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PETITION FOR SECTION 333 EXEMPTION – THOMAS CARRERO JR., ESQUIRE 

March 1, 2016 

 

U.S. Department of Transportation 

Docket Operations 

800 Independence Ave. S.W. 

Washington, DC 20591 

Re: Petition of Thomas Carrero Jr., Esquire for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, Thomas Carrero Jr., Esquire (individual) hereby applies for an exemption from the 

Federal Aviation Regulations (“FARs”) identified below, to allow civil operation of small unmanned 

aerial systems (“sUAS” or “UAS”) as part of daily business operations. 

Description of Petitioner: Thomas Carrero Jr., Esquire provides legal and real estate services to clients 

that often require photographs. In recent months clients have requested aerial photographs that would 

require hiring an outsider to provide services related to taking said photographs. These photos are often 

utilized for marketing and/or litigation purposes. • Thomas Carrero Jr., Esquire is an attorney licensed in 

Florida, Pennsylvania and New Jersey and is a licensed Florida Realtor and Real Estate Agent • Thomas 

Carrero Jr., Esquire is properly licensed in the State of Florida to provide said services. • Thomas Carrero 

Jr., Esquire holds the following licenses/certifications; Attorney, Realtor and Real Estate Agent. 

In accordance with 14 C.F.R. § 11.81(a), Thomas Carrero Jr., Esquire provides the following information 

in support of its Petition for Exemption: 

Name and Address for Petitioner: Thomas Carrero Jr., Esquire, 1225 Tamiami Trail, A10, Port Charlotte, 

FL 33953; 941-624-4529; tcarrerojr@carrerolaw.com 

Point of contact for this Petition and specific contact information is as follows: T Thomas Carrero Jr., 

Esquire, 1225 Tamiami Trail, A10, Port Charlotte, FL 33953; 941-624-4529; tcarrerojr@carrerolaw.com 

Description of Proposed Operation: Thomas Carrero Jr., Esquire proposes to conduct the operation of a 

UAS, specifically the DJI Phantom 3 Standard (hereinafter " Phantom 3"), within the parameters of 

providing aerial photographs of single family residences and/or large acreage parcels of land... The Pilot 

in Command (“PIC”) for each operation will, at a minimum, be Thomas Carrero Jr., Esquire. Thomas 

Carrero Jr., Esquire has adopted and incorporated many of the AMA’s UAS Safety Code (the “Code”) 

and Operating Guide’s (the “Guide”) procedures into its own safety code and guide, which sets forth the 

mandatory standard operating procedures for its proposed UAS operations as detailed herein. The 

exception would be the location of operations that will take place at private residences with the 

authorization of the owner and not on property leased or owned by the AMA. These procedures provide a 

baseline to ensure that the Phantom 3 pilot possess sufficient knowledge of both airspace and the 

technology to operate safely in the National Airspace System (“NAS”). Any other assistant or 

photographer will operate with Thomas Carrero Jr., Esquire as the PIC in each operation and will meet 

the standards specified in the Guide, as well as any other additional requirement the FAA requires under 

this application. 
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Proposed UAS Operations Meet the Requirements of Section 333: Proposed operations in this 

Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as each 

of the statutory criteria and relevant factors are satisfied thusly: 

 a.) Approval is Warranted Based on the UAS’s Size, Weight, Speed, and Operational Capability. 

 Thomas Carrero Jr., Esquire will employ the Phantom 3 quadcopter for the operations described 

in this Petition for Exemption. This UAS is classified as a small drone or hobby craft and is lawfully used 

for recreational operations. The Phantom 3 has a maximum take-off weight of 2.69 pounds (including 

battery). The flight speed is limited to a maximum of 33.5 miles per hour and it will not be flown at an 

altitude that exceeds 200 feet AGL. All flights will be managed in such a way that they can be safely 

terminated with a reserve battery power of 25% of the battery's maximum charge. The Phantom 3 does 

not carry any flammable propellant or fuel. The UAS also has an integrated GPS system that calculates 

the UAS's position and height and relays that information via a secure connection to the operator. 

Through use of this GPS system and the installed firmware, the user is able to set maximum height and 

radius in relation to a pre-determined home point, restricting flight to a zone that is both approved by the 

FAA and the owner of the property being photographed. This system also automatically restricts flight 

within a range of airports that is greater than the 5 miles that the FAA requires. 

