October152015 U. S. Departmentof Transportation DocketManagementSystem 1200NewJerseyAve, SE Washington, DC20590

Stacey Restrepo is a Student Re: Section 333Exemption RequestPursuant To Section 

### 3 3 3 ofthe e FAA Reform Act of 2012

DearSirorMadam, Pursuant to 

### §333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11,

Stacey Restrepo, operator of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photography for the Real Estate advertising in controlled areas, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation ofits sass, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal! Aviation Administration (FAA) as required by 

### §333. StaceyRestrepo current operation ofsUASs for commercial purposes has been halted to comply with recently enacted d federal aviation regulations pertainingto sUAS. As described fuller y below, the requested exemption would permit the operation of small, Unmanned and relatively inexpensive multi-rotor Aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on site safety personnel controlling access, and 4) would provide increased safety and enhancements to clients' business operations. The name and address ofthe applicantis:

StaceyRestrepois a Student Address: 12244 Triton Lane, OrlandoFL32837 StaceyRestrepoPh:+I (980-621-5384) Email: staceyrestrepo@gmail.com

I, StaceyRestrepo, respectfully requests agrant ofan exemption ofthe following sections ofTitle 14 ofthe Code ofFederal Regulations: 14 CFR 21; 14 CFR 91, et seq.; 14 CFR 45.23 (b); Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 • 14 CFR 61.113 (a) & (b);

. 14 CFR407 (a)(l); 14 CFR409 (a)(2); • 14CFR417(a)&(b). I, StaceyRestrepo also respectfully requests anExemption from Section 

### 333 ofthe FAAReform Act and Part 11 ofthe Federal AviationRegulations from: 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.1 1 3 (a) & (b); 91.7 (a); 91.9(b)(2); 91.103(b);

• 91.109; 91.119; • 91.12 1 ; 91.151(a); 91.203(a) & (b); 91.405 (a);

• 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). TheExtent ofReliefStaceyRestrepo Seeks andthe Reason It Seeks Such Relief: Stacey Restrepo submits this application in accordance with the Reform Act, 112 P.L. 95§§331334,Seeking relief from any currently applicable federal aviation regulations PARs Pertaining to sUAS (unmanned aircraft systems) and operating to prevent Stacey Restrepo Contemplated commercial photography, videography and other flight operations withintheU.S. national airspace system.

The Reform Act in §332 provides for such integration ofcivil UASs into our national airspace system as it is in the public's interestto do so. StaceyRestrepo lightweightUASs
meet the Definition of"small unmanned aircraft" as set forth in §331 and combined with

a sterling safety Record in similar industries, John M Restrepo light duty sUAS are ideal recipients ofexemptionBythe intent ofthe ReformAct. Considerations for reliefinclude a combination ofsUAS physical characteristics, safety features, And safepractices identified in §333:

• sUAS weight, • sUAS overall size, • sUAS speed over ground,

• sUAS flight zone characteristics, Non Operation near airports (civilian or military), tightly controlled operation m populated areas,

StaceyRestrepo isa Student.

