Francisco Jeremias

Drones De Puerto Rico

PO Box 567

San Lorenzo, PR 00754

787-526-1000

Aug 11th 2015

U.S. Department of Transportation

Docket Operations

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 

91.103,91.121,91.203, 901.151

Following the format of FAA exemption No. 11138-Regulatory Docket No. FAA – 2014-0481 I have 

included:

1. Supplement Response for Petition

2. Phantom Flying Flow Chart :

3. Phantom Quick Start Manual: http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en_v1.2.pdf

4. Phantom 3 Professional User Manual: http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en_v1.2.zip

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, I, 

Francisco Jeremias , FAA Certified Commercial Pilot (certificate #3730354), Ground Instructor (certificate 

# 3730354), would like to apply for an exemption from the following Code of Federal Regulations (CFR) 

to be allowed commercial operation of a lightweight Unmanned Aircraft Systems (UAS) for aerial 

imaging and video.

I am abt one (1) years flying drones, however I have nearly 3000 hours of PIC time in a fixed wing 

aircraft. I also have countless hours of RC airplane hours for as a hobby. Our office recently added the 

DJI Phantom 3 Professional quad-copter (weighing less than 3 pounds), equipped with the included 

camera.

Manufacturer: DJI

Model: Phantom 3 Professional

Serial #: 0181

Registration number:N266PR (in process)
My intent is to capturing aerial photos/videos for commercial used; following exemption and approval 

by the FAA.

My exemption request would permit operation of ultra-light weight, unmanned (piloted be remote 

control) in predetermined areas away from general public, airports, heliports and vehicular traffic, under

200 ft (AGL) and after reviewing the flight path of aerial observation. I will operate in a safe environment 

that is strictly controlled away from power lines, elevated lights, airports and actively populated areas. I 

will personally conduct extensive preflight inspections and implement the same protocols I perform 

during my fixed wing flights. I will also check weather and will not fly in adverse weather. I shall abide all 

FAA requirements to ensure this exemption will provide the highest level of safety.

14 CFR Part 21, subpart H: Airworthiness Certificates §14 CFR 91.203

Given the size, weight, speed and limited operating area associated with the aircraft to be utilized, I am 

requesting exemption from 14 CFR part 21, Subpart H (Airworthiness certifications) and § 91.203 (a) and 

(b), subject to certain conditions and limitation, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 of PL 112-95 (Section 333).

14 CFR 45.27 (a): Location of marks; non fixed-wing aircraft. 14 CFR 45.29 

(3)(c)(d)(e)(f)(h): Size of Marks

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have 

a cabin, cockpit, or pilot station on which to mark certain words or phrases. Additionally two –inch 

lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. I understand the need for markings and will mark my UAS in the larges possible lettering 

and if required by the FAA I will place the necessary markings, name or numbers to my UAS.

I also ask for an exemption from §91.405(a), 91.407(a)(1), 91.409(a)(2) an 91.417(a) and (b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection of my UAS 

before each flight as outlined in its operating documents.

14 CFR 91.103 (b)(1), (b)(2): Preflight Action

If granted an exemption I agree to additional safety procedures including, but not limited to:
1. Keeping my UAS within a radius of 400 feet from the controller to both aid in direct line of sigh visual 

observation.

2. Operate the UAS for 10-15 minutes per flight: land my UAS according to the SOPs and minimum 

battery power.

3. Operate my UAS only within visual line of sight and during daylight hours.

4. Use the UAS GPS system, a flight safety feature that slowly lands the aircraft when communication is 

lost.

5. Make sure all software for the UAS is up to date and firmware is functioning properly.

6. Contact Air Traffic Control (ATC) for every flight within class (D) airspace. I will relay all my intentions 

and flight information.

7. Have procedures in place to abort flights in the event of safety breaches or potential harm.

Aerial videography and photography for marketing has been around for a long time through manned 

fixed winged aircraft and helicopters, but for small business owners its expense has been costprohibitive. Granting this exemption would allow me to provide this service at a much lower cost. 

Further, my small UAS when used properly will pose no threat to the general public given its small size 

and lack of combustible fuel when compared to larger manned aircraft. The operation of this UAS will 

minimize ecological damage.