 Additionally, the UAS contains a failsafe mode if its connection to the remote control is lost, and 

this system permits the UAS to return to a predetermined location and land without injury or damage. 

 b.) Approval is Warranted Based on the Operational Restrictions Set Forth in the UAS Standard 

 Operating Guide 

 Together, the Guide and the Phantom 3 User Manual contain all of the procedures and limitations 

necessary to successfully perform the operations specified in this Petition for Exemption. To assist the 

FAA in making a safety assessment of Thomas Carrero Jr., Esquire’s proposed operations, below is a 

summary of operational limitations and conditions which will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines: 

 1. The Phantom 3 weighs 2.69 +/- pounds. 

 2. Flights will be operated within the VLOS of the PIC and or an observer, at a minimum. 

 3. Maximum total flight time for each operational flight will be limited to 25% reserve 

battery power remaining. 

 4. Flights will be operated at an altitude of no more than 200 feet AGL. 

 5. All operations will be conducted in class G airspace. 

 6. Flights will be restricted to pre-determined areas of the owner/clients property, which 

will always be located outside of 5 miles radius from an airport of any size or the necessary NOTAM will 

be filed for safe operation in advance of operations. 

 7. Flight zones will be located at the maximum distance away from persons, inhabited 

structures, and vehicles that is possible given the layout of the property. The flight zone in which 

operations occurs will be assigned based on the real time traffic, activities, and weather conditions. 

 8. Flights will be limited to a speed of 30 mph and vertical ascent will be limited to 15 

mph. 

 9. The UAS will be operated and maintained in accordance with the requirements of the 

Phantom 3 User Manual and any manufacturer Safety Bulletins. 

 10. Prior to the operation, the flights will be fully preplanned and briefed, including 

compass calibration, possible contingencies and emergency procedures. 

 11. The UAS will have the capability to abort flight in the case of unpredicted obstacles 

or emergencies. 

 12. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 

 13. All UAS operations will occur in daylight, Visual Flight Rules ("VFR") conditions. 

Instrument flight rules flights are prohibited and no flights will occur at night, or in adverse weather 

conditions. 
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 14. The UAS will be controlled by the Phantom 3 Remote Control System and the radio 

frequency spectrum used for operation and control of the UA shall comply with the Federal 

Communications Commission ("FCC") or other appropriate government oversight agency requirements. 

Regulations From Which Exemption is Sought: The Federal Aviation Act expressly grants the FAA 

the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, 

as the term is defined under § 40101 of the Act, including UASs, from its safety regulations and 

minimum standards when the Administrator decides a requested exemption is in the public interest. 

Thomas Carrero Jr., Esquire seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45, 61 and 91 for purposes of conducting the requested operations using UAS. Listed below are: (1) 

the specific sections of 14 C.F.R. for which exemption is sought, and; (2) reasons why the exemption 

would not adversely affect safety or provide a level of safety equivalent to the rule, including any 

operating procedures and safeguards that Thomas Carrero Jr., Esquire has adopted which will ensure a 

level of safety better than or equal to the rules from which exemption is sought. 

 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates Part 21 prescribes procedural 

requirements for the issue of airworthiness certificates. Thomas Carrero Jr., Esquire requests exemption 

from this subpart to operate the Phantom 3 without the requirement for an airworthiness certificate. Based 

on the proposed UAS being limited in size, weight, speed, operating capabilities, and operating within 

VLOS, Thomas Carrero Jr., Esquire believes that an airworthiness certificate is not necessary to ensure an 

equivalent level of safety to manned aircraft operations. Equivalent Level of Safety 6 The UAS indicated 

is safe when taking into account its size, weight, speed, and operational capability. As set forth above, the 

Phantom 3 Advanced weighs less than 3 pounds and will be flown at less than 30 mph and completely 

outside controlled airspace. Additionally, the craft carries pilots nor passengers, carries no explosive 

materials and or flammable liquid fuels, and operates exclusively within the parameters stated in the 

Guide. Operations conducted under this exemption will be closely controlled and monitored by the PIC 

and will be conducted in compliance with local public safety requirements, to provide security for the 

area of operation. In all cases, the UAS operated under the proposed conditions, will be at least as safe as, 

or safer than conventional rotorcraft operating with an airworthiness certificate without the restrictions 

and conditions of the proposed UAS operations. Further, the Phantom 3 does not need a means to 

communicate with other aircraft or ATC, because those capabilities will be possessed by the PIC and 

Observer, who are not onboard the UAS. See Grant of Exemption, Docket FAA-2014-0352 at 13. In 

addition, the UAS will be operated at all times in visual line-of-sight and in VFR conditions. Id. 

