June, 11 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Bobby Rodriguez

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT 

OF 2012 (PUBLIC LAW 112-95)

Bobby Rodriguez

Independent Contractor 

618 45th Street

West Des Moines Iowa 50265

850-974-0538

Bobby.Rodriguez21@gmail.com
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
SUMMARY

Bobby Rodriguez (independent contractor) From her on out referred to as BRIC seeks exemption from 

the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit BRIC to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography of construction sites, residential and commercial real estate, civil landscapes and events over 

certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

BRIC has for 10,000 hours Pilot in Command (PIC) and Maintainer in combination with the Scan Eagle 

UAS ,INSITU(A Boeing Owned Company), Aerosonde UAS (Textron Systems Company) The A160 

Humming Bird Rotor Craft UAS and S100 UAS(The Boeing Company). I deployed overseas to different 

locations working American Government contract programs supporting Operation Enduring Freedom 

with the US Marine Corp, US Navy and US Army special forces teams. This includes sensor operations 

of each UAS platform as well.

My objective is to use the skills I have gained during the training and real world operations to provide 

affordable high-quality production system for a variety of governmental, commercial, public, and

residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

I have safely flown small RC electric quad copters recreationally for approximately 4 years without 

incident.

BACKGROUND

Unmanned Aircraft Systems: Blade Yuneec Typhoon G, Blade QX3 350 and Blade Chroma Camera 

Drone will be referred to as UAS.

I seek an exemption to operate UAS for compensation or hire within the NAS. The UAS is vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The UAS has a maximum gross weight of approximately 60oz. 

while having a diagonal dimension of 23.2”, a maximum speed of approximately 8m/s and a maximum 
flying height of 400'. UAS is equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors.

UAS that will be operated by Bobby Rodriguez will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance 

with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, BRIC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and 

the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the UAS in the 

National Airspace System(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a) 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In 

consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft 

and its operation, BRIC operator of UAS meets the conditions of FMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, 

BRIC requests relief from Sections 91.405(a) 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as 

these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. BRIC submits that the requested relief is proper since an equivalent level of safety will be 

ensured. BRIC will use his experienced A&P License #3659366 to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and UAS Instruction Manual). Furthermore, BRIC 

will document and maintain all maintenance records for the UAS. Relief from certain requirements of 

Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested 

by BRIC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum 

flight hour s and currency requirements, that the PIC is able to safely operate the UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. BRIC seeks relief from Section 91.7(a), entitled 

Civil aircraft airworthiness, because the UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, BRIC submits that they will ensure that the UAS is in an 

airworthy condition, prior to every flight, by determining that the UAS are in compliance with the 

operating documents (i.e. Monthly Maintenance Log, and UAS Instruction Manual) and that the aircraft 

are in a condition for safe flight. BRIC also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the UAS will not have a typical barometric altimeter onboard. However, 

altitude information of the UAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for 

active monitoring of the flight path. This altitude information, combined with BRIC operation of the UAS 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. Additionally, BRIC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. BRIC submits that safety will not be affected by operation of 
the UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total duration of approximately 23 minutes. Battery power

indicators are also able to show exactly how much battery power is left, as well as how much time is 

needed to return safely back to point of takeoff. In accordance with 14 C.F.R. § 11.81, BRIC provides the 

following information in support of its petition for exemption:

A. Name and Address of The Petitioner.

The name and address of the Petitioner and point of contact is:

Bobby Rodriguez

618 45th Street

West Des Moines

Iowa, 50265

850-974-0538

Bobby.rodriguez21@gmail.com

B. The Specific Sections of 14 C.F.R. From which BRIC Seeks Exemption.

1. BRIC Seeks Exemption From The Requirements Of Section

61.113 (a) and (b).

Section 61.113, entitled Private pilot privileges and limitations:

Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that 

is carrying passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC 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.

2. BRIC Seeks Exemption From The Requirements Of Section

91.7 (a).

Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. BRIC Seeks Exemption from The Requirements Of Section
91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure.

4. BRIC Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

5. BRIC Seeks Exemption From The Requirement Of Section

91.405 (a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or 

operator of an aircraft—

(a) 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[.]

6. BRIC Seeks Exemption From The Requirements Of Section

91.407(a) (1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7

of this chapter[.]

7. BRIC Seeks Exemption From The Requirements Of Sections

91.409(a) (1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

8. BRIC Seeks Exemption From The Requirements Of Sections

91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief that BRIC Seeks And The Reason BRIC Seeks The Relief.

1. Extent of Relief BRIC Seeks And The Reason BRICseeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, 

is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as 

well as a current and valid airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot 

may, for compensation or hire, act as PIC 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. As set forth more fully 

below, BRIC submits that an equivalent level of safety will be maintained because no PIC will be allowed 

to operate the UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating 

that the PIC is able to safely operate either the UAS in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, BRIC submits that all flights of the UAS, conducted by the PIC pursuant to the grant of this 

Petition:

(1) will be incidental to BRIC and (2) will not carry passengers or property for compensation or hire.

2. Extent of Relief BRIC Seeks And The Reason BRIC Seeks Relief From Section 91.7(a).
Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow BRIC to determine that the UAS are in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and UAS

Instruction Manual).

BRIC seeks the requested relief because the UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, BRIC will ensure that the UAS are in airworthy condition 

based upon its compliance with the operating documents (i.e., Monthly Maintenance

Log, and the manufacturers recommendations) prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief BRIC Seeks And The Reason BRIC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 

UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry 

data link to downlink altitude information from the UAS to the PIC at the ground control station (GCS). 

Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic 

control (ATC) in feet above ground level (AGL), BRIC seeks the requested relief because the UAS

altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 

CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures 

that a ground level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UAS on the heads-up display of the GCS.

4. Extent Of Relief BRIC Seeks And The Reason BRIC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 minutes. 

BRIC seeks the requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered UAS will severely constrain the practicality of any aerial video or still 

photo flight operations that BRIC proposes to conduct pursuant to this Petition. Significantly, as set forth 

below, the technical specifications of the UAS, the UAS operating documents, and BRIC’s proposed 

operating limitations, ensure that BRIC will safely operate the battery powered UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery 

power to fly for a total duration of 23 minutes.

5. Extent of Relief BRIC Seeks and The Reason BRIC seeks Relief From Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness 

certificate, BRIC requests relief from these Sections because the UAS do not require airworthiness 

certificates. As set forth more fully below, the UAS meet the conditions of FMRA Section 333 for
operation without an airworthiness certificate. Accordingly, BRIC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and UAS

Instruction Manual). Furthermore, BRICwill document and maintain all maintenance records for the 

UAS.

D. The Reasons Why Granting BRIC Request Would Be In The Public Interest; That Is, How It Would 

Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing

BRIC to safely, efficiently, and economically perform aerial video and photography of construction sites, 

real estate, events and civic landscape over certain areas of the United States.

Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of BRIC proposed operation of the UAS will be 

realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed 

to perform aerial acquisitions, an exemption allowing the use of a UAS would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and 

property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating 

in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 

UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting 

aerial video and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The UAS. Conducting aerial acquisitions 

with the UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels 

of air and noise pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the UAS produce no air pollution, and is the most viable

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft 

that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons 

per hour of leaded aviation fuel. The UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an 

internal combustion engine. By using the UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned aircraft

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the UAS (weighing approximately 60oz at their maximum 

gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan 

of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations with the UAS Will Benefit the Economy. 
In addition to being safe and efficient, the UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the UAS will allow United States based 

companies, BRIC to remain competitive and contribute to growth of the U.S. economy. Specifically, with

the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered UAS is one such technology 

that not only allows companies greater operational flexibility compared to manned aircraft, but provides 

such flexibility without the high operational cost of a traditional manned aircraft. By operating the UAS, 

companies such as BRIC, can remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy.

