**Alex Ranjel , Wichita Falls, Texas**

**– Section 333 Exemption Petition** 

June 15 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

**Re:** Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23 (B); 14 C.F.R. Part 12; 14 C.F.R 61. 113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1 ); 91.409(a) (2); 91.417(a) &(b)

Dear Sir or Madam,

I, Alejandro Ranjel am writing to the pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C. F.R. 1 1, to request that I, Alejandro Ranjel an owner and opera tor of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) li sted below so that I, Alejandro Ranjel may operate my small ultra

- light unmanned aircraft system (“UAS”) commercially in the airspace regulated by the Federal
Avia tion Administration (“FAA”).

As described herein I, Alejandro Ranjel am experience in flying quad

- copters for recreational puposes and have recently added a **PHANTOM 3 PROFESSIONAL** aircraft from **DJI.** My UAS comes equipped with numerous safety features a s well as HD 4K CAMERA. I plan to use my aircraft to for photography and video of real estate properties (residential and commercial)

, marketing, inspections, utilities, construction and disaster and emergency response following exemption and approval by t he FAA. Thereby enhancing economic growth in the North Texas

area.

I have flown small RC quad

- copters for approximately (2) years without incident. I, Alejandro Ranjel and totally committed to safety in each and every flight. My, Alejandro Ranjel exempti on request would permit operation of ultra

- light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. Predeter mined in areas away from general public, airports, heliports and vehicula r traffic for community videos, and within property boundaries for individual homeowners real estate listing videos/photos. Currently, similar lightweight, remote controlled UAS’s are legally operated by unmonitored amateur hobbyist with no safety plan or controls in place to prevent catastrophe. I, Alejandro Ranjel, will continue to strictly comply with safety and maintenance procedures included in all applicable UAS manufactures instructions and operating manuals to avoid and

preve nt public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS.Granting my, Alejandro Ranjel, request comports with the Secretary of Transportation’s

(FAA Administrator’s) respons ibilities and authority to not only integrate UAS's into the National airspace system, but to “...establish requirements for the safe operation of such Aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specifi c to the use of UAS's for real estate/Realtor purposes. Further I, Alejandro Ranjel, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below I, Alejandro Ranjel, respectfully request the grant of an exemption allowing me to operate ultra

- light weight, remote controlled UAS’s to enhance real estate listing videos for homeowners and other companies who cannot afford expensive manned aircraft for the same purpose. Bo th of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public hazard. **I. Contact Informati on:** 

Alejandro Ranjel 1216 We ndy Ridge Wi chita Falls, Texas 76302 (940)

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**II**

. **The Specific Sections of Title 14 of the Code of Federal Regulations From Which**  **Al ejandro Ranjel**  **Requests Exemption are:** 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a ) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

**III. The Extent of relief A lejandro Ranjel seeks and the Reason He Seeks Such**  **Relief:** I, Alejandro Ranjel, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, Alejandro Ranjel contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in S ection 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Alejandro Ranjel, ultra

- light weight UAS meets the definition of “small unmanned aircraft” as defi ned in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rul es governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can beadministered uniformly to all real estate related UAS aerial video and photography. The

Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Wh ether the UAS will be operated near airports or heavily populated areas; and, Wh ether the U AS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Alejandro Ranjel . My UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GP S and auto return safety technology. W eighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. I, Alejandro Ranjel, considers safety as foremost with each flight. My small unmanned aircraft is designed to hove r in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when ra dio controls are released. Wi th three modes to choose from, I utilize GPS MODE for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. Wh en pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may ap proach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three (3) to seven (7) minutes, with an altitude under one hundred fifty (150) feet. I, Alejandro Ranjel , utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is fifteen (15) to twenty

-five (25) min utes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance und er different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety. I, Alejandro Ranjel, am extremely cautious when operating of my UAS/ultra ligh t weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system.UAS Alejandro Ranjel, used in hobby flight, has a demonstrable safety record and does

not pose any threat to the general public or national security. **IV. How**  **Al ejandro Ranjel**  **Request Will Benefit the Public A s A**  **Whole:** Aerial videography for geographical awareness and for marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies and average home owners the expense of such 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. Manned aircraft pose a threat to the public through potential catastrophic crash that the community has experienced in the past. Each resulting in loss of life. Each with combustible fuel that exploded and burned on impact. Police helicopters have made em ergency hard landings within city limits. My, Alejandro Ranjel , UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act.. Granting my, Alejandro Ranjel, exemption request furthers the public interest through my ultralight weight 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 publi c’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. Permitting me, Alejandro Ranjel, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the community for companies looking to relocate or build in the North Texas area as well as individuals looking to relocate for career advancement through academi c and geographical awareness. Both of which serve as a stimulus to the community.

**V. Reasons Why Al**  **ejandro Ranjel Exemption Will Not A** **dv ersely**  **Af fect Safety Or**  **How The Exemption Will Provide a Level of Safety**  **A t Least Equal To Existing**  **Rule:**

My, Alejandro Ranjel, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Alejandro Ranjel, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innova tion and implementation of new and novel, as of yet undiscovered safety protocols that can be embraced by the NAR 6 , AAR 7 , and TAR8 for development in cooperation with the FAA.

My UAS weighs less than 5 pounds complete with a small ultra light weight high quality 4K camera; I only operate my UAS below 400 feet (well within the 400 foot permissible ceilingset by the FAA Modernization and Reform Act of 2012);

my UAS only operate for 20

- 25 minutes per flight; I land my UAS prior to manufacturer recommended mi nimum level of battery power;

My, Alejandro Ranjel, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into

our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. W hile the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra l ight weight UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and

zoom. Accordingly, my UAS ha s been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

**VI. A Summary The FAA** 

**May Publish in the Federal Register:** 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals a nd The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Alejandro Ranjel, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such a s airports and dense populations. My, Alejandro Ranjel, current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicab le in the form contemplated by the FARs, this Regulation is inapplicable.14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are

no on board pilots or passengers, and given the size of the UAS's, this Regulation is inappl icable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 95 65, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Alejandro Ranje l.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have

a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulat ion through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, Alejandro Ranjel, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, wh ile helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Alejandro Rajel, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 2 00 AGL; safely below the standard of 400 AGL. I, Alejandro Ranjel, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the si ze, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

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

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section,have discrepancies repaired as prescribed in part 4 3 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Alejandro Ranjel, UAS. However, as a safety precaution I inspect my UAS before and after each flight.

A Summary Th e FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Alejandro Ranjel, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety w ill be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved

. **In summary , A** **lejandro Ranjel seeks an exemption from the follow ing**  **Regulations:**

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Alejandro Ranjel small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and real estate operations, and to develop economic platforms to enhance the experience of those seeking to relocate to the North Texas area. Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, Alejandro Ranjel, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at loweraltitudes and in controlled airspace eliminating potential public risk flying to and from

established air fields. I, Alejandro Ranjel, have been informally analyzing fl ight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhan ce the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Alejandro Ranjel, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Alejandro Ranjel, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that ach ieved under current FARs. Accordingly I, Alejndro Ranjel, respectfully request that theFAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Alejandro Ranjel 1216 W endy Ridge Wi chita Falls, Texas 76302 (940)

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