 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft Title 14 sets forth the 

procedural requirements for airworthiness certification of normal category rotorcraft. To the extent 

Thomas Carrero Jr., Esquire UAS would otherwise require certification under Part 27, it seeks an 

exemption from Part 27's airworthiness standards for the same reasons identified in the request for 

exemption from 14 C.F.R. Part 21, Subpart H. 

 Thomas Carrero Jr., Esquire seeks an exemption from the aircraft marking and identification 

requirements contained in 14 C.F.R. §§ 45.23(b) and 45.27(a). 14 C.F.R. § 45.23(b), Markings of the 

Aircraft, states: When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable. 14 C.F.R. § 45.27(a), Rotorcraft, 

states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by § 45.23. Even though the UAS will have no 

airworthiness certificate, an exemption may be needed as the Phantom 3 is by definition “unmanned” and 

so has no entrance to a cabin, cockpit, or pilot station on which the above stated words can be placed. 

Given the size of the UAV, two-inch lettering may be impossible. The word “Exempt” can be placed on 

the fuselage in compliance with 14 C.F.R. § 45.29(f). 
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 The equivalent level of safety will be provided by having the Phantom 3 marked on its fuselage 

as required by 14 C.F.R. § 45.29(f) where the pilot, observer and others working with the UAS will see 

the identification of the Phantom 3 as “Exempt” if so desired. The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. d. 14 C.F.R. § 

91.7(a): Civil Aircraft Airworthiness The regulation requires that no person may operate a civil aircraft 

unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the Phantom 3, the description of proposed operations above, an equivalent level of 

safety will be provided. e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil Aircraft Flight Manual in the 

Aircraft 14 C.F.R. § 91.9(b)(2) states: "(b) No person may operate a U.S.-registered civil aircraft ... (2) 

For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof." 14 C.F.R. § 91.203(a) and (b) state: "(a) 

Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft 

unless the airworthiness certificate required by paragraph (a) of this section or a special flight 

authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." 

 Given the small size and configuration of the Phantom 3, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the UAS because there is simply no room. 

Also the UAS has no cabin or cockpit. 

 Furthermore, in an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared 

by Dean E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 

91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, 

registration certificate, and other required documents from the ground control station from which he or 

she is operating the aircraft. As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule 

is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of 

safety will be achieved be ensuring that the pilot has access to the documents at the ground control station 

or point of control from which he or she is piloting the Phantom 3. 

 14 C.F.R. § 91.103: Preflight Actions requires each pilot in command to take certain actions 

before flight to ensure the safety of flight. As FAA approved flight manuals will not be provided for the 

aircraft an exemption will be needed. An equivalent level of safety will be provided through the PIC 

following the procedures set forth in the Guide and Manufacturer’s User Manual. The PIC will take all 

actions including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. The PIC will account for all relevant site-specific 

conditions in the preflight procedures. The FAA has granted exemption from this regulation to other 

small UAS operators. See Exemption No. 11109. 

 14 C.F.R. § 91.109(a): Flight Instruction provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. Thomas Carrero Jr., Esquire seeks an exemption from flight instruction 

requirements contained within 14 C.F.R. § 91.109(a). The equivalent safety protocol for student training 

purposes consists of the PIC and student using a "buddy box" system that utilizes two transmitters when 

applicable. The transmitter of the student is connected by a trainer cable to another transmitter (master 

transmitter) controlled by the PIC instructor. The PIC Instructor is able to control the UAS with his or her 

transmitter then flip a switch to turn control over to the student and flip the switch again to reclaim 

control. In this way, the PIC Instructor can easily demonstrate how to fly the UAS or rescue the UAS if 

the student makes a poor aeronautical decision without passing the same transmitter back and forth to 

preserve safety to the NAS and manned aircraft operations. Given the size and speed of the UAS that the 

Thomas Carrero Jr., Esquire intends to use, an equivalent level of safe training can still be performed 

without dual controls because no pilot or passengers are aboard the UAS, and as required by the Guide, 

all persons will be a safe distance away in the event that any difficulties during flight instruction occurs. 
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Moreover, Petitioner will conduct training in a controlled and sterile environment. As required by the 

Guide, training and instruction will be conducted in a sterile area on property that is owned and controlled 

by Thomas Carrero Jr., Esquire. These facilities will not be open to the public during UAS operations, 

and access will be restricted to authorized business personnel involved with the company. 

