___ '!_ October 15 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave,

SE Washington, DC 20590 John Mario Restrepo Jrisa student '":"'.- ...... '. ..-.--.,. - .......

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--"·_._._.**~** \_.. ;"'\ ·' -.. . 'I**·~· ~~** f Re: Section 333 Exemption Request Pursuant To Section 333 of thee FAA Reform Act of 2012Dear Siror Madam, Pursuant to §333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14C.F.R. Part 11, John M Restrepo Jr, operator of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photography for the Real Estate advertising in controlled areas, hereby

applies foran exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation ofits sass, so long as such operations are conducted within and under the conditions outlined herein oras may be established by the Federal I Aviation Administration (FAA) as required by §333. John M Restrepo Jr current operation of sUASs for commercial purposes has been halted to comply with recentiy enacted d federal aviation regulations pertaining to sUAS. As described fuller y below, the requested exemption would permit the operation of small, Unmanned and relatively inexpensive· multi-rotor Aircraft under controlled conditions in airspace that is1) contained 2) predetermined 3) has on site safety personnel controlling access, and4) would provide increased safety and enhancements to clients' business operations. The name and address ofthe applicant is: John M Restrepo Jrisa student Address: 12244 Triton Lane, Orlando FL 32837 I, John Mario Restrepo Jr, respectfully requests a grant ofan exemption ofthe following sections of Title 14ofthe Code of Federal Regulations: 14 CFR 21;14 CFR 91,et seq.; 14 CFR 45.23 (b); Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of 2012 •14 CFR 61.113 (a)&(b); 14 CFR 407 (a)(l); 14 CFR409 (a)(2); • 14CFR417(a)&(b).

I, John M Restrepo Jr also respectfully requests an Exemption from Section 333 ofthe FAA Reform Act and Part 11ofthe Federal Aviation Regulations from:14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.1 1 3 (a)&(b); 91.7 (a); 91.9(b)(2); 91.103(b);• 91.109; 91.119; • 91.12 1; 91.151(a); 91.203(a) &(b); 91.405 (a); • 91.407 (a)(1); 91.409 (a) (2); 91.417 (a)&(b). The Extent of Relief John M Restrepo Jr Seeks and the Reason It Seeks Such Relief: John M Restrepo Jr submits this application in accordance with the Reform Act, 112 P.L. 95§§331334,Seeking relief from any currently applicable federal aviation regulations PARs Pertaining to sUAS (unmanned aircraft systems) and operating to prevent John M Restrepo Jr Contemplated commercial photography, videography and other flight operations within the U.S. national airspace system. The Reform Actin §332 provides for such integration of civil UASs into our national airspace system asitisinthe public's interest todoso. John M Restrepo Jr lightweight UASs meet the Definition of "small unmanned aircraft" asset forth in §331 and combined with a sterling safety Record in similar industries, John M Restrepo Jr light duty sUAS are ideal recipients of exemption By the intent ofthe Reform Act. Considerations for relief include a combination of sUAS physical characteristics, safety features, And safe practices identified in §333: • sUAS weight, • sUAS overall size,• sUAS speed over ground, • sUAS flight zone characteristics, Non Operation near airports (civilian or military), tightly controlled operation m populated areas, John M Restrepo Jr,isa student

