July 31, 2015 

ped rom a rtf nez 

FotoForemsica Aerial Photography 

Box 10197 

San Juan, PR 00922 

787-603-3377 

To: U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE, 

Washington, DC 20590 

From: Pedro Martinez - Owner 

FotoForensica Aerial Photography 

Lot I -7 Fernando Luis Ribas Dominicci Airport 

San Juan, PR 

Re: Petitioner: Pedro Martinez Aerial Photographer for 

Exemption Pursuant to section 333 of the FAA Reform Act 

Attn: To whom it may concern 

Dear Sir or Madam: 

Since 1972, I Pedro Martinez, have dedicated myself to the art of photography. I 

have been owner of several commercial aerial photography entities like, Pedro 

Martinez & Associates, Aerial/ Architectural Photography Inc. and now 

FotoForensica. I have worked in Puerto Rico my home town, for over 40 years 

doing aerial photography and aerial video and travelled to the Caribbean and 

Central America for several high end clients like Exxon, Me Donald's and Puma, 

just to mention a few. I have been privileged to work on some of the most 

recognizable and high-profile commercial buildings and industrial projects in the 

Caribbean, for the private enterprise, government and the military. Our work 

includes projects in the expanding healthcare system, pharmaceutical, 

infrastructure, public projects, housing development and major shopping 

centers and I have recorded, from the ground and from the air, all 14 controlled 

building demolitions in Puerto Rico, including a record, Villa Panamericana, the 

most buildings shot in a single implosion sequence: 17 buildings. 

pedromartTnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
f(Jr Exemption unckr Section 

t.Iul~\-T 31 ~ 

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As an aerial photographer and videographer, I have been required to perform 

different approaches from site selection and documentation, feasibility studies, 

rapid transit alignment sequence, commercial business demography, 

construction work, roof inspections, architectural work in process, monthly 

construction progress photography, crop conditions and damages, legal 

approach and forensic documentation, high value historical buildings 

documentation and recording, to high end real state approach for property 

marketing and sales. Our aerial photography from both airplanes and 

helicopters, have proven to be a great tool in the development of our economy. 

I'm a certified SELS, ME and glider pilot, with a second class medical certificate 

and over 6,100 hours of flying time and member of Professional Aerial 

Photographers Association International, an organization whose members, all 

aerial photographer's, follows and validates the need for a safe National Airspace 

System. 

Not only our techniques and procedures often requires our employees to be put 

in situations that require us to accept risk, but also in recent history we have 

been bidding on jobs also bid by drone operators in our area and we find it 

difficult to compete with them. Therefore, we would like to add drone service to 

our clients. All of our drone operators will be rated pilots. As described more 

fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1.limited, 2. Predetermined, and 3. controlled. The exemption 

would allow Pedro Martinez and FotoForensica Aerial Photography and its 

personnel, to conduct commercial operations of small unmanned aircraft 

systems ("UAS") meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333. 

I share Congress's goal of getting sUAS flying commercially in the United States 

safely and soon. In the FAA Modernization and Reform Act of 2012, Congress 

directed the FAA "to safely accelerate the integration of civil unmanned aircraft 

systems in the National Airspace System and under section 333 of the law, gave 

the FAA power to grant innovators "expedited operational authorization" to do 

so. 

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

Reform Act) and 14 C.F.R . Part 11, Pedro Martinez and FotoForensica Aerial 

Photography, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs"), to conduct commercial operation with a "small Unmanned 

Aircraft System" (sUAS), on our daily routine of aerial photography and 

videography, in order to improve the safety of our employees and reduce 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
Exemption under Title HCFR Seciion 33:1 

Page of 1:J 

operational cost. 

