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June 1, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and

Part 11 of the Federal I Aviation Regulations

Dear Sir or Madam:

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

"Reform Act") and 14 C.F.R. Part 11, Alejandro Araya dba AA FLY DRONESFL.llc, 

the operator of small Unmanned Aircraft Systems ("sUAS"), seeks an exemption 

from the Federal Aviation Regulations ("FARs") listed below and discussed in 

Appendix A. Attached as Appendix B is a summary of this request.

The requested exemption would permit commercial operation of Alejandro Araya

dba AA FLYDRONESFL sUAS's, which weigh approximately 10 lbs. And performs 

aerial surveys and videography that consists of still photographs and 

videography taken by on board cameras. The sUAS's takes a series of high 

quality, still digital images and video that are used to promote real estate sales

and survey in South Florida. Additional aerial inspections/survey applications 

may include construction jobsite monitoring, pipeline inspection and precision 

topological surveys. Use of the sUAS for aerial inspections and surveys reduce 

the need to utilize conventional manned aircraft, manned lifting devices or 

manned climbing for the same purpose and provides very high quality imagery at 

a fraction of the cost. These savings result in enhanced safety, efficiency and 

productivity for the affected activities, as well as environmental benefits.

Operations under the exemption will be subject to strict operating requirements 

and conditions to ensure at least an equivalent level of safety to currently

authorized operations using manned aircraft and under conditions as may be 

modified by the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize 

commercial operations of aerial photos and inspections or surveys using the 

sUAS's, which weigh less than 10 lbs. and are small in size. (See attached O&M 
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manuals for the 3DR SOLO and TAROT T6). The sUAS's will be operated under 

controlled conditions at low altitude in airspace that is limited in scope, as 

described more fully herein; it will have automated control features as described

below and in the O&M manuals. The sUAS also will be operated by an individual 

who has FAA Private Pilot License. Finally, the airspace in which the sUAS will 

operate will be Class G airspace or airspace approved by the FAA in

advance.

Alejandro Araya dba AA FLY DRONESFL respectfully submits that because these 

small, unmanned aerial vehicles will be used in lieu of comparatively hazardous 

operations now conducted with fixed wing and rotary conventional aircraft or 

other manned means of inspections, the FAA can have confidence that the 

operations will achieve at least the equivalent level or greater level of safety. 

Approval of the exemptions would thereby enhance safety and fulfill the 

Secretary of Transportation's (the FAA Administrator's) responsibilities under 

Section 333(c) of the Reform Act to "establish requirements for the safe operation 

of such aircraft systems in the national airspace system."

The name and address of the applicant are:

Alejandro Araya dba AA FLY DRONESFL 

Att: Alejandro Araya

Ph: 954-661-7469

Email: alexawl@bellsouth.net

Address: 5900 NE 2 Terr

 Oakland Park, FL 33334

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133 (a);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);
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14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2};

14 C.F.R. 91.417(a) & (b).

Appendix A discusses each rule listed above and explains why exemptions 

pursuant to the proposal set forth in this letter are appropriate, provide an 

equivalent level of safety, and are in the public interest.

The Applicable Legal Standard under Section 333

Alejandro Araya dba AA FLYDRONESFL submits that grant of this exemption 

application for use of the proposed UAS's in precision aerial inspections will 

advance the Congressional mandate in Section 333 of the Reform Act to 

accelerate the introduction of UASs into the national airspace system ("NAS") if it 

can be accomplished safely. This law directs the Secretary of Transportation to 

consider whether certain UASs may operate safely in the NAS before completion 

of the rulemaking required under the Section 332 of the Reform Act. In making 

this determination, the Secretary is required to determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national 

security in the light of the following:

• The UAS's size, weight, speed and operational capability;

• Operation of the sUAS in closed proximity to airports and populated 

areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act §333{a)(1). If the Secretary determines that such vehicles "may

operate safely in the national airspace system, the Secretary shall establish 

requirement for the safe operation of such aircraft in the national airspace 

system." ld. §333(c) (emphasis added). 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil 

aircraft, as the term is defined under §40101 of the Act, from the requirement that 

all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from. a requirement of a regulation
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prescribed under subsection (a) or (b) of this section or any of the sections 

44702-44716 of this title if the Administrator finds the exemption is in the public 

interest.

Applicant submits that this provision places a duty on the Administrator to not 

only process applications for exemptions under Section 333, but for the 

Administrator, if he deems the conditions proposed herein require modification in 

order to allow approval, to supply conditions for the safe operation of UAS. Todd 

Thomas dba Drone Pies welcomes the opportunity to consult with FAA staff in 

order to address any issues or concerns that this proposal may raise that they

believe may require modification.

49 U.S.C. §44701(f). See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. 

§91.203(a)(1). 

The grant of the requested exemption is in the public interest based on the clear 

direction in Section 333 of the Reform Act; the additional authority in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations; and the significant public benefit, including enhanced 

safety and cost savings associated with transitioning to UASs for aerial 

inspections and survey photography and real estate photography. Accordingly, 

the applicant respectfully requests that the FAA grant the requested

exemption without delay.

