. ,- '" .- -~ ... ... • J 1: .... -:-· -: ,. ' .... October 15 2015 ,_._ ·-· ... , ....... · 

U. S. Department of Transportation Docket Management System 

1200 New Jersey Ave, 

SE Washington, DC 20590 

John Mario Restrepo is a Real Estate Agent 

Florida Real Estate Licensed Agent # SL3317268 

;·~~:: --~-- "'l -, !.. ... ,_; '-- "' - ~- ':'L _, • • :. t.:: 

Re: Section 333 Exemption Request Pursuant To Section 333 of thee FAA Reform Act of 

2012 

Dear Sir or Madam, 

Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 

C.P.R. Part 11, 

John M Restrepo, operator of Small Unmanned Aircraft Systems (sUAS) equipped to 

conduct aerial photography for the Real Estate advertising in controlled areas, hereby 

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

commercial operation of its sass, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the Federal I Aviation 

Administration (FAA) as required by §333. 

John M Restrepo current operation of sUASs for commercial purposes has been halted to 

comply with recently enacted d federal aviation regulations pertaining to sUAS. 

As described fuller y below, the requested exemption would permit the operation of 

small, Unmanned and relatively inexpensive multirotor Aircraft under controlled 

conditions in airspace that is 1) contained 2) predetermined 3) has on sitem safety 

personnel controlling access, and 4) would provide increased safety and enhancements to 

clients' business operations. 

The name and address of the applicant is: 

John M Restrepo 

Realtor license # SL3317268 

Address: 12244 triton Ln, Orlando Fl32837 

John M Restrepo Ph: + I (980-6215960) 

Email I: mariorealtor1@aol.com 

I, John Mario Restrepo, respectfully requests a grant of an exemption of the following 

sections of Title 14 of the Code of Federal Regulations: 14 CFR 21; 14 CFR 91, et seq.; 

·14 CFR 45.23 (b); 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 • 14 

CFR61.113 (a) & (b); 14 CFR407 (a)(l); 14 CFR409 (a)(2); • 14CFR417(a)&(b). 

I, John M Restrepo also respectfully requests an Exemption from Section 333 of the FAA 
Reform Act and Part 11 of the Federal Aviation Regulations from: 

14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.1 1 3 (a) & (b); 91.7 (a); 91.9(b)(2); 

91.103(b); 

• 91.109; 91.119; • 91.12 1 ; 91.151(a); 91.203(a) & (b); 91.405 (a); 

• 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

T he Extent of Relief John M Restrepo Seeks and the Reason It Seeks Such Relief: 

John M Restrepo submits this application in accordance with the Reform Act, 112 P .L. 

95§§331334,Seeking relief from any currently applicable federal aviation regulations 

PARs Pertaining to sUAS (unmanned aircraft systems) and operating to prevent John M 

Restrepo Contemplated commercial photography, videography and other flight 

operations within the U.S.national airspace system. 

The Reform Act in §332 provides for such integration of civil UASs into our national 

airspace system as it is in the public's interest to do so. John M Restrepo lightweight 

UASs meet the Definition of "small unmanned aircraft" as set forth in §331 and 

combined with a sterling safety Record in similar industries, John M Restrepo light duty 

sUAS are ideal recipients of exemption By the intent of the Reform Act. 

Considerations for relief include a combination of sUAS physical characteristics, safety 

features,And safe practices identified in §333: 

• sUAS weight, • sUAS overall size, • sUAS speed over ground, 

• sUAS flight zone characteristics, 

Non Operation near airports (civilian or military), tightly controlled operation in 

populated areas, 

John M Restrepo, Real Estate professional 

Florida Licensed 

Realtor #SL3317268 

The client. Specific consideration is outline below. 

