.•
August 8th, 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140 1200NewJerseyAvenue, SE Washington, DC20590 ,. __.: i 

# H:02

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11ofthe Federal Aviation Regulations from certain parts ofthe FARs. Dear Sir or Madame, Pursuantto Section333ofthe FAAModernizationand ReformActof2012 (the ReformAct) and 14 C.F.R. Part 11. MauricioEscobar, photographer, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow him to operate a small Unmanned Aircraft System ("UAS") under the conditions and limitations set forth in this Petition. The proposed exemptions, if granted, would allow Petitioner to operate small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 pounds or less for the purpose of aerial filming of motion pictures, music videos, web videos, corporate videos, television programs and commercials, and still photography. The requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would provide safety enhancements to the already safe photography operations presently using manned helicopters and airplanes in 

### LosAngeles Countv. Approval of thisexemption would thereby enhance safety and fulfill the FAA Administrator's responsibilities to "

...establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) of the Reform Act." The name and address ofthe applicant is: 

### Mauricio Escobar3752 SouthviewCt. Palmdale Ca. 93550

Regulations from which the exemption is requested: 14CFR Part21 14C.F.R.§45.23(b) 14CFR §61.3 14C.F.R.§91.7(a) 14CFR § 91.9 (b) (2) 14C.F.R.§91.103 14C.F.R.§91.109 14C.F.R. §91.119 14C.F.R.§91.12114CFR §91.9 (b) (2} Requirement for manual to be No one aboard to read manual available in thecockpit 14CFR §91.103(b) Requirement for crew Unmannedvehicle membersto beonboard 14CFR §91.1 09 Requirementfordual No one aboard to operate controls during flight controls 14CFR §91.119 Minimum altitudes forsafe Safety requires operation flight below these altitudes 14CFR§91.121 Altimeter settings No one aboardto read altimeter 14CFR §91.203 (a) & (b) Requirement for registration No one aboard to read and airworthiness certificates certificates to be onboard 14CFR§91.205(b) Cockpit instruments No one aboard to read 14CFR§91.215 IJ"ransponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 14CFR §91.405 {a) Inspection requirements Designedformanned aircraft; not suitable foroffthe-shelf 14CFR §91.407(a) {1) Inspection approval Designedformanned requirements aircraft; not suitable foroffthe-shelf 14CFR §91.409 (a) {2) Airworthiness inspection Designedformanned aircraft; not suitable foroffthe-shelf 14CFR § 91.417 (a) &(b) Maintenance records Designedformanned requirements aircraft; notsuitableforoffthe-shelf

### High-quality video cameras and priced at affordable levels attracted the petitioner. His entire involvement with photography has involved exploring new technologies and adapting them to capture better quality imagery. Petitioner currently has practiced flying various UAS models under 50 pounds, under 35 miles per hour, under 400 feet, for total of sixty hours over remote areas of the Los Angeles metropolitan area, over remote locations in Antelope Valley, and in the rural areas of Los Angeles County, and in Central California for recreational purposes, exploring the potential and the limitations of its video subsystem. He is pleased with the quality of the still and video imagery captured and overall safe maneuverability and controlled operation of the various UASs he's flown. Currently, a number of people, some professional colleagues and potential future clients, have been made aware of Petitioner's accomplishments and have seen the results and are requesting Petitioner to undertake additional "micro drones, drones, or quadcopter" photographyfor compensation. He has been advised that this is not now permitted unless he obtains special permission from the FAA. Many competitors of Petitioner are actively flying UAS's to conduct aerial photography for commercial purposes, notwithstanding the FAA's stated prohibition. He also notes and has read the congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the economic and societal benefits that can resultfrom widespread deployment of UAS technology. Accordingly, Petitioner applies for authorization under the Federal Aviation Act, and the FARs rules to undertake the following activities for commercial purposes. Unless the Petition is granted, Petitioner will be at a significant competitive dis-advantage if he, as he prefers, complies with FAA policy. Vehicle 

