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Eric Amengual LLC Section 333 Petition

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No.

ERIC AMENGUAL LLC PETITION FOR AN EXEMPTION SEEKING RELIEF FROM

THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

(14 CFR) PART 21 SECTIONS; § 61.113(a) and (b), 91.7(a), 91.121, 91.151(b),

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

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM PURSUANT

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012.

Submitted June 25, 2014

Eric Amengual LLC

9731 46th Ct E

Parrish, FL 34219

518-222-4964

nytrooper@gmail.com
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Eric Amengual LLC Section 333 Petition

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

NAS National Airspace System

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012, Section 333

SOP Standard Operating Procedures

UAS Unmanned Aircraft System 

UAV Unmanned Aerial Vehicle 

UH Unmanned Helicopter

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Take Off and Landing
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Eric Amengual LLC Section 333 Petition

SUMMARY

Eric Amengual LLC 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) & (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. In consideration of the speed, 

weight, size, and limited operating area associated with the unmanned aircraft and its 

operation, Eric Amengual LLC's operation of the DJI T600 "Inspire 1" Unmanned 

Helicopter 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. This

exemption will permit Eric Amengual LLC to operate an Unmanned Aircraft System for 

the commercial purpose of conducting aerial data collection and research within the 

National Airspace System.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Eric Amengual LLC provides its clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. Eric 

Amengual LLC has over 10 years of professional experience in Information Technology

and Geographic Information Systems (GIS), and is a Florida real estate agent. He has 

over 3 years recreational/hobby experience in all aspects of aerial video and 

photography. The objective of Eric Amengual LLC aerial video and photography 

operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, including:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, mapping, engineering and other related professional 

activities.

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority.
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Eric Amengual LLC Section 333 Petition

4. Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations 

to increase awareness and improve safety for current and future UAS operations within 

the NAS.

7. Collecting data to create high-resolution orthophotos and site maps.

8. Photogrammetry and crop scouting to allow for a more efficient application of 

fertilizers, reducing the negative effects on the environment, which is in the public 

interest. 
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Eric Amengual LLC Section 333 Petition

BACKGROUND

Eric Amengual seeks an exemption to operate a DJI model T600 unmanned 

helicopter known as the "Inspire 1" for compensation or hire within the national airspace 

system. The Inspire 1 is comprised of a 4-rotor helicopter with attached HD camera 

system and a transportable ground station. The Inspire 1 UH has a maximum gross 

weight of approximately six and a half pounds (6.5 lbs.) and the following technical and 

operational specifications:

Weight (Battery and Camera included) ................................. 6.5 lbs.

Dimensions ........................................................................... 17.3" x 17.8" x 11.9" 

Hover Accuracy (GPS Mode)

Vertical ....................................................................... 1.6 ft. 

Horizontal ................................................................... 8.2 ft.

Max Angular Velocity

Pitch ........................................................................... 300°/sec. 

Yaw ............................................................................ 150°/sec.

Max Tilt Angle ....................................................................... 35°

Max Ascent Speed ................................................................ 16 ft./sec. 

Max Descent Speed .............................................................. 13 ft./sec. 

Max Air Speed ..................................................................... 49 mph 

Service Ceiling ...................................................................... 14,500 ft.

Max Flight Time .................................................................... 18 min. approx. 

Motor Model .......................................................................... DJI 3510

Rotor Blade Model ................................................................ DJI 1345

Operating Temperature Range ............................................. -10°to 40°C 

Supported Battery ................................................................. DJI Intelligent Battery 

Type ...................................................................................... 6S Lithium Polymer 

Capacity

Standard Battery ........................................................ 4700 mAh, 22.2 V 

Optional Battery ......................................................... 5700 mAh, 22.8 V
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Eric Amengual LLC Section 333 Petition

Operating Frequency ............................................................ 2.4~2.483 GHz

5.725~5.825 GHz

EIRP ..................................................................................... 20 dBm @ 2.4G

13 dBm @ 5.8G

The Inspire 1 UH that will be operated by Eric Amengual 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.

