U.S.	Department	of	Transportation	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)	

and	(b);	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)	

Dear	Sir	or	Madam:	

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

Act”)	and	14	CFR	Part	11,	Luis	G.	Tamez	(DBA	Drones	JPG),	operator	of	an	Unmanned	

Aircraft	System	(UAS),	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	

Regulations	(“FARs”)	to	allow	commercial	operation	of	its	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.	

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	

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,	cinematography	and	news	gathering.	

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

with	the	owners	or	local	government authority.	

4. Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	

including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.	

5. 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.	

6. The	ability	to	offer	training	to	persons	individually	or	belonging	to	both	private	

and/or	public	organizations	that	have	interests	in	the	use	and	application	of	a	UAS	

for	the	purpose	of	the	safe	operation	of	a	UAS	to	enhance	the	safety	of	the	National	

Airspace	System	(NAS)	as	well	as	for	the	protection	of	the	persons	and	property.	

As	described	fully	below, the	requested	exemption	would	permit	the	operation	of	a	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.”	
Regulations	from	which	the	exemption	is	requested:	

14	CFR	Part	21	subpart	H	

14	CFR	45.23	(b)

14	CFR	61.113	(a)	&	(b)	

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)

Equipment	to	be	operated	is	the	DJI	Phantom	2	Vision+,	DJI	Phantom	3,	and	DJI	Inspire 1

The	DJI	Phantom	2	Vision+ 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	live	video	feed	will	have	an	

operating	frequency	of	5.728GHz	– 5.850GHz.	The	applicant	will operate	the	UAS	in	line	

of	sight	within	a	closed	off	and	predetermined	area	owned	and/operated	by	the	

property	representative.	

Given	the	small	size	of	the	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.	

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	UAS	will	weigh	less	than	55	lbs.	

2. The	UAS	will	have	a	maximum	operating	speed	of	no	more	than	50mph.	

3. Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	

Visual	Observer	(VO).	

4. Maximum	flight	time	for	each	operational	flight	will	be	30	minutes.	Flights	will	be	

terminated	at	25%	battery	power	reserve	or	30	minutes	of	flight	time	whichever	

occurs	first.	

5. 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.	

6. Minimum	crew	for	each	operation	will	consist	of	the	UAS	Pilot,	the	Visual	

Observer	(VO)	and	may	include	but	not	limited	to	a	Camera	Operator.	

7. The	UAS	pilot	will	be	a	designated	Pilot	in	Command	(PIC)	and	hold	a	Medical	

Certificate.	If	the	PIC	feels	another	operator	to	be	qualified	with	the	necessary	

skills	to	be	PIC	&	Class	Medical	Certificate,	that	person	may	be	designated	PIC	

provided	they	have	a	minimum	of	20	hours	of	flight	time	with	the	UAS.	

8. A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	

day’s	flight	consisting	of	all	the	days’	production	activities.	

9. All	flights	will	occur	under	Visual	Flight	Rules	Meteorological	Conditions	(VMC)	

only.	

10. The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	

center/Airport	Reference	Point	(ARP)	of	a	tower	controlled	or	uncontrolled	

airport.	

11. If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	

Reference	Point	(ARP)	of	a	tower	controlled	or	uncontrolled	airport	the	

respective	airports	will	be	contacted	advising	them	of	the	estimated	flight	time,	

flight	duration,	elevation	of	flight	and	other	pertinent	information.	

12. The	operator	will	file	FAA	Form	7711-1,	or	its	equivalent,	as	modified	in	light	of	

the	requested	exemption,	with	the	appropriate	local	Flight	Standards	District	

Office	(FSDO)	no	more	than	72	hours	but	no	less	than	48	hours	from	planned	

operation.	

13. The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	

planned	operation	and	ensure	that	only	consenting	persons	will	be	allowed	

within	100	feet	of	the	flight	operation,	and	the	radius	may	be	reduced	to	30	feet	

based	upon	an	equivalent	level	of	safety	determination,	as	required	under	the	

FOM.	With	the	advanced	permission	of	the	FSDO,	operations	at	closer	range	may	

be	approved.	

14. The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up-todate	information	for	the	particular	UAS	to	be	operated.	

15. The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	

times.	

16. Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	

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

appropriate	governmental	agencies.	
17. If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	

the	UAS	will	have	the	capability	to	return	to	a	pre-determined	location	within	a	

designated	location and	land	autonomously.	

18. The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	

obstacles,	weather,	or	emergencies.	

Sincerely,	

Luis	G.	Tamez/Owner

Drones	JPG

2101	N.10th	St	McAllen,	Tx

Phone	:	(956)279-7497

Email:	luis@dronesjpg.com