-participating persons (observers, the public, news media, 

etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 

8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA 

must return to a pre-determined location within the security perimeter and land or be 

recovered in accordance with the operator’s manual.
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18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual.

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

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.

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

be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be 

added to the operator’s manual.

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

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction 
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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 person responsible for the UAS filming 

production 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 the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming 

production event 

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

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

29. The 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.

30. The UAS must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

31. 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.

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS 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.
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34. The UAS may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management must be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

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

the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may 

not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, 

Mark W. Garza’s, request for exemption will reduce current risk levels and thereby enhance 

safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional video and photographic aircraft with much less flight time. 

Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk 

flying to and from established airfields. I, Mark W. Garza, have been informally analyzing and 

recording flight information and will compile safety protocols and the implementation of a flight 

operations manual for 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 my, Mark W. Garza’s, UAS and therefore the likelihood of 

death or serious bodily injury is significantly diminished. My, Mark W. Garza’s, operation of my 

UAS, weighing less than forty (40) pounds and traveling at lower speeds within limited areas low 

to the ground will provide an equivalent level of safety as that achieved under current FARs. 

Accordingly I, Mark W. Garza, respectfully request that the FAA grant my exemption request 

and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, 

and the general public at large. 

Respectfully submitted, 

Mark W. Garza

15804 Saddle Dr,

Excelsior Springs, MO 64024
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10

Appendix A

List of Aircraft

No. Make and Model Description Serial No. Registration

No.

1 DJI Inspire 1 Electric powered, 4 rotor, small 

unmanned multirotor helicopter

Not Yet 

Purchased

Pending

2 DJI Phantom 3 Electric powered, 4 rotor small 

unmanned multirotor helicopter

Not Yet 

Purchased

Pending

3 DJI AGRAS MG-1 Electric powered, 8 rotor, small 

unmanned multirotor helicopter

Not Yet 

Purchased

Pending

DJI Matrice 100 Electric powered, 4 rotor, small 

unmanned multirotor helicopter

Not Yet 

Purchased

Pending

1. DJI INSPIRE 1

The operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The DJI INSPIRE ONE flight in a 4 motor quadcopter setup. ,

3. Payload 

I. The DJI INSPIRE ONE flies it’s own light-weight integrated camera. 

II. Maximum All-up weight- 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.
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3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

and/or chips. Replace if propeller is questionable. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.

Appendix B 

2. DJI Phantom 3

The operation of the DJI Phantom 3 system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The Phantom 3 flight in a 4 motor quadcopter setup. ,

3. Payload

I. The Phantom 3 it’s own integrated camera. 

II. Maximum All-up Weight- 4lbs

4. Maintaining the Phantom 3

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 
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3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

and/or chips. Replace if propeller is questionable. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.

Appendix C

3. AGRAS MG-1

The operation of the DJI AGRAS MG-1 multirotor system are as follows (the flight controller 

operation manual is NOT explained in this manual but can be found in Appendix E, Section 1).

1. Build Materials

I. Carbon Fiber

II. ABS Plastic

III. Stainless Steel Hardware

2. Motor Configuration

I. X8 configuration utilizing 8 motors (DJI KV 130rpm/V) The motors are configured with 2 

motors per arm, one top and one bottom spinning in a counter-rotating direction. UAV is not 

equipped with camera but does not need one as its use will be only visual line of sight and no 

more than 15ft above top of tallest planted crop. 

II. In this configuration the AGRAS MG-1 can handle up to four (4) motors failing and still be 

able to fly.

3. Payload 

I. The AGRAS MG-1 will carry 10kg of either pesticide or fertilizer for crop 

II. 3 Flight modes Smart Mode, Assisted Mode & Manual Mode, according to terrain and specific 

needs 

III. Maximum All-up Weight- 34lbs

4. Maintaining the AGRAS MG-1

I. Before each flight:

II. After 45 hours of flight

1. Check all hardware to ensure it is securely tightened.

2. Check that all motors are level and locked in place.

3. Check all propellers to ensure they are tight and there are no visible signs of cracks, stress, 

and/or chips. Replace if any propeller is questionable. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of cuts, 

fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check all navigational lighting to ensure it is properly working.
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6. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary.

