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Angel Andres Videography dba Colorado Aerial Video

10450 Emerson St

Northglenn, CO 80233

719-360-7428

angel@angelandres.com

U.S. Department of Transportation,

Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Madam or Sir:

Thank you for your time. This letter serves to request of the USDOT an exemption from some rules of Title

14CFR for the purpose of operating two types of small Umanned Aerial Systems (herein referred to as sUAS)

commercially by my company, Angel Andres Videography:

DJIs Inspire1 Quadcopter & its supporting systems and;

3DRs Solo Quadcopter & its supporting systems

The authorization for such exemption currently exists as a result of the FAA Modernization and Reform Act of

2012. The precedent for issuance began with the first Section333 exemption granted to Astraeus Aerial on July

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, 2014 and continues presently with over 1,200 similar petitions granted as of August 17

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, 2015.

The primary use of the sUAS will be for obtaining low-level aerial footage of any object, person and/or property

which may be requested of my company by my clientele within the United States of America, its territories and

commonwealths (including Puerto Rico). A more detailed explanation of my operating intentions can be found in

the attached proprietary manual, Angel Andres Videography Aerial Operations Guideline.

Currently, the FAA is granting Section333 exemptions with a blanket COA for requests smilar to mine for those

operators willing to accept the following conditions:

UA must operate at or below 200ft AGL

UA may not fly within 5 nautical miles (NM) from an airport having an operational control

tower; or

3 NM from an airport with a published instrument flight procedure, but not an operational

tower; or

2 NM from an airport without a published instrument flight procedure or an operational tower; or

2 NM from a heliport with a published instrument flight procedure

I accept those conditions temporarily to allow my company to quickly take advantage of the blanket COA. However, I ask for your further consideration and feedback on the following:

A large part of my operation will be to film, at the property owners request, real-estate in the Greater

Denver area. Currently, there are three Class D airports (KAPA, KBJC, KFTG), and a Class B (KDEN) air-
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port surrounding this area. If I were operate 5nm away from any towered airport, that would add up to

an area of 78.5nm2 (square nautical miles) for each airport. That grossly restricts the operating area for

all sUAS operation.

I assert that a level of safety equivalent to currently exists can be maintained while operating as close

as 2NM to towered airports if the following conditons are met:

PIC files a flight plan & subsequently opens such plan with Flight Services prior to the flight

Prior to flight, two-way radio contact and position report must be made with:

The Air Traffic Controlling agency responsible responsible for that airport prior to

enter the airspace (i.e. Centennial Tower, Metro Tower, etc) or;

If no operating controlling agency exists at the airport during the time of flight (i.e.

no tower, tower closed) position reports must be made by radio on the appropriate

common traffic advisory frequency (CTAF) prior to and during the flight

The VideoDrone must remain below 200feet AGL or any altitude assignment from

Air Traffic Control.

Position reports are to be regularly broadcast on the CTAF until the operation is concluded.

Therefore, I request to conduct sUAS operations in an area between 2NM and 5NM from any towered airport

while heeding those conditions IF consideration of such request does not further delay the approval of this Section333 request and a subsequent issuance of the FAAs current blanket COA to my company, Angel Andres

Videography.

I herein request relief from the following sections of 14CFR:

Part 21 Airworthiness Certification 21, Subpart H Certification procedures for products and parts, Airworthiness

Certificates.

Reason:

In the initial grants of exemption to prior petitioners found in:

Exemption No. 11213 to Aeryon Labs, Inc. (Docket No. FAA- 2014-0642);

Exemption No. 11062 to Astraeus Aerial (see Docket No. FAA20140352);

Exemption No. 11109 to Clayco, Inc. (see Docket No. FAA20140507);

Exemption No. 11112 to VDOS Global, LLC (see Docket No. FAA20140382)

the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause

to find that the UAS operation enabled by this exemption is in the public interest.

The unmanned aerial vehicles and their respective systems that I am proposing to using in connection

with this exemption request are equivalent to those of the prior petitioners listed above in so much that

the systems:

carry no passengers or crew,

operate on an electrical power source as opposed to flammable fuel,

are substantially smaller (less than 10lbs) than their larger manned counterparts
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Part 45.23 (b) Marking of the Aircraft

The sUAS described in this exemption request will have no airworthiness certificates. However, I request an exemption as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word

Experimental can be placed. Given the size of the UA, two-inch lettering will be impossible. The equivalent level of safety will be provided by having the UA marked on its fuselage as required by §45.29 (f) where the pilot,

observer and others working with the UA will see the identification of the UAS as Experimental. The FAA has

previously issued exemptions to this regulation in Exemptions Nos. 10700, 8738, 10167 and 10167A.

