US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation February 15, 2016

Carlos R Chaparro 1813 Phillips Street Camden, NJ, US08104 CChaparro04@msn.com U.S Department ofTransportation Docket Management System 1200 NewJerseyAve

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Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a) ; 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b)
The exemption is in the public interest. Pursuantto the authority contained in 49 U.S.C. 106(f),40113, and 44701.

DearSir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the
"Reform Act") and 14CFR Part 11 of Unmanned Aircraft Systems (UAS), Carlos R Chaparro hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of Designated UAS, provided such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333.

Thankyou in advance foryour consideration. ... jCommercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in thefollowing areas: 

### 1. Photography

### IVideography 2. Inspections
As described fully below, the requested exemption would permitthe operation of designated UAS as setforth in this document under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibilities to"

.... establish requirements for the safe operation of such aircraft systems in the national airspace system." The name and address of the applicant is



### Carlos R Chaparro 1813 Phillips Street Camden, NJ, US 08104 CChaparro04@msn.com
From which the exemption is requested: 14CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14CFR 91

.9 (b) (2) 14CFR 91

.103 14 CFR 91

.109 14CFR 91.119 (c) 14CFR 91.121 14CFR91

.151 (a) 14 CFR 91

.203 (a) 14 CFR 91.405 (a) 14CFR 91.407 (a) 14CFR 91.409 (a) 14 CFR 91.417 (a)As in Grants of Exemption Nos. 11062to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109to Clayco, Inc. (see Docket No. FAA-2014-0507), 11 112to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213 to Aeryon Labs, Inc. (see Docket No

. FAA-2014-0642), and 12645 to Allied Drones (see Docket No. FAA-2014-0804), There is enhanced safety achieved using an unmanned aircraft (UA) withthe specifications described by the petitioner and carrying no passengers orcrew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Carlos R Chaparro Will operate one or more of the Following model UAS

. Phantom 2 vision plus and inspire 1 Safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly,the applicant graciously requests thatthe FAA grantthe requested exemption.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include:
1
.The UAS will weigh significantly less than 55 lbs

. 2

.The UAS, depending on the model in operation, will have a maximum operating speed of no more than 50mph. 3. Flights will be operatedwithin line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).4. Maximum flight time for each operational flight will be depending on the UAS model in operation, butwill not exceed 

### 30 minutes. Flights will be terminated at 

### 25% battery power reserve or 

### 30 minutes of flighttime whichever occurs first.


### 5. Flights will be operated at an altitude of no more than

### 400 feet Above Ground Level (AGL) and not more than 

### 200 feet above an elevated platform from which filming is planned. 

### 6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include athird, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of 

### 20 hours on the designated UAS. 

### 8. A safety briefing will be performed priorto each day'sflights consisting of all the days' Production activities. 

### 9. All flight activities will be logged. 

### 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

### 11. The flights will occur in Class G airspace no closerthan a mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. 

### 12. Flights will not be closerthan a 

### 5 mile radius of the geographic center/Airport.


### 13. The operatorwill do a pre check of aircraft priorto each flight. And log each flight. 14

. The operatorwill obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 

### 100feet of the flight operation, and the radius may be reduced to 

### 30feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.
15. The PIC and VO will have been trained in operation of UAS and receive upto date informationforthe particular UAS to be operated.16. The PIC and VO will be able to communicate by voice and/or radio at all times.
17. The PIC will abide by all rules 18. If the UAS loses communications with the remote controller or loses GPS signal,the UAS will have the capability to return to a predetermined location within a designated location and land autonomously. 19. The UAS will have the capabilityto abort aflight in case of emergencies with an automated "Return Home and Land" function

. 20

.The UAS will have the capabilityto abort aflight in case of unpredicted obstacles, weather, or emergencies such as low battery.
21. Any incident, accident, orflight operation thattransgresses the lateral or vertical boundaries of the operational area as defined bythe applicable GOA 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

. 14 C.F.R. Part 21, Subpart H:Airworthiness Certificates 14 C.F.A. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meetsthe requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section333 of the Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcratt) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UASto be operated hereunder is less than 55 lbs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements

.These safety enhancements provide a greater degreeof safetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates thatthere is no credible threatto national security posed bythe UAS, due to its size, speed of operation, location of operation, lack of explosive materials orflammable liquid fuels,and inabilityto carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the 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 lessthan 2 inches nor more than 6 inches high, the words "limited/' "restricted/ "light sportf "experimental/' or "provisional/ as applicable.
14C.F.R. § 45.23 (b). Marking of the AircraftThe regulation requires:When marks include onlythe 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 lessthan 2 inches nor more than 6 inches high,the words "limited/' "restricted/ "light sportf"experimentalf or "provisionalf as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the UAS,two inch lettering will be impossible. The word "Experimental" will be placed on thefuselage in compliance with §45.29 (f). US Department of Transportation February 20, 2015 The equivalent level of safetywill be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UASwill see the identification of the UAS as "Experimental." 14 C.F.R. 

### § 61

.113 (a) and (b The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the It is believed that the operation and limitations setforth in the FOM will equate to the safe operation of the UAS.