Improved financial performance of U.S. companies, through commercial use of the UAS, provides a

stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain competitive both in the United 

States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, BRIC

proposed operation of the UAS will not implicate any privacy issues. Specifically, the UAS will be 

operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and Instruction 

Manual) which requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 

14C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which BRICSeeks Exemption.

1. Reasons why UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 

(FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, BRIC operations of the UAS meet the conditions of FMRA Section 333, and 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 

provides authority for a UAS to operate without airworthiness certification and sets forth requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after 

the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned 

aircraft systems may operate safely in the national airspace system before completion of the plan and 

rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the 

Secretary shall determine, at a minimum--
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight do not 

create a hazard to users of the national airspace system or the public or pose a threat to national security; 

and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system. In 

seeking this exemption, BRIC submits that the UAS can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by:

(a) the characteristics of the UAS; (b) the pilot certification requirement; and (c) the specific operating 

limitations.

a. The Specifications Of The UAS Demonstrate Its Safe Characteristics. The UAS does not create a 

hazard to users of the NAS or the public, or Otherwise pose a threat to national security considering its 

size, weight, speed, and operational capability.

(i) Technical Specifications Of The UAS. The technical specifications of the UAS are set forth by the 

UAS User Manual, attached hereto as Appendix A.

(ii) The UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational 

Area. The UAS may be operated in both manual and global positioning flight modes. A complete 

description of the flight and navigational modes of the UAS is Provided at pages 11 of the User Manual 

attached hereto as Appendix A.

(ii) The UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of 

The Control Link Or Navigation. When the Control Link is lost, the UAS will remain stationary, in flight, 

for 3seconds or more. If, after 3 seconds, the UAS does not reacquire control link data from the GCS, the 

UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) 

via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe 

Functions of the UAS are set forth at pages 12 through 14 of the User Manual, attached hereto as 

appendix A.

(iv) GCS And Its Operation.

A complete description of the operation and specifications of the GCS and flight control software is 

provided in the UAS User Manual. User Manual is attached hereto as Appendix A.

b. Flight Operations of UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With 

A Safety Observer. The BRIC video production staff (Bobby Rodriguez) will be the only persons to act as 

a pilot in command (PIC) of the UAS. Additionally, a safety observer will assist him at all times during 

flight time.
c. Flights Of UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this 

exemption, BRIC proposes to commercially operate UAS for the special purpose of conducting aerial 

video and photography over certain areas of United States, pursuant to the following specific operating 

limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in 

the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight:

Unmanned Aircraft Systems.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial 

video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the 

operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other 

instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations contained in the grant of exemption and the procedures outlined in the operating documents, 

the conditions and limitations contained in the grant of exemption take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator 

may update or revise its operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to the grant of

exemption. If the operator determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The 
FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The 

PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the UAS 

to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third class medical 

certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS 

will be operated under the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must 

be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the 

operator’s PICs are permitted under the terms of the exemption. However, training operations may only 

be conducted during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must

operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of operations. Flights under special visual

flight rules (SVFR) are not authorized.
20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current 

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, 

and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The 

letter of agreement with the airport management must be made available to the Administrator upon 

request.

21. The UA may 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.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered 

in accordance with 14 C.F.R. part 47, and have identification (“N” Number) markings in accordance with 

14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities 

at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other 

than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or 

debris in the event of an accident. The operator must ensure that nonparticipating persons remain under 
such protection. If a situation arises where nonparticipating persons leave such protection and are within 