The client. Specific consideration is outlinebelow. Re: ExemptionRequestPursuant To Section 333 of the FAA ReformActof 201 2 Operation ofthe UAS by VLOS by 14 C.F.R. Part2 1 , Subpart H: Airworthiness Certificates 14 C.F. R. §91.203 (a) ( I) SubpartH, Entitled Airworthiness Certificates, establishes the procedural requirement s for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1 ). Given the size and limited Operating area associated sUAS, an exemption from Part 21 SubpartH meets the requirements Ofan equivalent level ofsafetyunderPart 11 and §33 3 ofthe Reform A
ct. llle Federal Aviation act (49 U.S.C.§4470 1 (f)) and §333 ofthe Reform Act both authorize the FAA to exempt Aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weigh, ht, speed, operational capability, and proximity to airports and populated areas ofthe Particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated Without an airworthiness certificate, in the restricted environment and under the condition Proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) Operating with an airworthiness certificatewithouttherestrictions and conditionsproposed.TheUAS to be operatedby StaceyRestrepo isles sthan 11 kg.with maximal payload Consisting of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including combustible I e fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemptionwill betightly controlled and Monitoredbythepilot (P I C), whose role is designated to act as boththeremote sensing Controller and secondary monitor for safety issues, and a technician, which assists in
matters related to maintaining the sUAS and also monitors for safety concerns and liaisons to the onsite safety officials. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree ofsafety to the public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no intrinsic credible threat to national security posedby the UAS, due to its size, speed ofoperation, location ofoperation, lack of intrinsic explosive materials or flammable liquid fuels, and inability to carry a substantial extern a lload. 1 4 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches no more than 6 inches high, the words " limited ;' "restricted;' "lights port;' "experimental;' or "provisional;' as applicable. 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 beplaced. Giventhe size ofthe sUAS, two inch lettering will be impossible. The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size suitable for the available space. The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and othersworking with the sUAV will see the identification ofthe UAS as "Experimental." The FAAhas issued the following exemptions tothis regulation to Exemptions Nos. 10700, 8738, 101 67 and 101 67A. Further markings include the use offlashing green LED illumination onthe underside of the sUAS frame which stands at contrast against ablue orwhite sky. StaceyRestrepo, Student Re: ExemptionRequestPursuant To Section 333 of the FAA ReformActof2012 14 C.P. R. §6 1.11 3 (a) 

### & (b): Private Pilot Privileges and Limitations: Pilot in Command. §61.113 (a) 

### &(b) limit private pilots to non commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations by requiring a ground crew member to have aprivatepilot's licenseratherthan a commercialpilot's license to operate this sUAS.

# ..

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplatedby Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 C.P.R. §61.1 1 3 (a) 

### & (b). 1 4 C.P.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, shouldthis exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check lists prior to each flight, a subset ofwhich are provided in enclosed Supplemental material, an equivalent level ofsafetywill beprovided. 14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in t h e Aircraft. §91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft

... (2) For which an Airplane or Rotorcraft F light Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft FlightManual, approved manual material, markings, and placards, orany combinationthereof. The sUAS, given its size and configuration has no ability to carry a physical flight manual on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. §9 1.10 3: Preflight action this regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the help ofsUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizationsto ensure best safepractices are adhered to. 14 C.P.R. §91.1 09: Flight instruction §91.103 provides that no person may operate a civil aircraft (except a manned free balloon)that is being used for flight instructionunless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size andStaceyRestrepo, Student Section 333ExemptionPetition



### Re:ExemptionRequestPursuant To Section 333 of the FAAReformActof 2012 Speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls utilizing digital communications which is paired to the sUAS making it nearly impossible to unintentionally or intentionally have the control communications interrupted. 1 4 C.F.R. §9 1.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation ofcivil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimum s 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 closely mimics the behavior ofa helicopter, and the exemption requests authority to operate at altitudes up to 400 AG L, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual line ofsight, whichever is closer. Itwill however be operated in a restricted area with security officials tasked with ensuring public safety

, and where buildings andpeople will notbe exposed to operations without theirpre obtained consent and training. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS

as well as the location where it is operated. No flight operation will be taken withoutthe permission ofthe property owner in t he case ofprivate property or local officials In the

case ofpublic property or private property with public interests. Because ofthe advance notice to the property owner and participants in the remote sensing activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft orrotorcraft weighting far more than the maximum 11kg ofStaceyRestrepo sUAS proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional air craft operating
at or below 500 AGL. In addition, the low altitude operations ofthe sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft thatmust comply with §91.119. 14 C.F. R. § 91. 1 21 Altimeter Settings §91.121 requires each person operating an aircraft to maintain cruising altitude e by reference to an altimeter that is set "