Figure 1: DJI T600 "Inspire 1"

PROVEN OPERATIONAL HISTORY OF DJI T600 IN THE NAS

Many DJI T600's are currently operating safely within the NAS both as hobby and 

commercial UAV's. The UH has onboard stability systems, compass, ground sensing 

sonic altimeters, and GPS. All of these allow the UH to hover with pinpoint precision and 

also take off and land autonomously. There is a failsafe built into the system allowing

the UH to return to a predetermined point (known as "home") at a predetermined 

altitude in the event of a control link failure between the aircraft and PIC. It will also 

automatically return home when the battery has reached a predetermined level, which 

ensures the aircraft will land before the battery level becomes critical. DJI is the world 

leader in UAS technology and also makes several other models which have logged
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Eric Amengual LLC Section 333 Petition

countless hours across the world with great success, giving DJI a reputation for some of 

the best technology, popularity, and reliability in the industry.

BASIS FOR PETITION

Petitioner, Eric Amengual, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator 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) & (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. In consideration of the speed, weight, size, and 

limited operating area associated with the unmanned aircraft and its operation, Eric 

Amengual's operation of the DJI Inspire 1 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. In accordance with 14 C.F.R. § 11.81, Eric Amengual

provides the following information in support of its petition for exemption:

NAME AND ADDRESS OF THE PETITIONER

Eric Amengual LLC 

9731 46th Ct E

Parrish, FL 34219

518-222-4964

nytrooper@gmail.com
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Eric Amengual LLC Section 333 Petition

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ERIC AMENGUAL

SEEKS EXEMPTION

14 C.F.R. § 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command.

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. 

Because the UAV will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC operating

the aircraft to have a private pilot’s license rather than a commercial pilot’s license to

operate the small UAV. Unlike a conventional aircraft that carries the pilot and 

passengers, Eric Amengual's UAV is remotely controlled with no living thing on board. 

The area of operation shall be controlled and restricted, and all flights are planned and 

coordinated in advance. The level of safety provided by the requirements included in the

SOP exceeds that provided by a single individual holding a commercial pilot’s certificate

operating a conventional aircraft. The risks associated with the operation of the UAV is

so diminished from the level of risk associated with commercial operations contemplated

by Part 61 when drafted, that allowing operations of this UAV as requested with a private

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113(a) & 

(b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should Eric Amengual's exemption be granted, no FAA regulatory standard will exist for

determining airworthiness.

14 C.F.R. §91.121 Altimeter settings.

The regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure
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airport or an appropriate altimeter setting available before departure.” As the UAS does 

not have a barometric altimeter, but instead a GPS height AGL read out and a sonic 

ground proximity sensor, an exemption may be needed. An equivalent level of safety 

will be achieved by way of the UAS recording its position as zero feet AGL upon 

powering on, and during flight the height AGL is displayed in real time to the PIC's 

display. The UH is also equipped with a sonic ground proximity sensor which detects

height AGL and automatically corrects the flight altitude to help prevent inadvertent flight 

into terrain.

14 C.F.R. § 91.151(b): Fuel requirements for flight in VFR conditions.

Section 91.151(b) prohibits an individual from beginning “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.” The batteries powering the Inspire 1 

provide approximately 18 minutes of powered flight, therefore meeting the 20 minute

reserve requirement is not possible. Eric Amengual believes that an equivalent level of 

safety can be achieved by limiting flights to 25% of remaining battery power. The UAS is 

also equipped with an audio warning which is set to notify the pilot at a predetermined 

battery level remaining. If the battery drops below this level, the UH will automatically 

return home and land, preventing the UH from being in the air when the battery reaches 

critically low levels. Eric Amengual's 25% restriction and the UAS's automated

systems would be more than adequate to return the UH to its planned landing zone 

from anywhere in their limited operating area.