7. Remove motor controllers and visually inspect and check for damage. Replace as 

necessary.

8. Remove flight controllers and visually inspect and check for damage. Replace as 

necessary. Check for updates to flight controller firmware. If available, install and perform a 

minimum of 15 test flights before conducting commercial work. 

Appendix D 

4. Matrice 100

1. Build Materials

I. Carbon Fiber

II. ABS Plastic

III. Stainless Steel Hardware

2. Motor ConfigurationI. The Matrice 100 flight in a 4 motor quadcopter setup

3. Payload

 I. Matrice 100 has it’s own integrated camera. Maximum All-up Weight- 4lbs

3. Maintaining the Phantom 3

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of 

cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for 

signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

and/or chips. Replace if propeller is questionable. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.
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Personal Protocols/Controls/Flight Manual 

Protocols and Controls 

Mark W. Garza, Excelsior Springs, Missouri

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre‐ flight preparation and during flight. Pre‐ Flight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. 

Inspect batteries for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

Check all GPS and Telemetry connections prior to flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of 

possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports

Vicinity of medical helipads/heliports 

Vicinity of light poles vicinity or utility wires 

Vicinity of trees flocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted public 

Gatherings that may attract viewers optional point of control for best visual site of UAS 

while in flight 

Emergency landing areas 

Takeoff and landing 

Inspect area for best and safest point of takeoff and landing 
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If in a subdivision or area that is within 150 feet of a residential street, post warning 

Sign(s)/stand(s) "Attention Aerial Photography In Progress ‐ Remain Back 150 Feet " 

Flight Protocol: takeoff and land from same location ( have alternate landing areas in case of 

emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles 

do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to 

minimal elevation sufficient to acquire desired results remained prepared for emergency landing 

at all times pay attention to flight time – warning meter for low voltage. 

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut 

down propulsion immediately following landing – priority of disconnecting batteries 

Post flight: 

1. a) Disconnect battery to prevent accidental activation of propulsion system 

2. b) Secure UAS in a safe location 

c) Remove all warning signs from public access areas Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight 

Pilot is being distracted from focusing on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 

Date:____________________ 

Location:___________________________________________________ 

pre‐ flight Inspection: 
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o Yes o No 

Comment: _________________________________________________ 

Elements 

Proximity to airport: _________________ (see attached map pinpointing approximate location 

of flight) 

Airport notified: No Yes 

Date:_______________ Time: ______________ 

Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: 

______________________________________________________________ 

Proximity to medium traffic road: 

_________________________________________________________ 

Proximity to heavily traveled roadway road: 

_________________________________________________ 

Proximity to congested population: 

________________________________________________________ 

Approx. Takeoff Time : GMT: 

Weather Good Fair Poor Comment : 

Visibility Good Fair Poor Comment : 

Wind Speed ___mph ___Gusts/MPH ___avg/MPH Comment : 

Approx. Landing Time: GMT: Estimated Elevation Ground level: 

Safety Concerns: 

Additional Comments: 

sea level: 
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Appendix 

'E'

Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and 

illustrated parts catalogs. These manuals may be attached to the docket when submitted. 

Information regarding design, aircraft performance, fail-safe features, operating limitations, 

normal and emergency procedures, and maintenance and inspection procedures is contained 

within the manuals and supplemental information documents listed below:

1. DJI Inspire Manual V1.0/ V2.0/Pro

2. Inspire 1 Maintenance Manual v1.0/v2.0/Pro

3. Intelligent Flight Battery Safety Guidelines v1.4

4. Inspire 1 Safety Guidelines

5. Phantom 3 Professional Manual V1.0

6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)

7. Matrice 100 Manual

8. Matrice 100 Safety Guidelines

9. AGRAS-M1 Manual

10. AGRAS-M1 Safety Guidelines

For more information or questions about this manual please contact:

Mark W. Garza

15804 Saddle Dr, Excelsior Springs, MO

254-535-3329