 14 C.F.R. § 91.119: Minimum Safe Altitudes prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, 

or structure in non-congested areas. Thomas Carrero Jr., Esquire requests an exemption from the 

minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119(d) allows for a helicopter to 

operate at less than those minimum altitudes when it can be operated "without hazard to persons or 

property on the surface," provided that "each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the 

proposed UAS operations will occur at under 200 feet AGL. Further, while the Phantom 3 will never be 

flown in or over congested areas, due to the nature and location of the proposed operations, the PIC, 

Observer(s), Instructors and/or Students may at times be less than 200 feet away from the UAS. 

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel onboard the Phantom 3, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent level of 

safety will be achieved given the size, weight, and 11 speed of the Phantom 3, as well as the controlled 

and sterile location where the operations will occur. In order to avoid any risk to manned aircraft, flight 

operations will be restricted to 200 feet AGL or below. As set forth in the Guide, the Phantom 3 flight 

height and radius restrictions will be set according to each operator’s level of experience which will be 

judged by the PIC. The Phantom 3 will be operated in an area that is owned by the client and closed to the 

public when in use. These restrictions will ensure that the proposed UAS operations are performed in a 

manner that protects the safety of participants, nonparticipants, the UAS, and other property. 

 14 C.F.R. § 91.121: Altimeter Settings requires a person operating an aircraft to maintain 

cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure 

airport or barometric pressure. This petition seeks an exemption from 14 C.F.R. § 91.121, to the extent 

that the Phantom 3 does not have a barometric altimeter, but rather a GPS altitude read out. The Guide 

requires compass calibration prior to each operation of the Phantom 3 to ensure the GPS functions 

correctly. The Phantom 3 User Manuel contains instructions for achieving this and the manufacturer, DJI, 

will provide additional support if necessary. 

 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions states: (a) No person 

may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising 

speed – i. During the day, to fly after that for at least 25 minutes; or ii. At night, to fly after that for at 

least 45 minutes. Thomas Carrero Jr., Esquire requests an exemption from 14 CFR § 91.151(a)'s fuel 

requirements for flight in VFR conditions because the technological limitations on the energy capabilities 

of the 4480mAh LiPo battery used in the Phantom 3 means that no meaningful flight operations can be 

conducted with the Phantom 3 while still maintaining a 30 minute battery reserve. An exemption from the 

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. The batteries powering the Phantom 3 

provide approximately 25 minutes of flight time. Training operations will be limited to a minimum 

voltage to ensure appropriate reserve battery to maintain an equivalent level of safety at all times. The 

UAS will notify the operator when they are approaching and they are required to land at their home point 

and either switch out the battery or pause operations for recharging. If both the operator and PIC fail to 

land the UAS prior to the allotted minimum voltage, the UAS will autonomously return to its original 

launch position. 

 Thomas Carrero Jr., Esquire seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R., sections 91.405, 91.407, 91.409, and 91.417. These rules specify maintenance and 

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections ...have discrepancies repaired as described in part 43 of this 
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chapter.”) Exemption from these rules is requested because these sections of Title 14 require the aircraft 

to be maintained and inspected in accordance with Part 43, which only applies to aircraft with an 

airworthiness certificate. Therefore, based on the exemptions sought, these sections do not apply to 

Thomas Carrero Jr., Esquire proposed UAS operations. Maintenance will be accomplished by authorized 

operators, staff, and/or contracted labor pursuant to the Guide and the Manufacturer’s User Manual. An 

equivalent level of safety will be achieved because a UAS like the Phantom 3 or like craft and its platform 

are very limited in size, will carry a small payload, and will operate only in defined areas for limited 

periods of time. If mechanical issues arise the Phantom 3 will be able to land immediately on property 

owned by the client and or owner of the craft to receive immediate maintenance. As provided in the 

Guide and Manufacturer’s User Manual, the operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and will keep a log of any maintenance performed. 