The client. Specific consideration is outline below. Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of201 2 Operation ofthe UAS by VLOS by 14 C.F.R. Part 2 1 , Subpart H: Airworthiness Certificates 14 C.F. R. §91.203 (a)(1) Subpart H, Entitled Airworthiness Certificates, establishes the procedural requirement sfor the issuance of airworthiness certificates as required byFAR §91.203 (a)(1). Given the size and limited Operating area associated sUAS, an exemption from Part 21 Subpart H meets the requirements Ofan equivalent level of safety under Part 11and §333 ofthe Reform A ct. ll1e Federal Aviation act (49 U.S.C.§4470 1(t)) and §333 ofthe Reform Act both authorize the FAA to exempt Aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weigh, ht, speed, operational capability, and proximity to airports and populated areas ofthe Particular UAS. Inall cases, an analysis of these criteria demonstrates that the UAS operated Without an airworthiness certificate, inthe restricted environment and under the condition Proposed will beat least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) Operating with an airworthiness certificate without the restrictions and conditions proposed.The UAS tobe operated by John M Restrepo .Jrislessthan 11kg. with maximal payload Consisting of remote sensing instrumentation, carries neither no persons, carrtes no e?<-plosive or flammable materials including combustible I e fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and Monitored bythe pilot (PIC), whose roleis designated toactas both the remote sensing Controller and secondary monitor for safety issues, anda technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and liaisons tothe onsite safety officials. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safety tothe public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under 14C.F .R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there isno intrinsic credible threat to national security posed bythe UAS, duetoits size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, and inability to carry a substantial extern a I load. 1 4 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than2 inches no more than6 inches high, the words " limited ;' "restricted;' "lights port;' "experimental;' or "provisional;' as applicable.Even though the sUAS will have no airworthiness certificate, an exemption may be needed asthe sUAS will have no entrance tothe cabin, cockpit or pilot station on which the word "Experimental" canbe placed. Given the size ofthe sUAS, two inch lettering will be impossible. The word "Experimental" will be placed onthe frame in compliance with §45.29 (f)ata size suitable forthe available space. The equivalent level of safety will be provided by having the sUAS marked onits fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAVwill see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions tothis regulation to Exemptions Nos. 10700, 8738, 10167 and 101 67A. Further markings include the use of flashing green LED illumination onthe underside of

the sUAS frame which stands at contrast against ablue or white sky. John M Restrepo Jr,isa student

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of 2012

14 C.P. R.§6 1.11 3(a)&(b): Private Pilot Privileges and Limitations: Pilot in Command. §61.113 (a)&(b) limit private pilots tonon commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve theequivalent level of safety of current operations by requiring a ground crew member to havea private pilot's license rather thana commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on bc;>ard. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations as requested with a private pilot inthe ground crew exceeds the present level of safety achieved by14 C.P.R. §61.1 1 3(a)&(b). 1 4 C.P.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless itisin airworthy condition. As there will beno airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained inthe Manual for maintenance and use of safety

check lists prior to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 14 C.P.R. §91.9 (b) (2): Civil Aircraft Flight Manual in t h e Aircraft. §91.9 (b) (2) provides: No person may operate aU.S. registered civil aircraft ...(2) For which an Airplane or Rotorcraft F light Manual isnot required by §21.5 of this chapter, unless there is available inthe aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof. The sUAS, given its size and configuration has no ability to carry a physical flight manual onthe aircraft. The equivalent level of safety will be maintained by keeping the flight manual atthe ground control point where the pilot flying the sUAS will have immediate access toit. The FAA has issued the following exemptions tothis regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R.§9 1.10 3: Preflight action this regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to. 14 C.P.R. §91.1 09: Flight instruction §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not. have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls fora number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided bythe fact that neither a pilot nor passengers will be carried inthe aircraft and bythe size andJohn Mario Restrepo Jr,isa student Section 333 Exemption Petition Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 Speed ofthe aircraft. Enhancing this safety isthe technology inherent inthe remote controls utilizing digital communications which is paired tothe sUAS making it nearly impossible to unintentionally or intentionally have the control communications interrupted.14C.F.R.§9 1.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters tobe operated atless than the minimum s prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption isfora sUAS

that closely mimics the behavior ofa helicopter, and the exemption requests authority to operate at altitudes upto 400 AG L,an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is closer. Itwill however be operated ina restricted area with security officials tasked with ensuring public safety ,and where buildings and people will notbe exposed to operations without their pre obtained consent and training. The equivalent level of safety will be achieved given the size, weight, speed ofthe UAS