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of201 2 

Operation of the UAS by VLOS by 

1 4 C.F.R. Part 2 1 , Subpart H: Airworthiness Certificates 14 C.F. R. §91.203 (a) ( 1) 

Subpart H, 

Entitled Airworthiness Certificates, establishes the procedural requirement s for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1 ). Given the size 

and limited Operating area associated sUAS, an exemption from Part 21 Subpart H meets 

the requirements Of an equivalent level of safety under Part 11 and §333 of the Reform A 

ct. ll1e Federal Aviation act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act both 

authorize the FAA to exempt Aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weigh, ht, speed, operational capability, and 

proximity to airports and populated areas of the Particular UAS. In all cases, an analysis 

of these criteria demonstrates that the UAS operated Without an airworthiness certificate, 

in the restricted environment and under the condition Proposed will be at least as safe, or 
safer, than a conventional aircraft (fixed wing or rotorcraft) Operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated by John M Restrepo is les s than 11 k g. with maximal payload 

Consisting of remote sensing instrumentation, carries neither no persons, carries no 

explosive or flammable materials including combustible l e fuels, and operates 

exclusively within a secured area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

Monitored by the pilot (P I C), whose role is designated to act as both the remote sensing 

Controller and secondary monitor for safety issues, and a technician, which assists in 

matters related to maintaining the sUAS and also monitors for safety concerns and 

liaisons to the on site safety officials. These enhancements to current safety practices and 

regulations, which already apply to civil aircraft, provide a greater degree of safety to the 

public and property owners than conventional aircraft operations conducted with 

airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H . Lastly, application 

of these same criteria demonstrates that there is no intrinsic credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack 

of intrinsic explosive materials or flammable liquid fuels, and inability to carry a 

substantial extern a 1 load. 

1 4 C.P.R. §45.23 (b). Marking of the Aircraft The regulation requires: 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 no more than 6 inches 

high, the words " limited ; ' "restricted;' "lights port;' "experimental ;' or "provisional;' as 

applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may be 

needed 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 sUAS, two inch 

lettering will be impossible. 

The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a 

size suitable for the available space. 

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

sUAV will see the identification ofthe UAS as "Experimental." The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 101 67 and 101 

67A. 

Further markings include the use of flashing green LED illumination on the underside of 

the sUAS frame which stands at contrast against a blue or white sky. 

Jobn M Restrepo, Real Estate Professional 

Florida Licensed Realtor #SL3317268 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

14 C.P.R. §6 1.11 3 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. §61.113 (a) & (b) limit private pilots to non commercial operations. Because 

'" 
the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring a ground crew member to 

have a private pilot's license rather than a commercial pilot's license to operate this sUAS. 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no persons on board. The area of operation is controlled and restricted, 

and all flights are planned and coordinated in advance . The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations as 

requested with a private pilot in the ground crew exceeds the present level of safety 

achieved by 14 C.P.R. §61.1 1 3 (a) & (b). 

1 4 C.P.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 

aircraft and the requirements contained in the Manual for maintenance and use of safety 

check lists prior to each flight, a subset of which are provided in enclosed Supplemental 

material, an equivalent level of safety will be provided. 

14 C.P.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. §91.9 (b) (2) 

provides: No person may operate a U.S. registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft F light Manual is not required by §21.5 of this chapter, unless the 

re is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability to carry a physical flight 

manual on the aircraft. The equivalent level of safety will be maintained by keeping the 

flight manual at the ground control point where the pilot flying the sUAS will have 

immediate access to it. The FAA has issued the following exemptions to 

this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10167, 

10167A, 10602,32827, and 10700. 

14 C.P.R. §9 1.10 3: Preflight action This regulation requires each PIC to take certain 

actions before flight to insure the safety of flight. As FAA approved rotorcraft flight 

manuals will not be provided for the aircraft an exemption will be needed. The PIC will 

take all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. Further, we 

have proprietary manuals created with the help of sUAS experts, the manufacturer, the 

regional sUAS vendor and policy holding insurer and continue to work with these 

organizations to ensure best safe practices are adhered to. 

