August 20, 2015 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Dear Administrator: 

Coptergraphics PR would like the Federal Aviation Administration (FAA) to 

consider this letter as its formal Section 333, Waiver and Exemption. As a leader in 

the digital photography, television and cinematic industries. (CGPR) caters to a wide 

variety of photographic needs required to support of its clients, both private and 

commercial.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act”) and 14 C.F.R. Part 11, Coptergraphics PR an operator of 

Unmanned Aircraft Systems (“UASs”) for aerial photography and video on the real 

estate industry, surveying, agriculture industry, construction industry, motion 

picture industry, television industry and special events, hereby applies for an 

exemption from the Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UASs, 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. 

The specific section or sections of 14 C.F.R from which Coptergraphics PR seeks 

exemption: 

(CGPR) seeks exemption from applicable title 14 Code of Federal Regulations (CFRs) 

relevant to small Unmanned Aircraft System (sUAS), as defined by the FAA, 

operations. The below list, includes but is not limited to, regulations limiting sUAS 

operations. 

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

3. 49 USC § 44711 Prohibitions and exemption 

4. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 

5. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 

6. 14 CFR 91.119 Minimum Safe Altitudes. 

7. 14 CFR 91.121 Altimeter Settings. 

8. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions. 

9. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, 

and Alterations. 

10. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 

16(e)(1) Observer Medical. 

Coptergraphics PR

HC 02 Box 15710

Gurabo, Puerto Rico 00778
Coptergraphics PR is requesting relief from multiple regulatory constraints under 

title 14 CFR Parts 21, 45, 61, 65, 91 as well as other UAS regulatory guidance under 

FAA Notice 8900.227, Public Law 112- 95, Title 49 United States Code (USC), with 

regards to Unmanned Aircraft System (UAS) operations, more specifically sUAS 

commercial operations. 

An exemption is being requested because (1) Coptergraphics PR can provide a level 

of safety that is equal (or greater than in many cases) to those provided by existing 

rules, and (2) the request is in the public interest. The FAA’s authority to issue 

exemptions from operating rules, and the Secretary’s authority granted by Section 

333 of P.L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, provide an 

opportunity to authorize certain UAS operations in the National Airspace System 

(NAS) prior to implementation of the UAS rule. This incremental step and 

opportunity will allow Coptergraphics PR to safely and legally enter into the NAS. 

The requested exemption would permit Coptergraphics PR to operate UASs under 

controlled conditions in airspace that is (1) limited; (2) predetermined; (3) subject 

to controlled access, and (4) would provide safety enhancements to the already safe 

operations of those aircraft of similar size, weight, speed, and operating capability 

that have been granted entry into the (NAS) via the rules in Academy of Model 

Aeronautics (AMA) Code. 

Photos and Videos from several angles and height are far more effective than 

ground- based imagery for displaying the characteristics of large, complex 

properties with several buildings where helicopters cannot reach. It is known that 

charting a 2 seat full-sized helicopter or airplane for this purpose, has proven very 

costly and has limitations. The benefits of reduced cost, reduced noise interference, 

safety and improved quality of presentation from the UASs will be valuable to and 

benefit many real estate industry, agriculture industry, construction industry, 

motion picture industry, television industry, surveying and special events. The site 

based photography occurs in restricted or other areas where access to the public is 

strictly limited and controlled. Under virtually all circumstances, all of the only 

property or structures near the sites are owned and operated by the same entity 

soliciting the aerial photography services. As a result, the operation has no 

substantial impact on any third persons not involved in the actual site project. As 

established by the exemptions already granted by the FAA, approval of 

Coptergraphics PR exemption would enhance safety, new windows of opportunities 

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.” Section 333(c) of the Reform Act. 

Operation Overview 
UASs operated by Coptergraphics PR weigh less than 10 pounds, including the 

payload (first person view system, camera and gimbal). They operate at speeds of 

no more than 30 knots, can hover, and can simultaneously move vertically and 

horizontally. Coptergraphics PR will only operate its UASs in line of sight (VLOS) 

and will operate only within the operation manuals and authorize airspace. They 

will routinely be operated below 200 feet above ground level (AGL), and never 

about 400 feet AGL. Operations will always be conducted in areas that are clear of 

all people, except the pilot in command (PIC), PIC’s helper(s) or/and production 

crew. Such operations will insure that the UAS will “not create a hazard to users of 

the national airspace system or the public.” 