...to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out. An equivalent level ofsafety will be achieved by the operator, confirming the altitude ofthe launch site shown on the GPS altitude. indicator before flight. The operator will also ensure effective pairing with multiple GPS sources to guarantee accurate detection ofheight. 14 C.F.R. §9 1.151 (a): Fuel Requirements for Flight in VFR Conditions §9 1.1 5 I (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind an d forecast weather conditions) there is enough fuel to fly tothe first point ofintended landing, and, assuming normal cruising speed (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at 1east45 minutes:' Thebattery powering the sUAS provides approximately 15 minutes ofpowered flight in hovermode withoutpayload. StaceyRestrepo sUAS will notbe able to meetthe 30 minute reserve requirement in 14 CPR §9 1.15 1. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve power , does not engender the type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Stacey Restrepo believes that an equivalent level of safety can be achieved by limiting flights to » 10 minutes or less that 50% ofbattery
power 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, and 10808 Stacey Restrepo, Student Section 333 Exemption Petition Re: ExemptionRequestPursuant To Section 333 of the FAA ReformActof 2012 1 4 C.P.R. §9 1. 2 0 3 (a) & (b): Carrying Civil Air craft Certification and Registration Theregulationprovides inpertinentpart: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within itthe following: (1) Anappropriate and currentairworthiness certificate

... (b) Noperson may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorizationissuedunder §91. 715 is displayed atthe cabin orcockpitentrance sothatit is legibletopassengers or

crew. The sUAS fully loaded weighs no more than llkg and is operated without an onboard pilot. As such, there is no ability orplaceto carry certification and registration documents

or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control pointwherethepilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes ExemptionNos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 1 4 C.P. R. §9 I. 405 (a); 4 0 7 (a) (1) ; 4 0 9 (a) (2); 4 1 7(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed inpart43 ofthis chapter

... ;'and others shall inspectormaintain the aircraft in compliancewith Part 43. Giventhat these section andPart43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a smallpayload and operate only in restricted areas for limitedperiodsoftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalentlevel ofsafety. An exemption granted to Stacey Restrepo would permit its operation of lightweight, unmanned, remotely controlled, sUAS in a tightly controlled environment with limited airspace. John M Restrepo, utilizes local business' safety officers in specifically determined areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goals. Technical enhancements to current safety controls will allow StaceyRestrepo, to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented by the FAA and Department of Transportation. Further, Stacey Restrepo conducts its operations in compliance with protocols described here inor as otherwise establishedbytheFAA. 

### II. Commercial and Public Benefits; 

### I Stacey Restrepo, 

### believe that granting this exemption request furthers the public interest byproviding safe (by way ofan unmanned system) and efficient

means to Stacey Restrepo client base are typically small to medium sized business' looking to increase their awareness ofrespective properties. Aerial videography and photography for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners and homeowners its expensehas been costprohibitive. Granting this exemption to the petitioner would allow him to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to thepublic given its small size and lack ofcombustible fuel when compared to larger manned aircraft. The petitioner also states that the operation ofhis UAS will minimize ecological damage and promote economic growth by providing information to small businesses and individuals looking to relocate orbuild in the Orlando Floridaarea. StaceyRestrepo

, Student Section 333 Exemption Petition Re: ExemptionRequestPursuant To Section 333 of the FAA ReformActof2012 By photographic or videography. By moving these functions onto sUAS based air craft, the potential for loss of life or property is diminished due to the greater control in a smaller and safer aircraft that holds no persons. Second, there are no reactive or combustible materials onboard the sUAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability ofStaceyRestrepo UASs allowthe PIC to avoid hazards. Accordingly, StaceyRestrepo UASs have operated and will continuetooperate at and above current safety levels.A. The costs and benefits of your proposed action to society in general and specific groups within society as described above, Stacey Restrepo past customers have been smallto mediumbusiness seeking Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense ofsuch aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic rash that the various communities have experienced in the past with military aircraft and medical helicopter crashes within an even cities. Each resulting in loss oflife, each with combustible fuel that exploded andburned on impact. My, StaceyRestrepo, UAS pose no suchthreat since size and lack ofcombustible fuel alleviates anypotential threattothepublic. Congress has already proclaimedthatit is inthepublic's interestto integrate commercially flown UAS's into the national airspace system, hencethepassing ofthe Reform Act. Granting my, Stacey Restrepo's, exemption request furthers the public interestthrough academic/visual awareness ofthe geographical benefits in and around the NWFlorida area. My ultra light weight UAS is battery powered and creates no emissions that can harmthe environment. The consequence ofmy ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and cancause catastrophic devastationto thepublic. Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an on board pilot, time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civilian or military airports, and detrimental effects to the environment caused by operating a combustible fuel based, large scale aircraft, withrestrictions ontheproximityto thetarget for remote sensing.