14 C.P.R. §91.1 09: Flight instruction §91.1 03 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. sUAS and remotely piloted aircraft, by 

their design do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight instruction in experimental 

' 

..... 
aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by 

the fact that neither a pilot nor passengers will be carried in the aircraft and by the size 

and 

John Mario Restrepo, Real Estate Professional 

Florida Licensed Realtor #SL3317268 

Section 333 Exemption Petition 

Re: Exemption Request Pursuant To Section 333 ofthe FAA Refo rmAct of2012 

speed of the aircraft. Enhancing this safety is the technology inherent in the remote 

controls utilizing digital communications which is paired to the sUAS making it nearly 

impossible to unintentionally or intentionally have the control communications 

interrupted. 

1 4 C.F .R. §9 1.119 : Minimum safe altitudes §91.119 establishes safe altitudes for 

operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the 

minimum s prescribed, provided the person operating the helicopter complies with any 

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS 

that closely mimics the behavior of a helicopter,. and the exemption requests authority to 

operate at altitudes up to 400 AG L, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 AGL or 

beyond unaided visual line of sight, whichever is closer. It will however be operated in a 

restricted area with security officials tasked with ensuring public safety , and where 

buildings and people will not be exposed to operations without their preobtained consent 

and training. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the location where it is operated. No flight operation will be taken without the 

permission of the property owner in t he case of private property or local officials In the 

case of public property or private property with public interests. Because of the advance 

notice to the property owner and participants in the remote sensing activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighting far more than the maximum 11 kg of John M 

Restrepo sUAS proposed herein and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with 

conventional air craft operating at or below 500 AGL. In addition, the low altitude 

operations of the sUAS will ensure separation between these small UAS operations and 

the operations of conventional aircraft that must comply with §91.119. 

14 C.F. R. § 91. 1 21 Altimeter Settings §91.121 requires each person operating an 

aircraft to maintain cruising altitude e by reference to an altimeter that is set " ... to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude 

read out. An equivalent level of safety will be achieved by the operator, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. The operator 
will also ensure effective pairing with multiple GPS sources to guarantee accurate detec 

tion of height. 

14 C.F.R. §9 1.151 (a): Fuel Requirements for Flight in VFR Conditions §9 1.1 51 (a) 

prohibits an individual from beginning "a flight in an airplane under VFR conditions 

unless (considering wind an d forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cruising speed( 1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at 1 east 45 

minutes:' The battery powering the sUAS provides approximately 15 minutes of powered 

flight in hover mode without payload. John Mario Restrepo sUAS will not be able to 

meet the 30 minute reserve requirement in 14 CPR §9 1.15 1. Operating the small UAS, 

in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed , with less than 30 minutes of 

reserve power, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. John Mario Restrepo believes that 

an equivalent level of safety can be achieved by limiting flights to » 1 0 minutes or less 

that 50% of battery power whichever happens first. This restriction would be more than 

adequate to return the sUAS to it's planned landing zone from anywhere in its limited 

operating area . Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673 , and 10808 

John Mario Restrepo, Real Estate Agent 

Realtor# SL3317268 

Section 333 Exemption Petition 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act o/2012 

1 4 C.P.R. §9 1. 2 0 3 (a) & (b): Carrying Civil Air craft Certification and Registration 

The regulation provides in pertinent part: 

(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 dispiayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

The sUAS fully loaded weighs no more than llkg and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents 

or to display them on the sUAS . An equivalent level of safety will be achieved by 

keeping these documents at the ground control point where the pilot flying the sUAS will 

have immediate access to them, to the extent they are applicable to the sUAS. The FAA 

has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 

9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

1 4 C.P.R. §9 1. 405 (a); 4 0 7 (a) ( 1 ); 4 0 9 (a) (2); 4 1 7(a) & (b): Maintenance 

Inspections These regulations require that an aircraft operator or owner "shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 
repaired as prescribed in part 43 of this chapter ... ;'and others shall inspector maintain 

the aircraft in compliance with Part 43 . Given that these section and Part 43 apply only 

to aircraft with an airworthiness certificate, these sections will not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight manual. An 

equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for 

limited periods oftime. If mechanical issues arise the UAS can land immediately and will 

be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is 

in working order prior to initiating flight, perform required maintenance, and keep a log 

of any maintenance performed. Moreover, the operator is the person most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition to provide 

the equivalent level of safety. 