Given the small size of Coptergraphics PR’s UAS and the restricted sterile 

environment within which they will operate, Coptergraphics PR UAS operations 

adhere to the Reform Act’s safety requirements. Additionally, due to the size of the 

UASs and the limited areas in which they will operate, approval of this application 

presents no national security issues. Based on the substantial level of safety 

surrounding the proposed operations, and the significant public benefit (enhanced 

safety), reduction in environmental impacts (reduced emissions and noise), the 

grant of the requested exemption is in the public interest. Accordingly, 

Coptergraphics PR, respectfully requests that the FAA grant the requested 

exemption without delay. 

Aircraft 

Coptergraphics PR operates a Tarot 680 PRO and Inspire 1 series manufactured by 

DJI, as well-known leader in multirotor technology industries. DJI strives to bring 

new perspectives to aerial work and help companies accomplish feats safer, faster, 

and with greater efficiency. They have an unparalleled commitment to quality and 

safety, a culture of constant innovation, and a focus on transforming complex 

technology into easy-to-use devices. The Tarot multirotor package includes, 

camera, gimbal, propulsion system, flight control system, 2.4 GHz frequency remote 

controller. 

The Tarot is about 2 foot square in size. It has a maximum ascent speed of 11 knots, 

a maximum descent speed of 3 knots, and a maximum flight speed of 29 knots. 

While operating within VLOS, the remote control has a range of 2,624 feet. The total 

weight (including the payload) is 7.50 pounds. 

The Tarot 680 Pro is equipped with a DJI Naza-M V1 flight control system. This 

provides for incredible ease of use and stability. Pilots can control the Tarot’s 

movements in many directions – including pitch (forward and backward), roll (left 

and right), elevator (up and down), and yaw (turn left or right). The flight control 

system can also provide Intelligent Orientation Control (IOC), failsafe, battery level 

warnings, and with the on screen display system (OSD) shows to the pilot in 
command (PIC) the aircraft’s current reading, direction, and approximate distance 

from home on the on-screen radar, battery voltage, altitude, distance. The built-in 

GPS system aids in stabilizing the aircraft and automatically and safely returns it 

back to its home point in any case where communication between the remote 

control and multirotor are lost. 

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric 

altimeter that measures both attitude (ATTI) and altitude. The inertial 

measurement tells the Phantom how it’s tilted. And the gyros tell it if it’s rotating in 

any particular direction. 

The Tarot’s compass read geomagnetic information and assist the Global Positioning 

System (GPS) to accurately calculate the position and height of the aircraft. The 

vertical hover accuracy is +/- 2.6 ft. The horizontal hover accuracy is +/- 8.2 ft. 

The Tarot has LED flight indicators beneath each of its six rotor arms. The LEDs 

illuminate to indicate the orientation of the UAS. The status of the flight control 

system alert the (PIC) of any possible issues via established light codes are 

displayed by another led beneath the body of the UAV so it can be seen on the fly. 

The Tarot’s DJI Naza software has the capability to be upgraded via USB in a 

computer to enhanced performance with the latest software or firm available on DJI 

website. 

Such highly advanced capabilities will ensure that the SUASs can be safely 

operated and “not create a hazard to users of the national airspace system or the 

public.” As per Reform Act Section 333 (b). 

Equivalent Level of Safety

Detailed below is a list of operational safeguards Coptergraphics PR believes are 

essential for safe operations of which many have been previously approved by the 

Administer for similar sUAS operations. In addition, Coptergraphics PR will not 

commence sUAS operation that will create an undue hazard to users of the national 

airspace system (NAS), the public, or pose a threat to national security. 

Coptergraphics PR has published and/or adopted the following documents to be an 

integral part of its sUAS operations. 

