(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. Request onder Section 333 of the FAA Refonn. Act and Part 11 of the 

Federal Aviation Regulations. 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the ••Reform Act") 

and 14 C.F.R. Part 11 ~Luxury Aerial Shots, LLC seeks an exemption from Federal Avi.ation 

Regulations {"'F ARs~;) detailed below for the foUowing described U~anned Aircraft System .. 

THE UNMANNED AIRCRAFTSYSTEM (UAS) DETAILS: 

The manufacturer is DJI. It is model F550 lightweight (5.3 lb gross weight fully equipped)~ 

battery only operated 6 motor craft in the form of a hexacopter that takes off and lands vertically. 

It has been modified to carry the following equipment in flight; 

• An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based tran.smitter/controller. 

• An on-board camera capable of capturing images in the form of full color, high 

definition still photos and videos. 

• It is equipped to send flight data from the on-board flight computer to the on-board radio 

ttansmitter including 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 onboard camera plus 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 

Policy N 8900.227 Secti.on 14 "Operational Requirements for UAS". 

Luxury Aerial Shots respectfully requests the grant of exemption 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 

limited to) the Specific Sections ofTitle 14 of the Code ofFederaJ Regulations and part ll of the 

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 of relief Luxury Aerial Shots seeks and the reason why: 

Luxury Aerial Shots is seeking relief from any applicable F ARs operating to prevent Luxury 

Aerial Shots from conducting low level aerial shots of real estate and other possible legal flight 

operations. The weight of the UAS meets the definition of''small unmanned aircraft" found in 

section 331 oC¢The Reform Act~'. Luxury Aerial Shots seeks to operate legally as a small 

business that caters to real estate agents. Realto:rs are not allowed to use UAS's or hire unless 

they~ or the person they hire, is rulowed by the FAA to fly a VAS. Luxury Aerial Shots would 

satisfy the need for safe and affordable aerial shots. 

At less than 6 pounds, Luxury Aerial Shots uses a UAS that jt considerably Jess than 55 pounds 

including the camera that is attached. The UAS will be used at speeds under 30mph because of 

the nature of the business and the limited physical capabilities of the UAS. It is designed to hover 

and take pictures. The UAS will be in accordance with fl.ying well below 400ft. 

The UAS in which Luxury Aerial Shots would be using only utilizes battery power for its 

operations. Ther.e are no combustible fuels used in the UAS that Luxury Aerial Shots uses. The 

maximum flight time for our particular UAS is 18 minutes battery life. It will fly no more than 

15 minutes maximrun at one time at one location. The amount of time the UAS will be in the air, 

under 400ft, 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 if communication is lost. Further, the GPS onboard a11ows the UAS to 

return back to its launched position if the battery life of the UAS is low. Another safety protocol 

for Luxury Aerial Shot's UAS is that it can fly and land with :five motors. IF one of the six were 

to fail, it can rp.ak.e it back safely. 
1HE GROUND STATION PART OF THE SYSTEM: 

Luxury Aerial Shots, LLC 

CEO- Bryan Gonzalez 

6826 NE Jacksonville Rd 

Ocala, Florida 34479 

PH: (352)361-1932 

• A Pilot in Command (PIC) in operational control of a flight operation from beginnmg to 

end and who controls the UAS while in the air. Additionally, the line of site ofthe UAS 

will not leave the sight of the PIC. 

• A 1OOm W, 2.4GHz radio transmitter/controller operated by the PIC to control the U.AS 

while in flight; 

• A radio receiver receiving live video and flight data from the on-board. camera and 

·computer. It projects 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 of death or serious bodily injury. With a small 

payload consisting of harmless electronics such as a camera and GPS, the UAS;s only purpose is 

to be used as a tool to take pictures and videos. 

Low level aerial photos and video from several angles are far more effective than ground based 

photos. Low level aerial video and pictures show the layout of properties 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 Specialist in the U.S. Navy, the cost of fuel, time, and emissions of such 

aircraft (helicopters and. planes) is not efficient enough for most customers to afford. 

The benefits of reduced cost and improved efficiency of the UAS allows future customers to 

afford this service with a faster turnaround time at a lesser cost. 

Additionally~ I respectfully request that Luxury Aerial Shots be allowed to use the UAS to 

benefit possible first responders in. my area for actions that could benefit the public. 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 benefit people 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 of battery power. Therefore, 

the UAS used by Luxury Aerial Shots would only have a flight time of 5 - 15 minutes at on.e 

time. The likelihood of injury 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 willing to follow the safety guidelines of the FAA Policy N 

8900.227 Section 14 "Operational Requirements for UAS'1 with the appropriate exemptions for 

flying a small UAS. 

(a) No flight will be made with a UA Gross weight exceeding 55 poWlds; 

(b) All operations must occur in FAA 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 over private property with the permission of the 

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 densely populated areas; 

(f) The UAS will not be operated at air shows~ 

(g) Th.e UAS wi.JJ not be operated over any open-air assembly of people; 

(h) The UAS will n.ot be operated over heavily trafficked roads; 

(i) The U AS will not be operated within 5 NM of an airport or heliport; 

(j) The UAS will not be operated over properties smaller than two acres in size; 

(1<) Operations will be res1ricted to day only and weather conditions equivalent to VFR; 

(1) The PIC will btiefthe property owner about the operation and risk before the first flight at 

each new location; 
Luxury Ael'ial Shots, LLC 

CEO- Bryan Gonzalez 

6S.26 NE Jacksonville Rd 

Ocala, Florida 34419 

PH: {352)361-1932 

(m) No flight may be made without a Pre-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 if not listed above. 

As stated by President Barak Obama i.n .his recent memorandum for the heads of executive 

departments and ageneies concerning VAS's, published on February 15,2015. "As compared to 

manned aircraft, UAS may provide lower-cost operation and augment existing capabilities while 

reducing risks to human life. Estimates suggest the positive economic impact to U.S. industry of 

the integration ofUAS into the NAS could be substantial and likely will grow for the forese~able 

future". Luxury Aerial Shots believes flying its UAS as a small business~ within the safety 

parameters of the FAA. can. help people and promote the economy. 

The name and contact information of the applicant are: 

Luxury Aerial Shots, LLC 

Attn; Bryan Gonzalez 

Phone: 352~361-1932 

Email: LuxuryAeriaJShots@hotmail.com or Bgonza8304@live.com 

With prior mjlitary experience as an Aviation Logistics Specialist in the Navy, I understand 

safety is paramount in. dealing with the airspace and the settings below. Please contact me at any 

time if au;y additi.onal infonnation is needed or any questions transpire. 

Luxury Aerial Shots respectfully requests that the FAA grant its exemption request without 

delay. I do look forwar:d to working with you gu,ys. Thank you for your time. 

Respectfully, 

Bryan 

~A--~ Gonzalez, CEO . 

Luxury Aerial Shots, LLC 

(352) 361-1932