An exemption granted to John M Restrepo would permit its operation of lightweight, 

unmanned, remotely controlled, sUAS in a tightly controlled environment with limited 

airspace. John M Restrepo, utilizes local business' safety officers in specifically 

determined areas (designed flight zone) to mitigate injury and property damage while 

fulfilling clients' goals. Technical enhancements to current safety controls will allow 

John M Restrepo, to operate exceeding current safety specifications, and stay ahead of, or 

meet, new ones being implemented by the FAA and Department of Transportation. 

Further, John M Restrepo conducts its operations in compliance with protocols described 

here in or as otherwise established by the FAA. 

II. Commercial and Public Benefits; 

I John M Restrepo, believe that granting this exemption request furthers the 

public interest by providing safe (by way of an unmanned system) and efficient 

means to John M Restrepo client base are typically small to medium sized 

business' looking to increase their awareness of respective properties. Aerial 

videography and photography for real estate marketing has been around for a 

long time through manned fixed wing aircraft and helicopters, but for small 

business owners and homeowners its expense has been cost prohibitive. 

Granting this exemption to the petitioner would allow him to provide this 

service at a much lower cost. Further, the petitioner indicates his small UAS 

will pose no threat to the public given its small size and lack of combustible fuel 

when compared to larger manned aircraft. The petitioner also states that the 

operation of his UAS will minimize ecological damage and promote economic 

growth by providing information to small businesses and individuals looking to 

relocate or build in the Orlando Florida area. 

John Mario Restrepo 

, Florida Licensed realtor 

# SL3270953 

Section 333 Exemption Petition 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 
By photographic or videography. By moving these functions ol).to sUAS based air craft, 

the potential for loss of life or property is diminished due to the greater control in a 

smaller and safer aircraft that holds no persons. Second, there are no reactive or 

combustible materials on board the sUAS and thus the potential for fire or explosions is 

greatly diminished. Third , the small size and extreme maneuverability of John M 

Restrepo UASs allow the PIC to avoid hazards. Accordingly, John M Restrepo UASs 

have operated and will continue to operate at and above current safety levels. 

A . The costs and benefits of your proposed action to society in general and specific 

groups within society as described above, John M Restrepo past customers have been 

small to medium business seeking Aerial videography for geographical awareness and for 

real estate marketing lias been around for a long time through manned fixed wing aircraft 

and helicopters. For small budget real estate companies and average homeowners the 

expense of such aerial videography is cost prohibitive. Only large companies and high 

end Realtors or luxury homeowners can afford to absorb such expense. Depriving 

nonluxury homeowners and lower budget Realtors from a valuable marketing tool. 

Manned aircraft pose a threat to the public through potential catastrophic rash that the 

various communities have experienced in the past with military aircraft and medical 

helicopter crashes within a even cities. Each resulting in loss of life, each with 

combustible fuel that exploded and burned on impact. 

My, John M Restrepo, UAS pose no such threat since size and lack of combustible fuel 

alleviates any potential threat to the public. 

Congress has already proclaimed that it is in the public's interest to integrate 

commercially flown UAS's into the national airspace system, hence the passing of the 

Reform Act. Granting my, John M Restrepo's, exemption request furthers the public 

interest through academic/visual awareness of the geographical benefits in and around the 

NW Florida area. My ultra light weight UAS is battery powered and creates no emissions 

that can harm the environment. The consequence of my ultra light weight UAS crashing 

is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain 

combustible fuel and can cause catastrophic devastation to the public.· 

Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the 

need for an on board pilot, time consuming adherence to regulations surrounding 

bookkeeping and submission of flight paths to local civilian or military airports, and 

detrimental effects to the environment caused by operating a combustible fuel based, 

large scale aircraft, with restrictions on the proximity to the target for remote sensing. 