A. Petitioner Information 

Pedro Martinez - FotoFon§nsica Aerial Photography 

Lot I-7 

Fernando Luis Ribas Dominicci Airport 

San Juan, PR 

PO Box 10197 

San Juan, PR 00922 

787-603-3377 celular 

pedroprmartinez@gmail.com 

B. Specific section or sections of 14 CFR from which Pedro Martinez 

Aerial Photographer seeks relief and exemption 

Statutory Authority Section 333, titled "Special Rules for Certain Unmanned 

Aircraft Systems", provides a mechanism for seeking expedited FAA 

authorization of safe civil UAS operations in the NAS. Section 333(a) states that 

the FAA "shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the (comprehensive) 

plan and rule making required by section 332(b)(1) of this Act or the guidance 

required by section 334 of this Act." In Section 332(b)(1), as I mentioned, 

Congress made it clear that Section 333 provides a mechanism for "expedited 

operation authorization" if several factors are met. Petitioner meets all 

requirements to permit FAA approval of commercial UAS operations. 

14 CFR Part 21 (h) 

14 CFR Part 27 

14 CFR 45.23 (b) 

14 CFR 45.27 

14 CFR 61.113(a) and (b) 

14 CFR 61.133 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 (b) (2) 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
l'S Department of Tnmsponation 

Pedro Martinez 

July<H, 2015 

Page -1- I:l 

14 CFR 91.203(a) and (b) 

14 CFR 91.401 - 91.417 

for Exemption under 

C. Reasons for requesting relief 

1-1-CFR Section 

Pedro Martinez and FotoForensica Aerial Photography plans to exploit the 

capabilities of Unmanned Aerial Systems to offer a multitude of services, 

including: 

-Aerial surveying for hard to reach areas of buildings 

-Roof top inspections 

-Building exterior envelope inspection 

-Visual documentation of existing site conditions before construction 

-Visual documentation of existing site conditions during construction 

-Visual documentation of existing site conditions after construction 

-Quality control and assurance inspections 

-Agricultural support 

-Real Estate photography 

-Aerial film making and photography 

-Construction site inspections and monitoring 

-Wildlife and forestry monitoring 

-Educational and research operations 

-Legal and forensic documentation for court cases and exhibits 

D. The Aircraft 

Unmanned Aircraft System- The Aircraft 

We are petitioning for exemption to enable Pedro Martinez and FotoForensica 

Aerial Photography to operate a DJI Phantom III Professional, equipped with a 

three-axis gimbals and using High-Definition cameras. This sUAV has a built-in 

capability to limit the height it flies above the ground, to limit the radius of the 

distance it flies from the operator. On a later date, an Inspire I will join the fleet. 

Specifications include: DJI Phantom III Professional: 

• Diagonal size (including propellers): 590 mm (1ft - 11 in) 

• Maximum Weight: 1280 kg (2 lb -13oz) 

• Number of Rotors: 4 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
Ueparl.melll. 

Pedro Martinez 

,July 1 , 2015 

Page 5 13 

Request l(>r Exemption under T11:le -+CFR Section 333 

• Power of Rotors- 100 W 

• Maximum Ascent Speed: 5 m/ s (984 fpm) 

• Maximum Cruise Speed: 16 m/s (31 kts) 

• Maximum Descent Speed: 3 mj s (590 fpm) 

• Maximum Flight time: Approximately 23 minutes 

Pedro Martinez and FotoForensica Aerial Photography agrees that the UAS will 

include, at minimum: flights not to exceed a maximum altitude ceiling of 400' 

AGL, flight programming capabilities, a flight termination link available to the 

operator to prevent a "fly away," and safe abort procedures. If the UAS loses 

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

location and land or be recovered in accordance with the Operations Manual. 

The UAS will have markings identifying the serial number and identification 

(N-number) markings as large as practicable. 

E. Operating Parameters 

a. Petitioner proposes that the exemption requested herein apply to 

civil aircraft that have the characteristics and that operate with 

the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under 

the current regulatory structure because the proposed 

operations represent a safety enhancement to the already safe 

operations conducted with conventional aircraft. Further details 

about the aircraft and operating procedures are available in the 

Operations and Training Manual. 

b. The limitations and conditions to which Pedro Martinez Aerial 

Photographer agrees to be bound when conducting operations 

with sUAS include; 

i. UAS Pilot and/ or Observer 

1. All flights will be performed by a licensed pilot. 

2. All UAS operations must utilize a visual observer 

("VO") when necessary. 