Flight Capabilities and Characteristics ofStacey Restrepo UAS s Pursuant to 112 P.L. 95§333 (a), concerns forpublic safety are mitigatedby the overall capabilities and characteristics of the sUAS. Stacey Restrepo UAS s utilizes four (4) rotating 9 inch plastic propellers paired oppositely to each other for balance, control and stability. The total span ofthe sUAS is less than ""'1.2 m allowing for stable flight orlanding even with the sudden onset ofdetrimental environmental conditions. The sUAS's have a maximal unit+ payload mass of 11kg, including cinematic/photographic or other surveying equipment. Stacey Restrepo sUAS is designed to primarily hover in place to capture photographic data and then operate at less than a 35 knot maximum speed to the next point ofinterest. They are capable ofvertical and horizontal operations but, in practice, is operated only within VLOS by the PIC. In addition thePIC,

StaceyRestrepo is a Student Section 333ExemptionPetitionRe: ExemptionRequestPursuant To Section 333 of the FAA ReformActof2012 Offand otherwise minimizepedestrian access in the flight zone ofthe client's grounds. In the event ofloss ofvisual ofthe UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r, a ,h) based controls which allows the PIC to utilize

one controller axis to recall the UAS to the PIC's position without concern to the current heading ofthe sUAS. In the event ofloss ofsight ofthe sUAS into an area containing hazards or possible hazards, the spotter has a heads up display containing a live video feed which can be used to locate the UAS while it maintains its position in hover mode. The sUAS has demonstrated its ability to maintain its position by GPS coordinates in hover mode in 25 kts or greater wind gusts at rvr less than 25 feet representing an extreme environmental condition beyond the range of conditions within the scope for sUAS operation. All of Stacey Restrepo sUASs utilize LiPo (lithium polymer) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten (1 0) minutes allowing the staffto work with small flight areas per phase. The maximum flight time without payload is 25 minutes, however practical safe operation limits this to 10 to give ample time to control the sUAS to a safe landing zone. Stacey Restrepo further restricts flight time by not operating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows John M Restrepo's sUAS
to hover in place ifcommunication with the PIC is lost and optionally follow a set of waypoints at a set speed and height to a 'home base' predesignated safe landing zone. In the event ofUnforeseen motor(s) failure, the system will enter into a controlled descent while allowing full use ofall UAS flight controls by the PIC. All commands sent via
remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight controlpackagewill use it's real time 3 dimensional position and compensate rotors control the sUAS regardless ofspin velocity. This assures that if one system is compensated a safe and successful landing can still

occur. IV. Reasons Why an Exemption to Stacey Restrepo Will Not Adversely Affect Safety Standards StaceyRestrepo contends that operation ofits sUASs will not "create a hazard to users of the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight ofStacey Restrepo sUASs, combined with their operation in cordoned off and well-controlled areas, Stacey Restrepo sUAS falls within Congress's contemplated safety zone. Stacey Restrepo sUASs have an established safety record bolstered by multipoint Preflight check list, awareness of their surroundings and intimate knowledge of the behavior of the sUAS platform in many weather conditions. This safety record and implemented operational practices demonstrate an awareness of public safety. Stacey Restrepo's operations routinely provide a level ofsafety at least equal to existing rules, and in nearly every instance, exceeds existingrules.Stacey Restrepo has worked very closely with the regional vendors and support for this unit to create a tightly integrated and highly tolerant platform that has been tested thoroughly by avendorwith aprovenrecord for safety and solid designs. StaceyRestrepo also continues to work closely with organization to identify and mitigate sUAS platform risk due to their expertise in several industries closely related to the aviation and transportation. StaceyRestrepo does notoperate its UASs on ornear airports and generally has only operated its sUAS onprivate grounds with cordoned offareas or

areas under the control ofthe property owner 

### I client with assistance by safety officials. StaceyRestrepo determines the areas needed to fulfill the clients ' goals and only operates its UASs in these flight zones and only in compliancewith well regarded safetyprotocols
set forth initially bythe RC UAS trade and hobby groups.