F 1 i g h t Capabilities and Characteristics of John M Restrepo UAS s Pursuant to 112 

P.L. 95§333 (a), concerns for public safety are mitigated by the overall capabilities and 

characteristics of the sUAS. John M Restrepo UAS s utilizes four (4) rotating 9 inch 

plastic propellers paired oppositely to each other for balance, control and stability. The 

total span of the sUAS is less than ""'1.2 m allowing for stable flight or landing even with 

the sudden onset of detrimental environmental conditions. The sUAS's have a maximal 

unit+ payload mass of 11kg,including cinematic/photographic or other surveying 
equipment. John M Restrepo sUAS is designed to primarily hover in place to capture 

photographic data and then operate at less than a 35 knot maximum speed to the next 

point of interest. They are capable of vertical and horizontal operations but, in practice, is 

operated only within VLOS by the PIC. In addition the PIC, 

John Mario Restrepo is a, Florida Licensed Realtor 

Realtor license # SL3270953 

Section 333 Exemption Petition 

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 

off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In 

the event ofloss of visual of the UAS, the PIC can change flight controls from cartesian 

(X,Y,Z) based controls to radial (r, a ,h) based controls which allows the PIC to utilize 

one controller axis to recall the UAS to the PIC's position without concern to the current 

heading of the sUAS. In the event ofloss of sight of the sUAS into an area containing 

hazards or possible hazards, the spotter has a heads up display containing a live video 

feed which can be used to locate the UAS while it maintains it's position in hover mode. 

The sUAS has demonstrated it's ability to maintain it's position by GPS coordinates in 

hover mode in 25 kts or greater wind gusts at rvr less than 25 feet representing an 

extreme environmental condition beyond the range of conditions within the scope for 

sUAS operation. 

All of John M Restrepo sUASs utilize LiPo (lithium polymer) battery based power 

sources, decreasing safety risks from more easily combustible, fuel based, power sources. 

Flight times generally last between eight (8) to ten (1 0) minutes allowing the staff to 

work with small flight areas per phase. The maximum flight time without payload is 25 

minutes, however practical safe operation limits this to 10 to give ample time to control 

the sUAS to a safe landing zone. John M Restrepo further restricts flight time by not 

operating its sUASs with less than twenty five percent battery capacity. Further safety 

management systems in place include a GPS mode that allows John M Restrepo's sUAS 

to hover in place if communication with the PIC is lost and optionally follow a set of 

waypoints at a set speed and height to a 'home base' predesignated safe landing zone. In 

the event of UNforese-en motor(s) failure, the system will enter into a controlled descent 

while allowing full use of all UAS flight controls by the PIC. All commands sent via 

remote controller received during a controlled descent are translated to an 'as meant' 

paradigm meaning the flight control package wiJl use it's real time 3 dimensional position 

and compensate rotors control the sUAS regardless of spin velocity. 

This assures that if one system is compensated a safe and successful landing can still 

occur. 

I V. Reasons Why an Exemption to John Mario Restrepo Will Not Adversely 

Affect SafetyStandards 

John M Restrepo contends that operation of it's sUASs will not "create a hazard to users 

of the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the 

diminutive size and weight of John M Restrepo sUASs, combined with their operation 
in cordoned off and well controlled areas, John M Restrepo sUAS falls within 

Congress's contemplated safety zone. 

John M Restrepo s UASs have an established safety record bolstered by multipoint 

Preflight check list, awareness of their surroundings and intimate knowledge of the 

behavior of the sUAS platform in many weather conditions. This safety record and 

implemented operational practices demonstrate an awareness of public safety. John M 

Restrepo' s operations routinely provide a level of safety at least equal to existing rules, 

and in nearly every instance, exceeds existing rules. 

John M Restrepo has worked very closely with the regional vendors and support for this 

unit to create a tightly integrated and highly tolerant platform that has been tested 

thoroughly by a vendor with a proven record for safety and solid designs. 

John M Restrepo also continues to work closely with organization to identify and 

mitigate sUAS platform risk due to their expertise in several industries closely related to 

the aviation and transportation. John M Restrepo does not operate its UASs on or near 

airports and generally has only operated its sUAS on private grounds with cordoned off 

areas or areas under the control of the property owner I client with assistance by safety 

officials. John M Restrepo determines the areas needed to fulfill the clients ' goals and 

only operates its UASs in these flight zones and only in compliance with well regarded 

safety protocols set forth initially by the RC UAS trade and hobby groups. 