Flight Operations Manual (Flight Ops Manual) 

Motion Picture and Television Operations Manual (MPTOM) 

DJI Published 

User Manuals 

Maintenance Manuals 

Safety Guidelines 

 

The operating limitations proposed by Coptergraphics PR provide for at least an 

equivalent or higher level of safety. In an effort to join the FAA in its mission to 
provide the safest, most efficient aerospace system in the world and to minimize the 

risk to the NAS or to persons and property on the ground. As a member of AMA 

(Academy of Model Aeronautics) member #949590, Coptergraphics PR agrees to be 

bound by the following limitations and conditions when conducting commercial 

operations under an FAA issued exemption as set forth in operator’s manual and 

UASs will be operated within the standards that the FAA has allowed in the 

Academy of Model Aeronautics (AMA) Safety Code: 

 

1. The UASs will weigh less than 55 pounds. 

2. Will not be flown in a careless and reckless manner. 

3. Will not be flown at a location where UASs activities are prohibited. 

4. Flights will be operated within line of sight of a pilot and/or observer. 

5. Maximum flight time for each operational flight will be 25 minutes. Flights 

will be terminated at 25% battery power reserve and will occur prior to the 

25 minute limit at about 15 minute flight time. 

6. Flights will be operated at an altitude of no more than 400 feet AGL, and not 

more than 200 feet above an elevated platform from which filming is 

planned. 

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

Observer, and the production staff. 

8. A UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the UAS Pilot, who possesses the necessary PIC qualifications, is also 

present on set, that person can also be designated as PIC. 

9. A briefing will be conducted for planned UAS operations prior to each day’s 

flight. All personnel performing duties within the boundaries of the safety 

perimeter are required to attend. 

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in 

light of the requested exemption, with the appropriate Flight Standards 

District Office (”FSDO”). 

11. The operator will obtain consent of all persons involved in the filming and 

ensure that only consenting persons will be allowed within 100 feet of the 

flight operation. With the advanced permission of the FSDO, operations at 

closer range can be approved. 

12. The operator will submit a written Plan of Activities to the FSDO three days 

before the proposed shoot. 

13. The Pilot and observer must be trained in UAS operations and have received 

current information on the particular UAS to be operated. 

14. The Observer and pilot will at all times be able to communicate by voice 

and/or visual signals. 

15. Written and/or oral permission from the relevant property holders will be 

obtained. 

16. 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. 

17. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security 

Perimeter and land. 

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

obstacles or emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot 

Preflight Action Plan 

The PIC will follow a comprehensive pre-flight checklist to ensure that the UAS is in 

a condition for safe flight. This plan will be improved as needed in order to ensure 

all known safety precautions and/or safety precautions suggested by the 

manufacturer are being accounted for. 

Preventative Maintenance 

Comprehensive preventative maintenance plan will be followed in order to ensure 

the UAS’s software is up-to-date, the batteries are in good health, and the aircraft 

itself is always ready for safe flight. 

Privileges and Limitations: 

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial 

operations. Because the UAS will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current operations by 

requiring the (PIC) operating the aircraft to have a sport pilot license rather than a 

commercial pilot’s license to operate a small UAS. Unlike a conventional manned 

aircraft, a UAS is remotely controlled by a ground-based operator. The operational 

area is controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated 

with the use of a UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 allowing UAS use by a private pilot 

as the (PIC) exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and 

(b). 14 C.F.R. § 91.103: Preflight Action Section 91.103 requires each pilot to 

preflight an aircraft before flight to insure the safety of flight. As FAA approved 

rotorcraft flight manuals will not be used, an exemption is requested. However, an 

equivalent level of safety will be provided. The (PIC) will take all actions, including 

reviewing weather, flight battery requirements, landing and takeoff distances, and 

aircraft performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 
91.119 provides, in pertinent part, that: “except when necessary for takeoff or 

landing, no person may operate an aircraft below the following altitudes: ..... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure.” 

Because Coptergraphics PR requests authority to operate at altitudes only up to 200 

feet and never above 400 feet, and not more than 200 feet above an elevated 

platform from which filming is planned, an exemption is needed to allow such 

operations. The UAS will never operate higher than 400 AGL. It will, however, be 

operated in a restricted area within a security perimeter, where buildings and 

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

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

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

the permission of property owners or local officials. Because of the advance notice 

to the property owners and participants in the filming activity, all affected 

individuals will be informed of the planned flight operations. Compared to flight 

operations for manned aircraft and the lack of flammable fuel, any risk associated 

with the proposed UAS operations is far less than conventional aircraft operating at 

or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure 

separation between a UAS and conventional aircraft.

