August 7, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., Washington, DC 20590 **RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation**  **Regulations.**
Dear Sir I Madam:
Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), Juan Luis Colon

-Candelaria (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal Aviation Regulations ("FARs") to allow fo r commercial o peration for aerial imaging and video of homes & properties, public and private events, news gathering, safety inspections, surveys, search and rescue missions and landscapes in the Commonwealth of Puerto Rico. **Applicant:** Juan Luis Colon

-Can delaria Paseo de la Ceiba 304 calle Moca Juncos, P.R. 00777

-7426 **Attachments:** DJI Safety Guidelines

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)
14 CFR 91.10314 CFR 91.1 09

14 CFR 91.119 (c)
14 CFR 91.121 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) and (b) Extent of relief I seek, and why **14 CFR Part 21 subpart H** The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I request exception. In the restricted environment an d under the conditions proposed o peration will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions. **14 CFR 45.23 (b)** Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to ma rket certain words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would need to be smaller than required minimum. Understanding the importance of lettering, I will mark my UAS with the largest possible letters by placing the word "Experimental" or assigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required.
**14 CFR 91.7** (a) As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check list prior to each flight an equivalen t level of safety will be provided. **14 CFR 91.9 (b) (2)** Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety willbe maintained by keeping the flight manual at ground control point where the pilot will have immediate

access to it. **14 CFR 91.103** As FAA approved flight manuals will not be provided for the aircraft, an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those found in attachment " DJI Safety Guidelines ". An equivalent level of safety will be provided by preflight protocol) to properly match the machine.
**14 CFR 91.109** UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalen t level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft.
**14 CFR 91.113** (a) **and (b)** I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills.
**14 CFR 91.121** The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe an exemption may b e needed. An equivalent level of safety is achieve by the operator receiving live flight data monitoring and confirming current a ltitude along with altitude of launch site shown on GPS altitude indicator. **14 CFR 91.203 (a) and (b)** Similar to, 14 CFR 91.9 ( b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately such documents. An equivalent level of safety will be achi eved by keeping these documents to the extent they are applicable to the UAS, at the ground control point where pilot has immediate access to them.
**14 CFR 91.405** (a), **14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417** (a) **and (b)** Given this section only a pplies to aircraft with an airworthiness certificate; these sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight. Juan Luis Colon

- Candelaria is seeking relief from all FARs above preventing applicant from conducting aerial photography and video of real estate taken at levels less than 400ft, at a speed less than 33.5 mph, and with a ma ximum flight time of 22 minutes . The drone to be used is a DJI Phantom 3 Professional . At 2.74 pounds, the weight of the UAS's meets the definition of "small unmanned aircraft" found in section 331 "The Reform Act". In order to obtain high qualityphotography and video the UAS will be used at speeds much less than it's top speed of 33.5 mph. Due to

the UAS being battery powered, there are no combustible fuels onboard the UAS. Maximum flight time for the UAS's is 22 minutes for their battery life. Flights will be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated with these aircrafts, I find this exception to be reasonable with an equivalent, or greater, level of safety to be reached by the operator. **Safety:** *Please see attachment " DJI Safety Gui delines " for safety precautions I use for every flight. Aside from these practices I have more than 25 years of experience piloting radio controlled aircrafts, both airplanes and rotorcrafts

. I’m also a certified Private Pilot, this gives me knowledge of t he different types of airspace, right of way rules, basic weather knowledge and weather minimums whic h helps me in the decision making of whether to fly or not. **Additionally:** 1) I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport manager has been made. 2) I land my UAS prior to manufacturer recommended minimum level of battery power

. 3) I pilot my UAS through remote control by line of sight

. 4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then slowly lands if communication with the remote control pilot is lost. 5) I actively analyze flight data and other sources of information to constantly update and enhance safety protocol. 6) I conduct extensive pre -flight inspections and protocol, during which safety carries primary importance. 7) I always obtain all necessary permissions prior to operation; and, 8) I have procedures in place to abort flights in the event of safety breaches or potential danger. **Pub lic Interest**  The use of an UAS in the real estate industry provides both buyers and sellers a higher level of service. For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting in a quicker sale of their home. Quicker home sales also help to accelerate the economy as a whole. Buyers experience the benefit of encompassing a whole property, sometimes several acres, in one photo or a short video. Not only does this benefit the specific home seller or home buyer, but it benefits the general public because it is much more efficient than traditional ways of using a plane or helicopter to achieve the same result. We can now provide this level of service while being conservative with fuel,time, emissions, noise, and other resources. Considering size, weight, speed, and absence of

combustible fuels, my UAS will have much less of a safety concern for the general public when compared to larger manned aircraft.