as well asthe location where itis operated. No flight operation will be taken without the permission ofthe property owner inthe case of private property or local officials Inthe case of public property or private property with public interests. Because ofthe advance notice tothe property owner and participants inthe remote sensing activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft**w~ighting** far more than the maximum 11kgof John M Restrepo Jr sUAS proposed herein and the lack of flammable fuel, any risk associated with these operations isfar less than those presently presented with conventional air craft operating ator below 500 AGL. In addition, the low altitude operations ofthe sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with §91.119. 14 C.F. R.§91.121 Altimeter Settings §91.121 requires each person operating an aircraft to maintain cruising altitude eby reference toan altimeter thatisset 11 •••tothe elevation ofthe departure airport oran appropriate altimeter setting available before departure. 11As the sUAS may not have a barometric altimeter, but instead aGPS altitude read out. An equivalent level of safety will be achieved bythe operator, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight. The operator will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height.14 C.F.R. §9 1.151 (a): Fuel Requirements for Flight in VFR Conditions §91.1 5 1 (a) prohibits an individual from beginning "a flight inan airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fueltoflyto the first point of intended landing, and, assuming normal cruising speed (1) During the day, tofly after that forat least 30 minutes; or(2)At night, tofly after that foratIeast 45 minutes:' The battery powering the sUAS provides approximately 15 minutes of powered flight in hover mode without payload. John Mario Restrepo Jr sUAS will notbe able to meet the30 minute reserve requirement in14 CPR §9 1.15 I. Operating the small UAS, ina tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed ,with less than 30 minutes of reserve power, does not engender the type of risks that Section 9l.l51(a) was intended to alleviate given the size and speed ofthe small UAS. John Mario Restrepo Jr believes that an equivalent level of safety canbe achieved by limiting flights to»10 minutes orless that 50% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS toits planned landing zone from anywhere inits limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808 John Mario Restrepo Jr,isa student Section 333 Exemption Petition Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of201 2

14 C.P.R. §91.203(a)&(b): Carrying Civil Air craft Certification and Registration The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate acivil aircraft unless ithas within itthe following: (1) An appropriate and current airworthiness certificate ... (b) No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a)ofthis section ora special flight authorization issued under §91. 715is displayed atthe cabin or cockpit entrance so thatitis legible to passengers or crew.The sUAS fully loaded weighs no more than llkg andis operated without an onboard pilot. As such, there isno ability or place to carry certification and registration documents orto display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents atthe ground control point where the pilot flying the sUAS will have immediate access to them, tothe extent they are applicable tothe sUAS. The FAA

has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 14C.P. 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 Eof this part and shall between required inspections, except as provided in paragraph (c)of this section, have discrepancies repaired as prescribed in part 43ofthis chapter ...;'and others shall inspect o r maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply tothe applicant.Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level of safety will be achieved because these small UASs are very limited in size and 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 isin working order prior to initiating flight, perform required maintenance, and keep alog of any maintenance performed. Moreover, the operator isthe person most familiar with the aircraft and best suited to maintain the aircraft inan airworthy condition to provide the equivalent level of safety. An exemption granted to John M Restrepo Jr would permit its operation of lightweight, unmanned, remotely controlled, sUAS ina tightly controlled environment with limited airspace. John M Restrepo, utilizes local business' safety officers in specifically determined areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goals. Technical enhancements to current safety controls will allow John M Restrepo Jr,to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented by the FAA and Department of Transportation. Further, John M Restrepo Jr conducts its operations in compliance with protocols described here inoras otherwise established bythe FAA. II. Commercial and Public Benefits;

IJohn M Restrepo Jr, believe that granting this exemption request furthers the public interest by providing safe (by way ofan unmanned system) and efficient means to John M Restrepo Jr client base are typically small to medium sized business' looking to increase their awareness of respective properties. Aerial videography and photography for real estate marketing has been around fora long time through manned fixed wing aircraft and helicopters, but for small business owners and homeowners its expense has been cost prohibitive. Granting this exemption tothe petitioner would allow him to provide this service ata much lower cost. Further, the petitioner indicates his small UAS will pose no threat tothe public given its small size and lack of combustible fuel when compared to larger manned aircraft. The petitioner also states that the operation ofhis UAS will minimize ecological damage and promote economic growth by providing information to small businesses and individuals looking to relocate or build inthe Orlando Florida area. John Mario Restrepo Jr ,isa studentSection 333 Exemption Petition Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of 2012 By photographic or videography. By moving these functions onto sUAS based air craft, the potential for loss oflife or property is diminished due to the greater control ina smaller and safer aircraft that holds no persons. Second, there are no reactive or combustible material son board the sUAS and thus the potential for fireor explosions isgreatly diminished. Third, the small size and extreme maneuverability of John M Restrepo Jr UASs allow the PIC to avoid hazards. Accordingly, John M Restrepo Jr UASs have operated and will continue to operate atand above current safety levels. A. The costs and benefits of your proposed action to society in general and specific groups within society as described above, John M Restrepo Jr past customers have been

small to medium business seeking Aerial videography for geographical awareness and for

