(February 23, 2015) U.S. Dept. of**Transportation~** Docket Opemtions West Building Ground 

### Floor, Room wl2-140 1200 New Jersey Avenue, SE Washington, DC 20590 ; ; Luxury Aerial Shots, LLC

**CEO~** Bryan Gonzalez 6826 NE Jacksonville Rd Ocala, Florida 34479

PH; (352)361-1932

Re: Exemption.Requestonder Section 333 oftheFAARefonn. Actand Part 11 ofthe Federal Aviation Regulations. Dear Sir orMadam, Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the ••ReformAct") and 14 C.F.R. Part 11

**~Luxury** Aerial Shots, LLC seeks an exemption from Federal Avi.ation Regulations {"'F

**ARs~;)** detailedbelow forthe foUowing described

**U~anned** Aircraft System.. 

### THE UNMANNED AIRCRAFTSYSTEM (UAS) DETAILS: The manufacturer is DJI. It ismodel F550 lightweight (5.3 lb gross weight fully
**equipped)~** battery only operated 6 motor craft in the form ofa hexacopter that takes offand lands vertically. It has been modified to carry the following equipmentinflight; • An on-board flight computer with GPS navigation and location ability thatreceives signals for flight controls from a ground-based 

### tran.smitter/controller. • An on-board camera capable ofcapturing images in the form offull color, high definition still photos and videos. • Itis equipped to send flight data from the on-board flight computerto the on-boardradio ttansmitterincluding altitude

**AGL~** horizontal and vertical speed, compass direction of flight and direction back to its launch 

### site. • A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the onboardcameraplus all the flight data from the telemetry 

### system described above.luxury Aerial Shots, LLC

**CEO~** Bryan Gonz.alez 6826 NE Jacksonville Rd Or::ala, !=lorida 34479

PH:
**(352)361~1932**
The Unmanned Aircraft System will be operated in the 

### field with a PIC in accordance with FAA PolicyN 8900.227 Secti.on 14 "Operational Requirements for UAS". Luxury Aerial Shots respectfully requests the grantofexemption allowing 

### to operate lightweight, remote controlled UAS's lavvfully and safely. Luxury Aerial Shots also respectfully requests Exempti.on Request Section 333 from (but not limitedto) the Specific Sections ofTitle 14 ofthe Code ofFederaJ Regulations and part ll ofthe Federal Aviation. Regulations listed below. 14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(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); 91.417 (a) & (b) The extent ofreliefLuxury Aerial Shots seeks and the reason why: Luxury 

### Aerial Shots is seeking relief

### from any applicable F ARsoperating to prevent Luxury Aerial Shots from conducting low level aerial shots ofreal estate and otherpossible legal flight operations. The weight ofthe UAS meets the definition of''small unmanned aircraft" found in section 331 oC¢The Reform

**Act~'.** Luxury Aerial Shots seeksto operate legally as a small business that caters to real estate agents. Realto:rs are not allowed touse UAS's orhire unless

**they~** or theperson they hire, isrulowed bythe FAA to fly a VAS. Luxury Aerial Shots would satisfy the need for safeand affordable aerial shots. Atless than 6pounds, Luxury Aerial Shots uses a UAS that jtconsiderably Jess than 55 pounds includingthe camera that is attached. The UAS will be used at speeds under 30mph because of the nature ofthe business and the limited physical capabilities oftheUAS. It is designed to hover 

### and takepictures. 

### The UAS will be inaccordance with 

### fl.ying well below400ft. The UAS inwhich Luxury Aerial Shots would be using onlyutilizes batterypowerfor its operations. Ther.e are no combustible fuels used in the UAS that Luxury Aerial Shots uses. The maximumflight time for our particular UAS is 18 minutes battery life. It will fly no more than 15 minutes maximrun atonetime at one location. The amount oftime the UAS will be in the air, under400ft, is 

### very minimal. A Safety system in place for Luxury Aerial Shot's UAS includes a GPS mode that allows the UAS to hover in place 

### ifcommunication is lost. Further, the GPS onboard a11ows the UAS to return backto its launchedposition 

### ifthe battery life ofthe UAS is low. Another safetyprotocol for Luxury Aerial Shot'sUAS is that itcan fly and land with :five motors. IF one ofthe six were to 

### fail, it can rp.ak.e itback safely.1HE GROUND STATIONPART OF THE SYSTEM: Luxury Aerial Shots, LLC CEO- Bryan Gonzalez 6826 NE Jacksonville Rd Ocala, Florida 34479

PH: (352)361-1932

• APilot inCommand (PIC) in operational control ofa flight operation from 

### beginnmg to end and who controls the UAS while inthe air. Additionally, the line ofsite oftheUAS will not leave the sight ofthe PIC. 