3. The pilot-in-command ("PIC") and VO must be able 

to communicate verbally during the operations. If 

unable to maintain two-way communication, or if 

any condition occurs that may otherwise cause the 

operation to be unsafe, the operator will immediately 

pedromartfnez- aerial photographer Box 10197 San Juan, PR00922 787-603-3377 
US Department Tmnsponation 

Pedro - FoloFon~nsiCL\-F1equest f<x F:xem.ption Ti1le HCFR Section 

,July 31, 2015 

() 13 

conclude the operation. 

ii. Operational Parameters 

1. Aircraft will not carry pilots or passengers, and 

aircraft will not carry explosive materials or 

flammable liquid fuels. 

2. The sUAS operated by the petitioner weights less 

than 55 pounds, including the payload (camera, lens 

and gimbal). 

3. UAS must be operated within visual line of sight of 

the pilot at all times. 

4. UAS may not be flown at ground speeds exceeding 

30 knots. 

5. Flights will be operated at an altitude of no more 

than 400 feet above ground level. 

6. Each sUAF operation will be completed within 20 

minutes flight time or 25% battery power remaining, 

whichever occurs first. At 30% battery the sUAS will 

enter a return and land sequence, at 20% it will land 

immediately. 

7. The UAS flight will be aborted in the event of 

unpredicted obstacles or emergencies in accordance 

with the Operations Manual. 

8. Operations will be conducted at a "sufficient 

distance" from populated areas and under the land 

owners consent, never over congested areas or over 

open-air assembly of people. Such operations will 

insure that the sUAS will "not create a hazard to 

users of the national airspace system or the public." 

9. The operator must obtain a Certificate of Waiver of 

Authorization (COA) prior to conducting any 

operations under this grant of exemption. 

10. Before conducting operations, the radio frequency 

spectrum used for operation and control of the sUAS 

will comply with the FCC or other appropriate 

government oversight agency requirements. 

11. sUAS operations will not be conducted during night, 

as defined in 14 C.F.R. § 1.1. All operations will be 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
Department 

Pedro Martinez FotoFori~nsJca-l<equcst for Exe.mption under Title 1 

,July l, 201 

7 uf l ~} 

conducted under visual flight rules (VFR). 

12. The sUAS will not be operated by the PIC from any 

moving device or vehicle. 

13. The sUAS will 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. 

14. The sUAS will not operate in class B, C, or D airspace 

without approval from the FAA. The sUAS will not 

operate within 5 nautical miles of the geographic 

center of a non-towered airport as denoted on a 

current FAA published aeronautical. 

15. Any incident, accident, or flight operation that 

transgresses the lateral or vertical boundaries of the 

operation area defined by the applicable COA will be 

reported to the FAA's office within 24 hours. 

Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions 

contained on the NTBS web site; www.ntsb.gov. 

16. The operator will follow the procedures as outlined 

in its Operation Manual. 

17. The Operations Manual will be made available upon 

request. 

18. Prior to each flight, the pilot will inspect the sUAS to 

ensure it is in condition for safe flight. If the 

inspection reveals a discrepancy, the aircraft will be 

prohibited from operating until the necessary 

maintenance has been performed and the sUAS is 

found to be in a condition for safe flight. 

19. All maintenance and alterations will be properly 

documented in the aircraft records. 

20. Petitioner will institute a rigorous maintenance 

program to ensure airworthiness of the sUAS. 

Operator will follow the manufacturer's sUAS 

aircraft/ component, maintenance, overhaul; 

replacement, inspection, and life limit requirements. 

21. Operator will develop procedures to document and 

maintain a record of the UAS maintenance, 

preventative maintenance, alterations, status of 

pedromartinez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
US Department of Transponalinn 

Pedro Mart.inez -

31,2015 

Page 8 13 

Exemption umkr Tttle 1 Section ~333 

replacement/ overhaul component parts, and the 

total time in service of the UAS. These procedures 

will be added to the Operations Manual. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Pedro Martinez Aerial Photographer requests an exemption from the following 

Federal Aviation Regulations (FARs) as well as any additional regulations that 

may technically apply to the operation of the sUAV System: 

14 CFR Part 21- Airworthiness Certificates 

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates. 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 and Section 

333 of the FMRA 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 UAS. In all cases, an analysis of these criteria demonstrates that the 

UAS operated without an airworthiness certificate, in the proposed environments 

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 DJI Phantom III is to be operated hereunder is less than 25 pounds each 

including payload, carries neither a pilot nor passenger, carries no explosive 

materials nor flammable liquid fuels, and will operate exclusively within the 

parameters stated in the Operations Manual. 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, to provide security for the area of operation. These UAS will 

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

to national security. 