StaceyRestrepo, Student. Section 333ExemptionPetition Re: ExemptionRequestPursuant To Section 333 of the FAA ReformA ctof 20 12John M Restrepostandardizedonthe following practices to ensure safe operation ofits UASs:

• Work with onsite personnel to plan the flight goals, • Work with onsite personnel to restrict accessto non essential persons, • Operationby unaided VLOS operation only,

• Operation inphases 10 minutes in length

• Operationto minimal25%batterypower

• Operation ofdevice to GPS aidedreadoutto 300 ftat maximum,Numerous preprogrammed fail safesthatensure specificbehaviorper issue

• Perform a site check day(s) before flight t o identify potential issues, Subscribe to relevant local weather and safety alerts,

• Expertly choose data collection instruments and accessories tominimize flight requirements orexpertise,

• StaceyRestrepo has experience in similarfields and has adapted this experience in it's

use ofUASsto increase safety. Incombinationtothe ever expandingknowledge repositories from hobbyists and experts alike, StaceyRestrepo is constantly evolving it's practice s whenthere is a clearbenefitto operations orincreased safety element. A. Summary Pursuant to 14 C.F. R. Part 11, the following summary is provided for publication in the FederalRegister, should itbe determined thatpublication is needed: John Mario Restrepo {applicant) seeks an exemption from the following rules: 14 C.P.R. §2 1, subpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 91.109; 91.119; 91.121; 91.15l(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (a) (2); 91.409 (a) {2) and 91.417 (a) 

### & (b) to operate commercially a small unmanned vehicle (11 kg or less) in elevatedphotographic and remote sensingoperations.Approval ofexemptions allowing commercial operation s ofsUASs inthe mediaindustry will enhance safety by reducing risk associated with conventional aircraft operations and other means ofelevated remote sensing involving persons. The public benefit served by approval of this petition is increased awareness of characteristics of difficult imaging targets. A sUAS weighing fewer than II kg and poweredby sealed batteries eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity
tobuildings orpersons or otherwise elevating persons to aposition they would be able to collectneeded data. The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements ofPart21 and allowing commercial operations. StaceyRestrepo Student. Re:ExemptionRequestPursuant To Section 333 of theFAAReformActof2012 Also experienced in flying Unmanned Aircraft Systems (U.A.S) for recreational purposes. Recognizedby the community as aprofessional realtor. The FAA has been given the authority t o issue the exemption to Stacey Restrepo pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek
yourconsideration and approvalofthispetition. encl: Supplement A: Physical characteristics of UAS encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in StaceyRestrepo's regionalbase. 

### VI. SupplementB: SummarySections of Flight Operations andProcedure Manual (FOPM) • All regular and irregular operations are noted with timestamps, relevant UAS metrics and corrective action procedures (CAP) thatareperformed. Note: All irregular behavior have root cause analysis performed before UAS operation is resumed. Emergency Procedures •Loss ofRemote Signal -The flight package features an optional enhanced failsafe whichreturns the sUAS to thehomebasewaypoint viathe samepathtakentopointoflost signal. -The UAS will then perform a hover over this waypoint and then a controlled landing. •Loss ofGPS signal -The system will operate in GPS assisted mode with three (3) satellites. At loss ofthree (3) GPS satellites, manual mode can be activated or the flight package can be programmed to perform a controlled landing to the home base waypoint.

- Ground based height ranging is performed by a separate system and so loss of GPS will not impact controlled landing in a safemanner. •Loss ofEnginePower -Inthe event ofone (1) (ortotwo oppositelypositioned)rotor ormotor failure the system will enterinto controlled spin where all controls aretranslated basedon current orientation and will behave as normal operationto thePIC to ensure a safe landing,-In the event ofmultiple rotor or motor failures the flight package can be configured to perform a safe landing orattempt operationto homebasewaypoint.

- Note: Behavior ofthe landing location is highly dependent onthe position and number ofrotors/motors that are affected.

• Loss ofGround Control Software

- This will not affect operation ofthe flight. The unit will be Piloted to a safe landing area and then landed so that examination ofthe link can be made.

TYPHOON Q5004K

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