### • A 1OOm W, 2.4GHz radio 

### transmitter/controller operated by

### the PIC to control 

### the U.AS while in flight; • Aradio receiver

### receiving live video and flight data from the 

### on-board. camera and ·computer. Itprojects it 

### all 

### in. one screen to 

### the Pilot in Command. The UAS, weighing less than 6lbs fully loaded, is 

### powered by battedes and operates with no people on 

### board which 

### lowers the likelihood 

### ofdeath or serious bodily injury. 

### With a small payload consisting ofharmless electronics such as a camera and GPS, the UAS;s only purpose is to be used as atool to take pictures and videos. Low level aerial photosand video from several angles are far more effective than ground based photos. Low level aerial video and pictures showthe layout ofproperties with the advantage of seeing more in one photo or short video. Current applicants have chartered helicopters and small planes for this purpose. As an ex Aviation Logistics Specialistinthe U.S. Navy, the cost offuel, time, and emissions ofsuch aircraft (helicopters and. planes) is not efficient enoughfor most customers to afford. The benefits ofreduced cost and improved efficiency ofthe UAS allows future customers to afford this service with a faster turnaround time at alesser cost.

**Additionally~** Irespectfully request that Luxury Aerial Shots be allowed to use the UAS to benefit possible first responders 

### in. my area for actions that could benefitthepublic. Such as, forest fires and/or search and rescue.Luxury Aerial Shots, LLC CEO- Bryan Gonzalez 6826 NE Jacksonville Rd Ocala, Florida 34479

PH: (352)361-1932 Luxury Aerial Shots will not operate a UAS near aitports and generally does not fly over crowds. Situational awareness is key. The areas where Luxury Aerial Shots conducts aerial photography is predetermined which allows for a controlled environment to operate safely. With allowing Luxury Aerial Shots to conduct business with a light weight UAS, it could very well help the economy and benefitpeople in first response situations. Further, Luxury Aeri.al Shot's UAS is considerably lighter than the alternative which is a helicopter or small plane. Currently, Luxury Aerial Shots has only one 

### UAS which 

### only operates off 18 minutes ofbattery power. Therefore, the UAS used by Luxury Aerial Shots would only have a flighttime of

### 5- 15 minutes at on.e time. The likelihood ofinjury or even death with such a small unmanned aircraft, compared to an aircraft 

### fl.o-wn 

### by a person loaded with combustible

### fuel, is considerably low. 

### SUMMARY: Luxury Aerial Shots is more than willingto follow the safety guidelines ofthe FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS'1 with the appropriate exemptions for flying a smallUAS. (a) No flight will be made with a UA Gross weight exceeding 55 poWlds; 

### (b) All operations must occur inFAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no tnore than 25 knots and no further than 3/4 NM from the Pilot 

### In Charge; (c) Operations will be restdcted to flights overprivate property withthe permission ofthe property owner; (d) All required permits will be obtained from state and local government prior to operation; (e) The UAS will not be operated over denselypopulated areas; (f) The UAS will not be operated at air

**shows~** (g) Th.e UAS 

### wi.JJ not beoperated over any open-air assembly ofpeople; (h) The UAS will n.ot be operated overheavily trafficked roads; (i) The UAS will not be operated within 

### 5NM ofan airport orheliport; (j) The UAS will not be operated overproperties smallerthantwo acres in size; (1<) Operations will be res1ricted to day onlyand weather conditions equivalent to VFR; (1) The PIC will btieftheproperty owner about the operation and risk before the first flight at each new location;Luxury Ael'ial Shots, LLC CEO- Bryan Gonzalez 6S.26 NEJacksonville Rd Ocala, Florida 34419

PH: {352)361-1932 (m) No flight may bemade without aPre-Flight Inspection 

### by the PIC before each operation to ascertain that the UAS i.s in a condition safe for flight (see Appendix A). 

### My operations 

### a.bove, [(a) through (m)], are the bare 

### minimum. safety requirements Luxury Aerial Shots 

### will follow. Luxury Aerial Shots is also more than willing to follow any additi.onal safety requirements 

### ifnot listed above. As stated by President Barak Obama 

### i.n .his recent memorandum 

### for the heads ofexecutive departments and ageneies concerning VAS's, published onFebruary 15,2015. "As compared to manned aircraft, UAS may providelower-cost operation and augment existing capabilities while reducing risks to human life. Estimates suggestthe positive economic impactto U.S. industry of the integration ofUAS into the NAS could be substantial and likelywill growfor the

**forese~able** future". 

### Luxury Aerial Shots believes flying its UAS as a small

**business~** within the safety parameters ofthe FAA. can. help people and promote the economy. The name and contact information ofthe applicant are: Luxury Aerial Shots, LLC 

### Attn; Bryan Gonzalez Phone:

**352~361-1932** 

### Email: LuxuryAeriaJShots@hotmail.com orBgonza8304@live.com With priormjlitary experience as an Aviation Logistics Specialist inthe Navy, I understand safety is paramount in. dealing with the airspace and the settings below. Please contact me at any time ifau;y 

### additi.onal infonnation is needed or any questions transpire. Luxury Aerial Shots respectfully requests thatthe FAA grant its exemptionrequest without delay. I do look forwar:d to working with you gu,ys. Thankyou for yourtime. Respectfully,



# ~A--~ Bryan Gonzalez, CEO . Luxury Aerial Shots, LLC (352) 361-1932