real estate marketing has been around foralong time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat tothe public through potential catastrophic rash that the various communities have experienced inthe past with military aircraft and medical helicopter crashes within an even cities. Each resulting in loss of life, each with combustible fuel that exploded and burned on impact. My, John M Restrepo Jr, UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat tothe public. Congress has already proclaimed thatitisinthe public's interest to integrate commercially flown UAS's into the national airspace system, hence the passing ofthe Reform Act. Granting my, John M Restrepo Jr's, exemption request furthers the public interest through academic/visual awareness ofthe geographical benefits inand around the NW Florida area. My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence ofmy ultra light weight UAS crashing isfar less thanafull size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation tothe public. Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for anon board pilot, time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civilian or military airports, and

detrimental effects tothe environment caused by operating a combustible fuel based, large scale aircraft, with restrictions onthe proximity tothe target for remote sensing. Flight Capabilities a n d Characteristics of John M Restrepo Jr UAS s Pursuant to112 P.L. 95§333 (a), concerns for public safety are mitigated bythe overall capabilities and characteristics ofthe sUAS. John M Restrepo Jr UAS s utilizes four(4) rotating 9inch plastic propellers paired oppositely to each other for balance, control and stability. The total span ofthe sUAS isless than ""'1.2 m allowing for stable flight or landing even with

the sudden onset of detrimental environmental conditions. The sUAS's have a maximal unit+ payload mass of 11kg, including cinematic/photographic or other surveying equipment. John M Restrepo Jr sUAS is designed to primarily hover in place to capture photographic data and then operate a t less thana35 knot maximum speed tothe next point of interest. They are capable of vertical and horizontal operations but,in practice, is operated only within VLOS bythe PIC. In addition the PIC,John Mario Restrepo Jrisa, student Section 333 Exemption Petition Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of 2012 Off and otherwise minimize pedestrian access inthe flight zone ofthe client's grounds. In

the event of loss of visual ofthe UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r,a,h) based controls which allows the PIC to utilize one controller axis to recall the UAS tothe PIC's position without concern tothe current heading ofthe sUAS. Inthe event of loss of sight ofthe sUAS into an area containing hazards or possible hazards, the spotter hasa heads up display containing alive video feed which canbe used to locate the UAS while it maintains its position in hover mode. The sUAS has demonstrated its ability to maintain its position by GPS coordinates in hover mode in25ktsor greater wind gusts atrvr less than 25 feet representing an extreme environmental condition beyond the range of conditions within the scope for sUAS operation. All of John M Restrepo Jr sUASs utilize LiPo (lithium polymer) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally. last between eight (8)toten(10) minutes allowing the staff to

work with small flight areas per phase. The maximum flight time without payload is25 minutes, however practical safe operation limits thisto10to give ample time to control the sUAS toasafe landing zone. John M Restrepo Jr further restricts flight time by not operating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows John M Restrepo Jr's sUAS to hover in place if communication with the PICislost and optionally follow aset of waypoints ataset speed and height toa 'home base' predesignated safe landing zone. Inthe event of Unforeseen motor(s) failure, the system will enter intoa controlled descent while allowing full useofall UAS flight controls bythe PIC. All commands sent via remote controller received during a controlled descent are translated toan'as meant' paradigm meaning the flight control package will use it's real time3 dimensional position and compensate rotors control the sUAS regardless of spin velocity. This assures that ifone system is compensated asafe and successful landing can still occur.IV. Reasons Why an Exemption to John Mario Restrepo Jr Will Not Adversely Affect Safety Standards

John M Restrepo Jr contends that operation ofits sUASs will not "create a hazard to users ofthe national airspace system orthe public:' as stated in112 P.L. 95 §333 (b). Given the diminutive size and weight of John M Restrepo Jr sUASs, combined with their operation in cordoned off and well controlled areas, John M Restrepo Jr sUAS falls within Congress's contemplated safety zone.

John M Restrepo Jrs UASs have an established safety record bolstered by multipoint Preflight check list, awareness of their surroundings and intimate knowledge ofthe behavior ofthe sUAS platform in many weather conditions. This safety record and implemented operational practices demonstrate an awareness of public safety. John MRestrepo Jr's operations routinely provide a level of safety at least equal to existing rules, andin nearly every instance, exceeds existing rules. John M Restrepo Jrhas worked very closely with the regional vendors and support for

this unit to create a tightly integrated and highly tolerant platform that has been tested thoroughly bya· vendor witha proven record for safety and solid designs. John M Restrepo Jr also continues to work closely with organization to identify and mitigate sUAS platform risk dueto their expertise in several industries closely related to the aviation and transportation. John M Restrepo Jr does not operate its UASs onor near airports and generally has only operated its sUAS on private grounds with cordoned off areas or areas under the control ofthe property owner I client with assistance by safety officials. John M Restrepo Jr determines the areas needed to fulfill the clients 'goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially bythe RC UAS trade and hobby groups.