Airworthiness of the sUAS

A critical element of the exemption application involves evidence of the 

airworthiness of the sUAS. The Federal Aviation Act (49 U.S. C. §44701 (f) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated 

areas of the particular sUAS. Our small UAS's will operate at low speed in a

controlled environment, at least five miles from an airport or densely populated 

area. An analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be a least as safe, or safer, than a conventional aircraft (fixed wing 

or helicopter) operating with an airworthiness certificate without the restrictions 

and conditions proposed.

Mandatory Operating Conditions (see O&M and Safety lists)
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Grant of the exemption to Alejandro Araya dba AA FLY DRONESFL will be subject 

to the following mandatory conditions, which are based upon operating 

conditions set forth for operation of sUAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to avoid congested or populated areas, which are depicted 

in yellow on VFR charts.

• Operations to be conducted over private or controlled-access property.

• Permission from land owner/controller required before commencing 

flight.

• Operations to occur during Visual Flight Rules Meteorological 

Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS). 

VLOS guaranteed with a cylinder of operation around operator of 1⁄2 

nautical miles (NM).

Cylinder walls may be expanded by observer with ability to control 

aircraft.

• Operations to occur during daylight hours.

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 

NM from

• centerline azimuth of runway centerline measured from runway 

thresholds

• All required permissions and permits will be obtained from territorial, 

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

or other appropriate governmental agencies. 

Operator Requirements

Alejandro Araya dba AA FLYDRONESFL respectfully purposes that operator 

requirements should take into account the characteristics of the particular UAS. 

Certain UASs, such as the 3DR SOLO are characterized by a high degree of 

control and various built-in technical capabilities that limit the potential for 

operation outside of the operating conditions set forth above. Please see details 

in the attached O&M manuals.

Additional automated safety functions and safety enhancing features of the 

sUAS's include the following:
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• Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate return to aircraft take-off location ("home").

• Low power on the aircraft triggers escalating alarms at GCS.

• If the auto-pilot detects a lost-link to the GCS, landing procedure begins.

Given these safety features, Alejandro Araya dba AA FLYDRONESFL proposes 

that operators of the sUAS should not be required to hold a commercial pilot 

certification. Instead, operators should be required to:

• Hold a private pilot license.

• Have completed the manufacturer's training or a minimum of 10 hours 

training program for operation of the sUAS's.

Alejandro Araya dba AA FLYDRONESFL notes that the FAA has found that safety

factors permitted operation of sUASs by operators with these qualifications in the 

case of operations pursuant to public COAs when the mandatory operating 

conditions specified above were present. See Federal Aviation Administration, 

Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 

20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to 

the requirements for and privileges associated with the grant of airmen's

certificates. 49 USC §44701 (f).

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In summary, applicant seeks an exemption from the FARs set forth above in 

Appendix A to allow commercial operations of a sUAS's conducting precision 

aerial inspections or surveys and real estate photos.

Approval of the exemption allowing commercial operations of the sUAS for 

precision inspection, survey work, and real estate photos will enhance safety by

reducing risk. Conventional aerial inspection, survey operations, and real estate 

photos, using jet or piston powered aircraft present risks associated with 

vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry

large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft 

must fly to and from the survey location. Other conventional manned climbing or

manned lifts risk safety hazards associated with falls, electrical hazards, fuel 

related hazards, and inhalation associated with the structures being inspected. In 

contrast, a sUAS weighing less than 15 lbs. and powered by batteries eliminates a 

portion of that risk given the reduced mass and lack of combustible fuel carried 

on board a manned aircraft and the lack of risks associated with manned lifts or 

manned climbing apparatus. The sUAS will carry no passengers or crew
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and, therefore; will not expose any individuals to the risks associated with 

manned aircraft flights, manned lifts or climbing hazards. 

Additionally, no national security issue is raised by the grant of the requested 

exemptions. Given the size, load carrying capacity, speed at which it operates, 

and the fact that it carries no explosives or other dangerous materials, the sUAS 

poses no threat to national security. 

The operation of the sUAS, weighing less than 15 lbs ., for inspections, surveys, 

and real estate photos in accordance with the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting Alejandro Araya dba AA FLY DRONESFL

from the requirements of Part 21.

The sUAS's satisfaction of the criteria set forth in Section 333 of the Reform Actsize, weight, speed, operating capabilities, lack of proximity to airports and 

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

it’s showing of an equivalent level of safety as it may relate to the requirement for 

FAA training, provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of the sUAS in the

commercial aerial inspection, survey, and real estate photo business.

Very truly yours,

Alejandro Araya

Owner

AA FLYDRONESFL

Enclosures:

Appendix A: Exemption Request and Equivalent Level of Safety Showings under

Applicable Rules Subject to Exemption

Appendix B: Operation and Maintenance Manuals:

3DR SOLO, TAROT T6 O&M Manual

Appendix C: Safety Checklists