### The Petitioner will fly various small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 pounds or less, at a speed no greater than 50 knots. This vehicle has built in capabilityto limit the height itflies above the ground, to limit the radius of the distance itflies from the operator, and to exclude itfrom class 8, C, and 0 airspace. The vehicle also has the built-in capability to return to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the height, radius, or airspace limitations programmed into it. The vehicle weighs about five pounds empty and has a maximum gross weight of approximately twenty pounds. It has a top speed of about 30 knots, carry neither a pilot nor passenger, carry no explosive materials orflammable liquids, and operate exclusivelywithin a predetermined area. It has four fixed pitch rotors, thrust from which is varied by changing RPM. It is powered by a lithium polymer battery. Flight Profile 

### The petitionerwill notfly UASabove 400feet above ground level, or morethan 1500feet awayfrom him.Hewill carefully preflightcheckthevehicle beforeeach missiontoassurethat itsnavigationsystem are properlycalibrated andthat anyincluded return-to-home features, altitude, and radius limitations work. He will operate the vehicle for aerial photography missions only in the early morning hours and other times when few people are out in the public. He will operate it only over largely unpopulated areas where the potential of uncontrolled descent to cause injuryor damage is lowest.He will not operate it in controlled airspace whatsoever, without express written consent from the FAA. In the unlikely event that a manned aircraft flies beloW 400 feet AGL where the petitioners operating his Phantom, he will keep both the vehicle and manned aircraft in sight and avoid the manned aircraft. More particularly, the Petitioner will fly UASs only over the following types of areas in Metropolitan Los Angeles:
• Over Lakes and various waterways of Los Angeles and the state of California, outward of the

shoreline
• Over open water in marinas, anchorages, and rivers amongst and surrounding the city of Los Angeles
• Over lines of railroad and rail classification yards
• Over metropolitan Los Angeles parks
• Over nonresidential and noncommercial large-scale industrial areas
• Over private propertywhen he has been commissioned bythe person in legal possession of the propertyto do so.
• Over public or private events petitioner is hired as photographer. ThePetitioner'sproposedoperationssatisfythecriteriaprovidedinSection333oftheReformAct relatingtosize,weight, speed operatingcapabilities, proximitytoairportsand populatedareasand operationwithinvisual lineofsightand nationalsecurity.The Petitionjustifies grantofthe requested exemptions allowthe Petitionertoobtain aerial photographywith hisdrone. Respectfully submitted, Mauricio Escobar

FARSection 14CFR§45.23(b)

14CFR Part21
14CFR§61.3

14CFR §91.7 (a) 

### APPENDIX Subject Requirementtodisplay registration numberonvehicle Aircraft certification requirements and procedures Requirement for pilot certificate

Airworthiness requirement Justification Insufficient space onvehicle
Designed for manned aircraft; not suitable for off-the-shelf sUAS Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for sUAS operator Designed for manned aircraft; not suitable for off-the-shelf sUAS14CFR § 91.151{a) • 14 CFR § 91.203 (a) & (b) 14CFR §91.205(b) 14CFR § 91.215 14CFR§91.405 (a) 14CFR § 407 (a) (1) 14CFR § 409 (a) (2) 14CFR § 417 (a)

### & (b) The Appendix describes the FARs from which an exemption is requested and summarizesthe justification for each requested exemption. The Petition is submitted to fulfill Congress' goal under Section 333(a) through (c) ofthe Reform Act, which directsthe Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Administrator must determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threatto national security in light of the following:
• The UAS's size, weight, speed, and operational capability;
• Operation of the UAS in close proximity to airports and populated areas; and
• Operation ofthe UAS within visual line ofsight oftheoperator

Reform Act § 333 (a). Ifthe Administrator determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." ld. § 333(c) (emphasisadded). The Secretary has delegated his aviation authority to the Administrator of the FAA. The Federal Aviation Act expressly grants the FAA the authorityto grant exemptions from its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs.The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 of the Federal Aviation Act if Administrator finds the exemption inthe public interest. 49 U.S.C. § 44701(f) See also 49 USC§44711(a);49'USC §44704; 14CFR §91.203 (a) (1). The petitioner has overfifteen years of experience as a digital photographer, both as a profession and hobby, and has been a helicopter and airplane RC enthusiast without incident for overtwelve years. The wide availability of small Unmanned Aircraft Systems, also known as "micro drones, drones, or quadcopter" capable of carrying