14 CFR Part 27: Airworthiness Standards: Normal Category Rotorcraft 

14 CFR Part 27 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. To the extent the Petitioner's DJI 

Phantom III would otherwise require certification under Part 27, as a rotorcraft, 

Petitioner requests an exemption from Part 27's airworthiness standards for the 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
US Dcpart:meni ofTransportation 

Pedro Maninez 

,luly 31, 201 

Page 9 of 13 

for Exemption under ion 

same reasons identified in the exemption request from item A. 14 CFR Part 21, 

Subpart H. 

14 CFR 45.23 Display of marks; general and 45.27 Size of marks. 

Aircraft Section 45.23(b) requires markings in letters not less than 2 inches nor 

more than 6 inches high the words. such as "limited, "restricted," and 

"experimental," as applicable. Section 45.27 requires that each operator of a 

rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by§ 45.23. 

Given the size of the UAS, two-inch lettering will not be feasible. The sUAS will 

also have no entrance to the cabin, cockpit, or pilot station on which the 

applicable words can be placed. An equivalent level of safety will be achieved by 

having any required words displayed on the aircraft, as applicable, in letters of 

legible size, in a location where the pilot, observer, and others working with the 

sUAS will see the identification. The FAA has issued exemptions to § 45.23 in 

Exemptions Nos. 10700, 8738, 10167, 10167A and 11062. The FAA issued an 

exemption to 45.27 in Exemption No.8496B. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a Private Pilot certificate may 

act as pilot in Command of an aircraft for compensation or hire. Subparagraph 

(b) allows a private pilot to act as pilot in command of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. Our proposed operations require that the PIC 

must hold at least a Private Pilot Certificate issued by the FAA and since the 

aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a 

business. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. We assume that the intent of this 

requirement is to ensure that flight manual information is available to the 

aircrew while operating the aircraft. We request an exemption to this 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
US Department of Transportation 

Pedro Maninez- FotoForionswa--Reqtwst for Exemption under Title -K'Fl< Section ;-;;33 

July 31, 

Page IO of 13 

requirement since the aircraft is not only too small to carry documentation, the 

documentation would not be available to the crew during flight operations. To 

obtain an equivalent level of safety and meet the intent of 91. 9, we propose that 

a current, approved sUAS Flight Manual must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight. 

91.103 Preflight action 

This regulation requires that the pilot in command shall, before beginning the 

flight, become familiar with all available information concerning that flight, 

including operating in the vicinity of airports, weather information, fuel 

requirements, and alternative actions if the flight cannot be executed as planned. 

Before every flight and to achieve an equivalent level of safety, the pilot not only 

will be familiar with the location of nearby airports and weather information to 

guarantee that the flight can be executed safely, but also will be aware of the 

environment around him, possible obstructions and duration of flight and 

battery energy, to guarantee a safe flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain 

flight tests. 

The regulation states that "No person may operate a civil aircraft that is being 

used for flight instruction unless that aircraft has fully functioning dual 

controls." The sUAS System ground based control station consists of a small 

hand-held radio transmitter and while it does not offer a second set of" controls", 

both the student and instructor can, and will, operate the single set of controls 

simultaneously. With both student and instructor having "hands-on" the 

controls during flight, we feel that this technique meets the intent 91.109 and 

provides an equivalent level of safety. 