John M Restrepo Jr,isa student Section 333 Exemption Petition Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Actof2012 John M Restrepo Jr standardized onthe following practices to ensure safe operation ofits UASs: • Work with onsite personnel to plan the flight goals, • Work with onsite personnel to restrict access tonon essential persons, • Operation by unaided VLOS operation only, • Operation in phases 10 minutes in length • Operation to minimal 25% battery power • Operation of device to GPS aided readout to 300ft at maximum, Numerous pre programmed fail safes that ensure specific behavior per issue • Perform asite check day(s) before flight to identify potential issues, Subscribe to relevant local weather and safety alerts, • Expertly choose data collection instruments and accessories to minimize flight requirements or expertise, • John M Restrepo Jrhas experience in similar fields and has adapted this experience in it'suse ofUASs to increase safety. In combination tothe ever expanding knowledge repositories from hobbyist sand experts alike, John M Restrepo Jris constantly evolving it's practice s when there isa clear benefit to operations or increased safety element. A. SummaryPursuant to14 C.F. R. Part 11,the following summary is provided for publication inthe Federal Register, should itbe determined that publication is needed: John Mario Restrepo Jr {applicant) seeks an exemption from the following rules: 1 4 C.P.R. §21, subpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113(a) &(b); 91.7 (a); 91.9 (b) (2);91.1 03{b); 91.109;91.119; 91.121; 91.151(a); 91.203(a) &(b); 91.405 (a); 91.407 (a)(1);91.409(a) (2); 91.409 (a) {2) and 91.417 (a)&(b)to operate commercially a small unmanned vehicle (11 kgor less) in elevated photographic and remote sensing operations. Approval of exemptions allowing commercial operation sof sUASs inthe media industry will enhance safety by reducing risk associated with conventional aircraft operations and other means of elevated remote sensing involving persons. The public benefit served by approval of this petition is increased awareness of characteristics of difficult imaging

targets. A sUAS weighing fewer than 11kg and powered by sealed batteries eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity to buildings or persons or otherwise elevating persons toa position they would be able to collect needed data. The operation of small UASs, weighing less than 55 lbs., conducted inthe strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. John Mario Restrepo Jrisa student Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 Also experienced in flying Unmanned Aircraft Systems (U.A.S) for recreational purposes.The FAA has been given the authority t o issue the exemption to John Mario Restrepo Jr

pursuant tothe Federal Aviation Act, 85 P.L. 726 (1958), andas such, we humbly seek your consideration and approval ofthis petition. encl: Supplement A: Physical characteristics of UAS encl: Supplement 8: Flight Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in John M Restrepo Jr's regional base. VI. Supplement B: Summary Sections of Flight Operations and Procedure Manual (FOPM) • All regular and irregular operations are noted with timestamps, relevant UAS metrics and corrective action procedures (CAP) that are performed. Note: All irregular behavior have root cause analysis performed before UAS operation is resumed. Emergency Procedures •Loss ofRemote Signal -The flight package features an optional enhanced failsafe which returns the sUAS tothe home base waypoint via the same path taken to point oflost signal.

-The UAS will then perform a hover over this waypoint and thena controlled landing. •Loss of GPS signal -The system will operate in GPS assisted mode with three (3) satellites. At loss of three

(3) GPS satellites, manual mode can be activated or the flight package can be programmed to perform a controlled landing tothe home base waypoint. - Ground based height ranging is performed bya separate system and so loss of GPS will not impact controlled landing inasafe manner. •Loss of Engine Powert-·-In the event ofone (1)(ortotwo oppositely positioned) rotor or motor failure the system will enter into controlled spin where all controls are translated based on current orientation and will behave as normal operation tothe PIC to ensure asafe landing, -In the event of multiple rotor or motor failures the flight package can be configured to perform asafe landing or attempt operation to home base waypoint. - Note: Behavior ofthe landing location is highly dependent onthe position and number of rotors/motors that are affected.

•Loss of Ground Control Software -This will not affect operation ofthe flight. The unit will be Piloted toasafe landing area and then landed so that examination ofthe link can

be made. TYPHOON Q500 4KYunee.com/support