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, US 08104 

CChaparro04@msn.com 

U.S Department of Transportation Docket Management System 

1200 New Jersey Ave., SE Washington DC 20590 

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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); 14 CFR91.9(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); 14 CFR 91.417(a) and (b) 

The exemption is in the public interest. Pursuant to the authority contained in 49 

U.S.C. 1 06(f), 40113, and 44701. 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 CFR 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 under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

Thank you in advance for your consideration. 

... j 
Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would provide professional services in the following 

areas: 

1. Photography I Videography 

2. Inspections 

As described fully below, the requested exemption would permit the operation of 

designated UAS as set forth in this document under controlled conditions in the 

NAS that would be a) limited b) controlled c) predetermined and d) safe. Approval 

of this exemption would increase public awareness of UAS operations and 

enhance safety to 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 081 04 

CChaparro04@msn.com 

From which the exemption is requested: 14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91 .9 (b) (2) 

14 CFR 91 .103 

14 CFR 91 .109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14CFR91 .151 (a) 

14 CFR 91 .203 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) 

14 CFR 91.409 (a) 

14 CFR 91.417 (a) 
As in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA-2014-0352), 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 

11 112 to 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) with the specifications described by the petitioner and 

carrying no passengers or crew, 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 

that the FAA grant the 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 under the 

FAA issued exemption as set forth 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 operated within 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, but will not exceed 30 minutes. Flights will be terminated at 

25% battery power reserve or 30 minutes of flight time 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 a third, 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 prior to each day's flights consisting of all 

the days' Production activities. 

9. All flight activities will be logged. 

1 0. All flights will occur under Visual Flight Rules Meteorological Conditions 

(VMC) only. 

11. The flights will occur in Class G airspace no closer than a mile radius of the 

geographic center/Airport Reference Point (ARP) of a tower controlled or 

uncontrolled airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport. 

13. The operator will do a pre check of aircraft prior to each flight. And log each 

flight. 

14. The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 

100 feet of the flight operation, and the radius may be reduced to 30 feet 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 up to 

date information for the 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 capability to abort a flight in case of emergencies with 

an automated "Return Home and Land" function. 

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

obstacles, weather, or emergencies such as low battery. 

21. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the 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 for the 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 by the Applicant, an exemption from Part 21 Subpart H 

meets the 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 aircraft from 

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 under the conditions proposed will be at least as safe, 

or safer, than a conventional aircraft (fixed wing or rotorcratt) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The 

UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored 

by both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree 
of safety to 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 that there is no 

credible threat to national security posed by the UAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to 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 less than 2 

inches nor more than 6 inches high, the words "limited/' "restricted/ "light sportf 

"experimental/' or "provisional/ as applicable. 

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 less than 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 the fuselage in 

compliance with §45.29 (f). US Department of Transportation February 20, 2015 

The equivalent level of safety will 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 UAS will 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 set forth in the FOM will equate to the 

safe operation of the UAS.