14 CFR 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 

sUAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400' AGL. As set forth herein, except for the limited conditions 

stated in the Manual, the sUAS will never operate at altitudes higher than 400' 

AGL. It will however be operated in an area with perimeter, where buildings and 

people will not be exposed to operations without their pre-obtained consent. The 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
US Departmt>nt of Transportation 

Pedro Martinez- Fow.Fnrl~nsica-l<equest for i'>wmption 

,July 31, 2015 

Page 11 of 13 

Tnk 1 Section :333 

equivalent level of safety will be achieved given the size, weight, speed of the 

sUAS as well as the location where it is operated. No flight will be taken without 

the permission of the property owner or local officials. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 25lbs 

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 400' AGL. In addition, the low-altitude operations of the 

UAS will ensure separation between these small UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119. The 

FAA issued an exemption to this regulation in Exemption No. 11062. 

14 CFR 91.121 Altimeter settings 

The regulation requires that aircraft shall maintain cru1smg altitudes by 

reference to an altimeter setting available within 100 NM of the aircraft. The 

sUAS will always fly below 400 feet AGL and will not need to maintain cruising 

altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the 

sUAS on-board computer to the display screen held by the PIC, providing a 

constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions 

The regulation provides that no person may begin a flight in an airplane under 

day-VFR conditions unless there is enough fuel to fly to the first point of intended 

landing and to fly after that for at least 30 minutes. We feel the intention of this 

paragraph is to provide an energy reserve as a safety buffer for delays to landing. 

The sUAV is battery operated and the maximum duration of flight from a single 

battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly 

more than 1/8 NM from the point of intended landing, a full battery charge at 

launch will ensure that we meet the reserve energy requirement of this 

paragraph. We request an exemption to the word "fuel" and ask for an equivalent 

interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required 

The regulation provides that an airworthiness certificate, with the registration 

number assigned to the aircraft and a registration certificate must be aboard the 

aircraft. Additionally, subparagraph (b) provides that the airworthiness 

certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
US Depart.m.ent of 

Pedro Martinez FotoFor(~nsica -Request i()r Exe.m.ption under Title I 

,July 1, 2015 

Page l of l 

Section 33:3 

passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too 

small to carry documentation, does not have an entrance, and is not capable of 

carrying passengers or crew. To obtain an equivalent level of safety and meet the 

intent of 91.203, we propose that documents deemed appropriate for this aircraft 

by the FAA will be collocated with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose 

that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following 

information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 

CFR 45.23. 

14 CFR 91.401- 91.417 Maintenance, Preventive maintenance and Alterations 

This regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with 

part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

"approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform 

maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed 

inspections after every two hours of flight. Maintenance performed by the PIC is 

limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All 

other maintenance will be performed by the manufacturer or their designated 

repair facility. The PIC will document work performed in accordance with 91.417. 

We feel that due to the size, construction, and simplicity of the aircraft, the PIC 

can ensure an equivalent level of safety. 

Such Other Relief as the FAA Deems Appropriate 

Pedro Martinez Aerial Photographer also requests exemption from such other 

FARs as the FAA Grant of Exemption issued pursuant to this Petition, the FAA 

issues interim or final rules for small UAS, Pedro Martinez Aerial photographer 

requests that it be relieved of the requirements of any conditions and limitations 

of said exemption and allowed to comply with any less burdensome applicable 

regulations that may have become effective 

CONCLUSION 

Based on the satisfaction of the criteria provided in Section 333 of the FMRA 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377 
US Deparinwnt of Transportation 

Pedro Martinez FotoFon'cnsJcu--1\equesi for l:':xempiion HCFl< 

,July 3l, 2015 

Page :3 of 13 

regarding size, weight, speed, operating capabilities, proximity to airports and 

populated areas, operation within visual line of sight, and national security, 

Pedro Martinez Aerial Photographer requests that the FAA grant it the necessary 

exemptions under Section 333 of the FMRA as requested herein to allow the use 

of small UAS aircraft for inspection of construction projects, respecting the 

privacy of citizens and property while keeping our skies safe. 

If you need any additional information, please do not hesitate to contact us at 

--'~~:,.Ll~-3377. 

FG--'M~~~ - owner 

FotoForensica Aerial Photography 

pedromartfnez- aerial photographer Box 10197 San Juan, PR 00922 787-603-3377