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. 11, to request that I, Alejandro Ranjel an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations (“FARs”) listed below so that I, Alejandro Ranjel may operate my small ultra-light

unmanned aircraft system (“UAS”) commercially in the airspace regulated by the Federal 

Aviation 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 as 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 the 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 exemption 

request would permit operation of ultra-light weight, unmanned (piloted by remote control) 

and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. Predetermined 

in areas away from general public, airports, heliports and vehicular 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 

prevent 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) responsibilities 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 specific 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. Both 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 Information:

Alejandro Ranjel 

1216 Wendy Ridge 

Wichita Falls, Texas 76302

(940)-414-0920

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which Alejandro 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 Alejandro 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 Section 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 defined 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 rules governing such craft. Thereby,

providing direct experience and valuable information for formal regulation that can be
administered 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; Whether the UAS will be operated near airports or

heavily populated areas; and, Whether the UAS 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 GPS and auto return safety technology. Weighing

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 hover 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 radio controls are released. With 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. When 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 approach 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) minutes 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 under 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 light 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 Alejandro Ranjel Request Will Benefit the Public As 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 homeowners 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 emergency 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 public’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 academic and geographical awareness. Both of which serve as a

stimulus to the community.

V. Reasons Why Alejandro Ranjel Exemption Will Not Adversely Affect Safety Or

How The Exemption Will Provide a Level of Safety At 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

innovation and implementation of new and novel, as of yet undiscovered safety

protocols that can be embraced by the NAR6, AAR7, 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 ceiling
set 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 minimum 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. While 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 has 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 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, 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 as 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 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 on board pilots or passengers, and given the size of the UAS's, this Regulation is

inapplicable. 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, 9565, 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 Ranjel.

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 regulation 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,

while 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 200 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 size, 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 43 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 The 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 will 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, Alejandro Ranjel seeks an exemption from the following 

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 lower
altitudes and in controlled airspace eliminating potential public risk flying to and from

established air fields. I, Alejandro Ranjel, have been informally analyzing flight 

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 enhance 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

achieved 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 Wendy Ridge 

Wichita Falls, Texas 76302

(940)-414-0920