Part 61 Certification: Pilots, Light Instructors, and Ground Instructors

Reason:

I assert that the need for a PIC to hold a Commercial Pilots certificate is an unecessary financial and

time-consuming burden on my company. The knowledge required for operation of the sUAS described in this

exemption request has already been obtained at the Sport and Private Pilot levels:

In previous grants of exemptions, such as Exemption No. 11080 (Regulatory Docket No. FAA2014-0355), the FAA wrote:

The FAA analyzed the areas of knowledge specified in 14 CFR part 61 for that of a

commercial pilot versus a private pilot. The results show that the required areas of

knowledge for a commercial versus private pilot cover the same fundamental principles,

Given that documented acknowledgment by the FAA, I request exemption from this part to the extent

that any FAA Certificated Sport Pilot or Private Pilot be allowed to act commercially on behalf of Angel Andres

Videography as PIC FOR HIRE of the sUAS described in this exemption request.

I request that the training guidelines listed in the attached, proprietary Angel Andres Videography VideoDrone Manual be approved for use of the sUAS described in this exemption request (i.e. DJI Inspire1 & 3DR

Solo).

Part 91 General Operating and Flight Rules

91.103(b)(2) Preflight action

91.105 Flight crewmembers at stations

91.109 Flight instruction

91.119 Minimum safe altitudes

91.121 Altimeter settings

91.151 Fuel requirements for flights in VFR conditions

91.215 ATC Transponder and Altitude Reporting Equipment

91.405 Maintenance required

91.407 Operation after maintenance

91.409 Inspections

91.417 Maintenance records

Reason:

91.119(c) Referring to Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500

feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. I request modification, waiver or exemption

and clarification concerning the terms "congested areas" and "densely populated". I request waiver from

this condition to allow safe, reasonable and responsible operations in areas of subdivisions and neighborhoods if so hired to operate in such areas.
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91.121 Referring to Exemption 11138 (DOUGLAS TRUDEAU), this section should not apply to my intended operations since the sUAS does not have an altimeter and instead utilizes electronic GPS sensor

for altitude information.

91.151(a) Referring to Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC), prior relief has been

granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos.

2689, 5745, and 10650. Similar sUAS specific relief has been granted in Exemption Nos. 8811, 10808,

and 10673 for daytime, VFR conditions. The sUAS I inteded to use (DJIs Inspire1 & 3DRs Solo) provide battery power remaining in percentage of full charge to the PIC via radio transmission to the control unit. The UAs batteries provide between 20 and 40 minutes of powered flight depending on operational needs.

Information Ive included in the attached operating manual (named Angel Andres Videography

VideoDrone Manual) details the procedures in connection with power management. Those documents

instruct the PIC to initiate a landing procedure when battery remaining reaches a specified level. Given

the limitations on proposed operations and the location of those proposed operations, the FAA found

that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.

91.215 requires aircraft to carry and use a transponder with altitude reporting equipment capabillity (i.e.

Mode C). Relief from this is needed because the size of the Inspire1 & Solo airframes are too small for

such equipment to be installed. However, the altitudes at which and locations where the UA will be operated will allow safe separation from other aircraft. Further, we are willing to use two-way radio communication to make positon reports from the base-station when in an area of 2NM to 5NM of any airport/heliport.

91.405, 91.407, 91.409 & 91.417 require maintenance; post maintenance procedure; inspection; and

maintenance record processes which do not apply, in a practical sense, to the DJI Inspire1 and 3DR Solo

airframes proposed for use in connection with this exemption request. The Inspire1 and Solo are commercially available airframes shipped with manufacturer specific instructions for maintenance.

Information Ive included in the attached Angel Andres Videography VideoDrone Manual details those manufacturer maintenance instructions and provide maintenance guidance to PIC under the

employ of Angel Andres Videography.

Public Interest

An sUAS operated under exemption granted in connection with this petition allows my company to assist

in meeting a growing public demand across the country for aerial video footage of property, products, events

and various creative services:

Property: Increasingly, real-property owners, real estate agents and many other entities are

seeking an enhanced perspective of their propertys amenities and propertys benefits that

cannot be portrayed via traditional, ground-based videography. Aerial videography provides

this perspective as a strong and highly desired marketing tool which advances commerce.

News Gathering: The demand for an elevated, objective view of newsworthy events has

long been an expensive investment for all television news agencies, particularly on a local

level. Many news agencies have opted, in recent years, to cut-back on their aerial coverage

of many newsworthy incidents. sUAS help augment this coverage positively.

