October 20, 2015

Federal Aviation Administration (FAA)

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT

Dear Sir or Ma’am:

This petition is being submitted on our behalf without legal counsel or counseling services. Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11,

Juan Angel Martin DBA AM Media Productions, a full service independent Video Producer, hereby 

applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of 

our Small Unmanned Aircraft Systems (sUAS) commercially in airspace regulated by the FAA so long as 

such operations are conducted with and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333.

The requested exemption would permit AM Media Productions to pursue its commercial interests in 

providing aerial data capture to clients using a small advanced sUAV in the following areas:

- Video

- Marketing

- Surveying

- Special Events

- Agriculture

- Inspection

- General Photography

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 – 91.417
I, Juan Angel Martin have been flying sUAV for over a year. My most recent experience is with a DJI 

Phantom 3 Professional. I have been flying as a hobbyist and now ready to bring my skills to a 

professional level. In doing so, I consider all safety precautions and regulations as foremost with each 

flight. 

My request to operate commercially is primarily to record digital video data and other aerial 

photography data for privately owned fee aerial video which will assist in the promotion and marketing 

of their program for ultimate disposition and sale. For a small budget video production company and 

average producers the expense of such aerial videography is cost prohibitive. Only large companies and 

high end film makers can afford such expense. Depriving small producers and low budget productions

from a valuable marketing tool. Also, using my sUAV service avoids the high risks in a helicopter and/or 

fixed wing aircraft with fuel and persons on board. The reduced noise and size creates a much smaller 

environmental impact which promotes public and environmental safety. 

I, Juan Angel Martin, will act as AM Media Production Pilot in Charge (PIC). 

To make sure the operation will be safely conducted, the PIC will survey the flight area for any mobile 

phone base stations, radio transmission towers, power lines, or any other electromagnetic interference 

that could disrupt flight. The PIC will scan the area for any large buildings or trees that may affect with 

GPS accuracy or flight. The PIC will verify the weather is safe for flight to avoid wind speed exceeding 10

m/s, snowfall, rainfall, and restricted environmental visibility. Additionally, the PIC will go through the 

PREFILGHT CHECKLIST/maintenance and FLIGHT TEST PROCEEDURES in a secure area safe from persons

and property. 

The DJI Phantom 3 Professional is equipped with a built-in stabilized HD camera and GPS safety features. 

These safety features include the ability to restrict the maximum altitude they operate above ground 

level (AGL), to limit the radial distance from the operator and to exclude them from operations within 

designated Class B, C and D airspace including “no-fly zones”. This model has a failsafe function that is 

automatically engaged in the event communication is lost between the sUAS and the main controller 

transmitter. At that time, the sUAS will return to its point of takeoff and land safely. If the connection is 

restored, the PIC can regain control of flight and land manually. 

These specifications meet or exceed the Model Aircraft Operating Standards as set below:

- The petitioner will only operate its sUAS in line-of-sight of a PIC and/or Observer and will 

operate at sites that are “sufficient distance” from populated areas within the sterile area 

described in the FOPM. Such operations will ensure the sUAS will “not create a hazard to 

users of the national airspace system or the public.”

- When flying the sUAS within three (5) miles of an airport, airport operators will be notified 

and the operator will give the right-of-way to avoid flying in the proximity of full-scale 

aircraft. 

- Maximum flight time for each operation will be 20 minutes.

- Flights will be terminated when battery levels reach 30%, allowing sufficient reserve flight 

time to safely land the sUAS. 

- The sUAS will be pre-programmed so it will not be operated at an altitude that will exceed 

200 feet AGL, and not more than 100 feet above an elevated platform from which 

videography is planned. 

- Minimum crew for each operation shall consist of: sUAS PIC and a visual Observer.
- The sUAS operated by the Petitioner weighs less than 25 pounds, including all payload. 

- The sUAS will operate at speeds not to exceed 50 knots, can hover and can simultaneously 

move vertically and horizontally. 

- Given the small size of the sUAS and the restricted sterile environment within which it will 

operate, AM Media Productions operations adhere to the reform Act’s safety requirements. 

We respectfully request exemption under Section 333 to enable AM Media Productions to operate 

efficient, limited, low-risk commercial sUAS operations for the activities stated respecting at all times 

the space and privacy of citizens and property while keeping airspace safe. 

Respectfully,

Juan Angel Martin DBA AM Media Productions 

D-19 Calle 23 Forest Hills

Bayamon, PR 00959

Tel: 787-422-7250

Email: ammediapr@gmail.com