500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, 

vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard 

to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

BRIC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate the UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the UAS 

in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures. Considering Bobby Rodriguez’s

proposed area of operations, and the operating limitations set forth-above; the parallel nature of private 

pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the UAS, BRIC submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for BRIC’s specific proposed flight operations. The FAA has previously granted relief 

from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

BRIC will not allow any PIC to operate the UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the UAS training and currency requirements, that the PIC is able to safely 

operate the UAS in a manner consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC 

must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total 

time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the 

same make and model of UAS to be used for operations under the exemption). In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 
BRIC’s proposed operations. The Administrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion 

picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged 

as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must 

also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may 

be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of 

UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior

documented flight experience that was obtained in compliance with applicable regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights can also be conducted under the 

grant of exemption to accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances in accordance with 14 

C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, BRIC will ensure safe operations by not allowing any PIC to operate the UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, BRIC will ensure that the UAS is in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the UAS will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with BRIC’s operation of the UAS within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude
information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero 

altitude initiation point is automatically established by the UAS at ground level. The FAA has previously 

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the limitations on 

the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, BRIC

will ensure that it will safely operate the battery powered UAS during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 23 minutes. Here, as in Exemption No. 11109, the 

technical specifications of the UAS; the limitations on the proposed flight operations; and the location of 

the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the UAS provide audible and visual warnings to the PIC

at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 

33% remaining battery power, and again at approximately 10% remaining battery power. At the critically 

low battery level, UAS will descend and land automatically. Significantly, previous exemptions granted 

by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 

2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely

Affect Safety.

In seeking this exemption, BRIC submits that the equivalent level of safety with regard to the regulatory 

maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b) will be met because BRIC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e.,

Monthly Maintenance Log, and UAS Instruction Manual). Furthermore, BRIC will document and 

maintain all maintenance records for the UAS. Since the UAS will be inspected as prescribed by the 

operating documents, BRIC will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the UAS User Manuals are attached hereto as Appendix A and 

B; a copy of the UAS Maintenance LOG is attached hereto as Appendix C.
Likewise, the exemption sought will not adversely affect safety because BRIC will use trained technicians 

to perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought 

would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), 

because all maintenance of the UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered.

In consideration of BRIC’s proposed operating limitations, the operating documents, and the technical 

aspects of the UAS, BRIC submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

previously granted relief specific to UAS in circumstances similar, in all material respects, to those

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special 

Conditions, BRIC requests that the FAA prescribe special conditions for the intended operation of the 

UAS, which contain such safety standards that the Administrator finds necessary to establish a level of

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such 

special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial 

video and photography over certain areas of the United States for compensation or hire. FMRA Section 

333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation 

of the UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual 

design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds 

necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Leading Edge’s intended operation of the UAS, which contain such safety standards that 

the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and91.417(a) & (b).

• A Summary That Can Be Published InThe Federal Register, stating: The Rules From Which BRIC seeks 

Exemption:

BRIC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption BRIC Seeks:

This exemption will permit BRIC to commercially operate an Unmanned Aircraft System (UAS) for the 

purpose of conducting aerial video and photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support

BRIC’S Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. 

As such, BRIC request for exemption may be granted pursuant to the authority of FMRA Section 333 and 

14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security; and further, provides the authority for such UAS to operate without airworthiness 

certification. As discussed in detail above, BRIC will operate the UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, BRIC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the UAS 

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA Administrator will 

be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing BRIC to safely, efficiently, and economically operate 

the UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, BRIC respectfully requests that the Administrator grant this Petition for 

an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit BRIC to operate the UAS 

commercially for the purpose of conducting aerial video and photography over certain areas of the United 

States.

Dated: June 10, 2015
Respectfully submitted,

Bobby Rodriguez

618 45th Street

West Des Moines IA 50265

850-974-0538

Bobby.Rodriguez21@gmail.com

Appendices:

A – Link to UAS Models: Click on link below

http://www.horizonhobby.com/pdf/BLH8675-manual-EN.pdf

http://www.horizonhobby.com/pdf/BLH8100-Manual-EN.pdf

http://www.horizonhobby.com/product/multirotor/yuneec-q500-plus-bonus-buy/camera-platforms/q500-

4k-rtf-with-st10--cgo3--2-battery--steadygrip--case-p-yunq4kpus