Artistic Expression: A less obvious but real demand is that of artistic and creative service

agencies. These include marketing companies; independent film productions and television

commercials. All enhancing commerce.

Disaster Survey: When reasonably compensated for expenses by an emergency response

agency (government or private) my company can use an sUAS to assist in the survey of,

and to a lesser degree the search and rescue of people in, an area suffering from incidents

related to natural disaster.

Through the use of my sUAS resources, I plan to assist those propery owners, news agencies, creativeservice teams and emergency management agencies gain value that only aerial videography can provide for a
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lower price and higher safety margin than is typically offered by large, manned, fossil-fuel driven aircraft.

Affect On Safety:

An sUAS operated under exemption granted in connection with this petition is capable of providing a

level of safety at least equal to the existing rules because:

The Inspire1 & Solo airframes are dramatically smaller than their larger, unmanned counterparts at a weight of less than 10lbs each (i.e. one Eurocopter AS350 currently used in Denver for general newsgathering can weigh over 2,500lbs)

The Inspire1 & Solo aircraft are powered by battery as opposed to flammable fuels

Though the PIC will not be present within the Inspire1 & Solo airframes, thousands of

flights documented by their respective manufacturers have repeatedly demonstrated the

ability to control the UAs remotely to an accuracy of 1/2meter vertically and 2-1/2meters

horizontally.

If the integrity of the radio link to the UA degrades to a level where the PIC can no longer

control the UA, both sUAS (Inspire1 & Solo) have built within the system a failsafe. This failsafe triggers the UAs return to a pre-determined GPS point/location.

If the power available in either of the UAs batteries falls below a preprogrammed level, the

UAs firmware causes the UA to initiate a controlled landing or return to a pre-determined

GPS point/location.

Both manufacturers have demonstrated their ability to address safety issues quickly and forward updates to firmware and airframes. This is done by a system of registration of the

sUAS by their respective owners to the company and incident reporting via their respective

websites:

http://3drobotics.com/download_software/

http://www.dji.com/product/inspire-1/download

The Pilot In Command of the sUAS described in this exemption request will be a certificated

Sport Pilot, Private Pilot or higher with knowledge of airspace and aircraft operations in the

United States National Airspace System. This allows safe and intelligent integration of the

sUAS in a world of full-scale aircraft.

Summary for the Federal Register:

The following summary can be used (and amendend as you see fit) for publication:

Angel Andres Videography dba Colorado Aerial Video (herin applicant) seeks an exemption

from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b)

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a);91.215 and; 91.405 (a); 91.407 (a)

(1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially two types of

small unmanned vehicles (55lbs or less) for online video, newsgathering, motion picture and

aerial survey operations.

Approval of exemptions allowing commercial operations of sUASs in the videography/film indus-
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try enhances safety by reducing risk. Many modern video operations, using jet or piston power

aircraft, operate at low altitudes from the subject being filmed and occasionally in close proximity to people and structures. These aircraft (such as one used in Denver, CO for newsgathering)

regularly weigh over 2,500lbs. and carry large amounts of jet A or other fuel (140 gallons for jet

helicopters). Those aircraft must fly to and from the video shoot location.

In contrast, an sUAS which weighs less than 55 lbs. and powered by batteries eliminates much

of that risk due to the reduced mass and elimination of combustible fuel carried on board. Additionally, the sUAS is carried to the area of the shoot by hand and carries no passengers or crew.

That alone almost completely eliminates the risk of injury to pilot and camera operator.

Allowing my company to operate small UASs provides an equivalent level of safety supporting

the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These small aircraft operate at slow

speeds, close to the ground, and in an area that is highly controlled. As a result, they are far

safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy. All flights will occur either over public property where at a safe distance from non-participating by-standers or, when granted permission from property owners, over private or controlled access property. Those people filmed on private property will have consented to being

filmed, or otherwise have agreed to be in the area where filming will take place.

All flights are operated by an FAA certificated Pilot.

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Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national

security  provide adequate justification for the grant of the requested exemptions allowing commercial operation of Angel Andres Videographys sUAS DJI Inspire1 and 3DR Solo in the aerial videography and television

industry pursuant to the Aerial Operations Guidelines stated and attached hereinto.

Sincerely,

Angel Andres Rosado

Owner Angel Andres Videography dba Colorado Aerial Video

angel@angelandres.com

References/Enclosures:

DJI Inspire1 Manufacturers Operating Manual web link:

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

3DR Solo Manufacturers Operation Manual web link:

http://3drobotics.com/wp-content/uploads/2015/08/v5_09_06_15.pdf

These are to be considered proprietary documents and are not to be published in the Federal Record:

Angel Andres Videography Aerial Operations Guideline