John M Restrepo, Florida Licensed Realtor. 

Realtor # SL3270953 

Section 333 Exemption Petition 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform A ct of 20 12 John M 

Restrepo standardized on the following practices to ensure safe operation of it's UASs: 

• Work with onsite personnel to plan the flight goals, • Work with onsite personnel to 

restrict access to non essential persons, • Operation by unaided VLOS operation only, 

• Operation in phases 10 minutes in length 

• Operation to minimal 25% battery power 

• Operation of device to GPS aided readout to 300 ft at maximum, Numerous 

pre programmed fail safes that ensure specific behavior per issue 

• Perform a site check day(s) before flight to identify potential issues, Subscribe to 

relevant local weather and safety alerts, 

• Expertly choose data collection instruments and accessories to minimize flight 

requirements or expertise, 

• John M Restrepo has experience in similar fields and has adapted this experience in it's 

use ofUASs to increase safety. In combination to the ever expanding knowledge 

repositories from hobbyist s and experts alike, John M Restrepo is constantly evolving it's 

practice s when there is a clear benefit to operations or increased safety element. 

A. 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: 

John Mario Restrepo {applicant) seeks an exemption from the following rules : 1 4 

C.P.R. §2 1, subpart 

H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 

91.109; 

91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (a) (2); 

91.409 (a) 

{2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (11 kg or 

less) in elevated photographic and remote sensing operations. 

Approval of exemptions allowing commercial operation s of sUASs in the media 

industry will enhance safety by reducing risk associated with conventional aircraft 

operations and other means of elevated remote sensing involving persons. The public 

benefit served by approval of this petition is increased awareness of characteristics of 

difficult imaging targets. A sUAS weighing fewer than 11 kg and powered by sealed 

batteries eliminates virtually all associated risk inherent in operating conventional aircraft 

in close proximity to buildings or persons or otherwise elevating persons to a position 

they would be able to collect needed data. 

The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide 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. 

John Mario Restrepo 

Real Estate Professional. 

Realtor License # SL 3 31 7268 

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 

As identified and described herein, John Mario Restrepo , also experienced in flying 

Unmanned Aircraft Systems(U.A.S) for recreational purposes. 

Recognized by the community as a professional realtor. 

The FAA has been given the authority t o issue the exemption to John Mario Restrepo 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek 

your consideration and approval of this petition. 

encl: Supplement A: Physica 1 characteristics ofUAS encl: Supplement B: Flight 

Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: 

Flight maps in John M Restrepo's regional base. 

VI. 

Supplement B: Summary Sections of Flight Operations and Procedure Manual (FOPM) 

• All regular and irregular operations are noted with timestamps, relevant UAS metrics 

and corrective action procedures (CAP) that are performed. Note: 

All irregular behavior have root cause analysis performed before UAS operation is 

resumed. 
Emergency Procedures • Loss of Remote Signal the flight package features an 

optional enhanced failsafe which returns the sUAS to the home base waypoint via the 

same path taken to point of lost signal. 

The UAS will then perform a hover over this waypoint and then a controlled landing. 

• Loss of GPS signal The system will operate in GPS assisted mode with three (3) 

satellites. At loss of three (3) GPS satellites, manual mode can be activated or the flight 

package can be programmed to perform a controlled landing to the home base waypoint. 

Ground based height ranging is performed by a separate system and so loss of GPS will 

not impact controlled landing in a safe manner. • Loss of Engine Power 

. In the event of one (1) (or to two oppositely positioned) rotor or motor failure the 

system will enter into controlled spin where all controls are translated based on current 

orientation and will behave as normal operation to the PIC to ensure a safe landing, 

In the event of multiple rotor or motor failures the flight package can be configured to 

perform a safe landing or attempt operation to home base waypoint. 

Note: Behavior of the landing location is highly dependent on the position and number 

of rotors/motors that are affected. 

• Loss of Ground Control Software This will not affect operation of the flight. The unit 

will be Piloted to a safe landing area and then landed so that examination of the link can 

be made. 

TYPHOON QSOO 4K 

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