14 C.F.R. §91.121 Altimeter Settings 

Section 91.121 requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As a UAS 

may not have a barometric altimeter, but instead a GPS altitude data, an exemption 

is needed. An equivalent level of safety will be achieved by the operator. 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed – (1) During the day, to fly after that for at least 30 minutes. 

The battery powering the Coptergraphics PR UAS’s provides approximately 25 

minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR 

§91.151, UAS flights will be limited to approximately 12-15 minutes in length. Given 

the limitations on the UAS’s proposed flight area and its proposed operations within 

a predetermined location, a longer time frame for flight in daylight VFR conditions is 

reasonable. Furthermore, operating the UASs in a tightly controlled area where only 

people, property owners, or official representatives who have signed waivers will be 

allowed, less than 30 minutes of reserve fuel does not engender the type of risk that 
§91.151(a) was intended to address. 

Coptergraphics PR believes that safety can be achieved by limiting flights to 12-15 

minutes or 25% of battery power, whichever occurs first. This restriction would be 

more than adequate to return the UAS to its pre-determined landing zone from 

anywhere in its limited operating area. 

Coptergraphics PR is not seeking an exemption for nighttime UAS operations. 14 

C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(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 in part 43 of this chapter...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Coptergraphics PR operations. 

Maintenance will be accomplished by the operator. An equivalent level of safety will 

be achieved because the UASs are limited in size, will carry a small payload and 

operate only in restricted areas for limited periods of time. If mechanical 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 flight, 

perform any required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the UAS and best suited to 

maintain it in an airworthy condition. 

Privacy

All flights will occur over private or controlled access areas with the property 

owner’s prior consent and knowledge. Filming will be only of people who have 

given their consent or otherwise have agreed to be in the area where filming will 

take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports; and populated areas and 

operation within visual line of sight and national security) provide more than 

adequate justification to grant Coptergraphics PR requested exemption, allowing for 

Coptergraphics PR UAS commercial operations for the aerial photography on real 

estate industry, agriculture industry, construction industry, motion picture, 

television industry, surveying and special events. 

Summary for Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed: 
Coptergraphics PR seeks an exemption under Section 333 from the following rules: 

14 C.F.R. Part 21, Subpart H; 61.23 (a); 61.113(a) and (b); 91.103; 91.109; 

91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 

91.417(a) and (b) to operate commercially a small unmanned aerial vehicle or UAS. 

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations will enhance safety by reducing risk. Conventional film 

operations, using turbine aircraft or helicopters, operate at low altitudes and 

present the risks associated with aircraft that weigh around 4,000 pounds, and 

which carry large amounts of Jet A fuel. Such aircraft must also fly to and from the 

film location. In contrast, a UAS weighing fewer than 10 pounds and powered by 

batteries eliminates virtually all of that risk given the small size and lack of 

combustible fuel. The UAS is carried, and not flown, to a film set. In this regard, the 

UAS carries no passengers or crew and, therefore, will not expose them to the risks 

associated with manned flights. 

The operation of UASs conducted in the strict conditions will provide an equivalent 

level of safety supporting the grant of the exemption requested herein. The UASs 

operate at slow speeds, close to the ground, and in a sterile environment. As a 

result, they are far safer than conventional operations conducted with turbine 

airplanes or helicopters carrying fuel and flying near the ground and people. 

If you have any questions or need any additional information, please contact the 

undersigned Coptergraphics PR, Attn: Ismael Solá Gotay; Ph: 787-210-2052; Email: 

coptergraphicspr@gmail.com; Physical Address: Calle Rio Cana, E-5 Hato Nuevo 3

Gurabo, Puerto Rico 00778; Mailing Address: HC 02 Box 15710, Gurabo, P.R. 00778.

Sincerely yours, 

ISMAEL SOLA GOTAY 

COPTERGRAPHICS PR