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 for commercial operation 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-Candelaria

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 91.103
14 CFR 91.109

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 and under the conditions proposed 

operation 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 market 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 equivalent 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 will 
be 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 

equivalent 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 be needed. An equivalent level of safety is achieve by the operator receiving live 

flight data monitoring and confirming current altitude 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 achieved 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 applies 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 maximum 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 quality 
photography 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 Guidelines" 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 the different types 

of airspace, right of way rules, basic weather knowledge and weather minimums which 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.

Public 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.