14 C.F.R. §91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections.

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

certificate, these sections will not apply to Eric Amengual. Maintenance will be 

accomplished by Eric Amengual pursuant to the User Manual, and Maintenance 

Manual. An equivalent level of safety will be achieved because the UAS will still

receive both scheduled and preventative maintenance. Eric Amengual will ensure that

the Inspire 1 is in working order prior to initiating flight, perform required maintenance,
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and keep a log of any maintenance performed. Moreover, the operator is the person

most familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety.

REASONS WHY GRANTING ERIC AMENGUAL'S REQUEST WOULD BE IN THE

PUBLIC INTEREST

Granting the present petition will further the public interest by allowing Eric 

Amengual to safely, efficiently, and economically conduct aerial inspection services, 

along with conducting aerial surveys, electronic news gathering, and aiding is search &

rescue operations, and aerial real estate photography/videography.

Use of UAS flight provides a much safer alternative for both the pilot and the 

public. For small, budget real estate companies and average homeowners, the expense 

of manned 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. My UAS poses 

minimal threat, since size and lack of combustible fuel mitigates potential risk to the 

public. My ultra lightweight UAS is battery powered and creates no emissions that can 

harm the environment. The consequence of my ultra light weight UAS crashing is far less 

than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel 

and can cause catastrophic devastation to the public. The public’s interest is furthered by 

minimizing the ecological and crash threat by permitting aerial video/photo capture 

through my battery operated ultra lightweight UAS's. 

Finally, replacing manned aircraft photographic and video shoots with UAS shoots 

will dramatically reduce emissions and aircraft noise, reducing/eliminating impact on the 

environment reducing annoyance to the public. 
Eric Amengual LLC Section 333 Petition

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FLIGHT OPERATIONS

Operations will only be conducted in the continental United States. Proposed areas of 

aerial operations include areas that are:

1. Not over congested areas or near large gatherings of people.

2. Not within 5 miles of any airport without airport manager's permission.

3. Not within 100 yards of persons or property non-essential to the mission.

5. UH will remain within visual line of sight of the PIC and VO.

6. No flight above 400 feet AGL.

14 C.F.R. §1.1 defines rotorcraft as "a heavier-than-air aircraft that depends 

principally on its support in flight on the lift generated by one or more rotors." It also 

defines helicopter as "a rotorcraft that, for its horizontal motion, depends principally on 

its engine driven rotors." The Inspire 1 meets these criteria and therefore should not 

require a waiver to operate under §91.119 since it can fulfill the requirements of

§91.119(d). However, Eric Amengual will take an added level of safety and not

operate over any congested area in addition to operating with extra requirements as per 

its SOP.

Eric Amengual will operate its UAV by the FAA’s own national airspace 

regulations. In order to increase flight safety and prevent accidental flights in restricted 

areas, thorough preflight action will be taken to ensure no airspace violations will occur. 

Extra measures will also be taken to ensure operations are always conducted in class G 

airspace in day VMC with 3 miles visibility. Eric Amengual's customers often require

flights to occur with as little as 2-3 hours notice, therefore a requirement to obtain a

NOTAM prior to each flight will greatly hinder the ability of Eric Amengual to fulfill its

customers' needs. These jobs are normally performed with a manned helicopter, and 

being able to do these missions with an unmanned helicopter will provide an added

level of safety and service to Eric Amengual's customers.
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FLIGHT OPERATIONS OF ERIC AMENGUAL'S UAV IS LIMITED TO LINE OF

SIGHT OF THE PIC WITH A VISUAL OBSERVER

All pilots will be assisted by a Visual Observer. The PIC and VO must meet the

requirements as set forth by the SOP, which will include training, briefings, and remain

within voice communication range throughout the flight. Both the VO and PIC will

remain within line of sight of the UH during the operation.

Additionally, Eric Amengual will only utilize a PIC holding either an airline 

transport, commercial, private, recreational, or sport pilot certificate. The PIC will also 

hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by 

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC will meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

CONCLUSION

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

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

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

justification for the grant of the requested exemptions allowing commercial operation of

applicant’s UAS.
Eric Amengual LLC Section 333 Petition

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