 Thomas Carrero Jr., Esquire seeks an exemption from 14 C.F.R. Part 61, 14 C.F.R. §§ 61.3, 

61.113: Private Pilot Privileges and Limitations. Thomas Carrero Jr., Esquire will serve as the PIC for all 

flight operations and the instructor/co-instructor of any course including an element of drone flight. This 

should qualify persons with a private pilot’s certificate, among other qualifications, to instruct drone 

operation education when necessary. However, as is the nature of the proposed operations, introductory 

flight instruction using the Phantom 3 UAS will be provided to staff who will likely not have a private, or 

any type of, pilot’s license. Accordingly, Thomas Carrero Jr., Esquire seeks exemption from 14 CFR Part 

61, including 14 CFR § 61.3 to the extent that these regulations are interpreted as requiring a student 12 

receiving UAS operation instruction to have a private pilot's certificate. All student instruction flights will 

be conducted under closely controlled circumstances, outside of navigable airspace and away from 

persons or property not involved in the instruction. In addition, the student instruction flights will be 

conducted under the close supervision of an instructor acting as PIC. In addition, to the extent that 

Thomas Carrero Jr., Esquire may be employing persons with a private pilot’s license to operate its UAS, 

an exemption is also sought from 14 C.F.R § 61.113, which restricts private pilot certificate holders from 

flying aircraft for compensation or hire, and which would also require a second class medical certificate. 

The purpose of this section is to ensure the skill and competency of any PIC where the aircraft is carrying 

passengers or cargo for hire. In this case, while instructors acting as PIC during UAS operations will be 

doing so for educational purposes as part of Thomas Carrero Jr., Esquire’s staff, the Phantom 3 or like 

craft carries neither passengers nor cargo. Moreover, in the Astraeus Aerial Grant of Exemption (FAA 

Docket No. FAA-2014-0352), the FAA determined that the unique characteristics of UAS operation 

outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring 

the PIC to have a Commercial Pilot Certificate and Class I or II Medical Certificate. Equivalent Level of 

Safety Thomas Carrero Jr., Esquire will ensure an equivalent level of safety to the regulatory 

requirements of 14 C.F.R. Part 61, including 14 C.F.R. §§ 61.3 and 61.113 by following the safety 

procedures provided in the Guide. In addition to training and experience requirements and limitations, 

Thomas Carrero Jr., Esquire has placed additional restrictions on its proposed UAS operations to ensure 

an extra margin of safety. The UAS will only operate in a controlled and sterile area away from persons 

and property not involved in the operation. It will be flown based on VLOS at no more than 200 feet 

AGL. Collectively, these procedures ensure that the proposed UAS operations can be conducted safely. 

Public Interest: Because the technology to provide photographs that can better facilitate clients desires to 

market real estate for the purchase of real estate has advanced to a degree that is not possible from 

traditional photography the public will be well served by offering aerial photographs that can better 

produce the desired results. Some of which include the depiction of the beauty and aesthetics of a 

property for marketing purposes or the location of a property to surrounding adverse conditions that may 

affect the decision process of an institutional lender when making a loan for a particular property. 

Likewise, should litigation arise due to disputes over boundary lines, encroachment, easements, etc..., 

aerial photography could provide evidence not readily avail to litigants in order to swiftly and amicably 

resolve disputes. 
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Privacy: All of Thomas Carrero Jr., Esquire’s UAS operations shall be conducted in accordance with 

applicable federal, state, or local laws regarding privacy. Thomas Carrero Jr., Esquire will not conduct 

flight operations over property that it does not own or control without the prior consent and knowledge of 

the property owner. Moreover, Thomas Carrero Jr., Esquire will not capture or use images from restricted 

areas requiring privacy and or confidentiality under any circumstance. This does not mean, however, that 

images may not be taken that are permitted by law and do not require a level of privacy that is an 

exception to the norm. As an attorney, Thomas Carrero Jr., Esquire, is especially cognizant of 

confidentiality and privacy laws. 

Federal Register Summary: Pursuant to 14 C.F.R. Part 11, the following summary is provided for 

publication in the FEDERAL REGISTER, should it be determined that publication is needed: 

Petitioner seeks an exemption from the following sections in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.3; 61.113; 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 

91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & 

(b). The exemption will enhance safety by reducing risk to the general public and property owners by: (a) 

ensuring that the operations of the UAS described above are recognized by the FAA in the form of an 

exemption; and (b) how to safely operate small UAS in furtherance of career objectives and to the benefit 

of public safety while providing a valuable service as it relates to the legal and real estate businesses 

provided by Thomas Carrero Jr., Esquire. 

Respectfully submitted, 

/s/ 

THOMAS CARRERO JR.