Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation

Regulations	from	14	C.F.R.	45.23(b);	14	C.F.R.	Part	21;	14	C.F.R.	61.113(a)&(b); 91.7(a);	91.9(b)	(2);	91.103(b);	91.109;	119.121;	91.151(a);	91.203(a)&(b); 91.405(a);	91.407(a)	(1 );	91.409(a)	(2);	91.417(a)&(b)

Dear	Sir	or	Madam,

I,	Corey	Molina,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of 2012	and	the	procedures	contained	within	14	C.F.R.	11,	to	request	that	I,	Corey Molina,	an	owner	and	operator	of	small	unma nned	aircraft,	be	exempted	from	the Federal	Aviation	Regulations	(“FARs”)	listed	below	so	that	I,	Corey	Molina,	may operate	my	small	ultra	light	weight	unmanned	aircraft	system	(“UAS”)	commercially in	airspace	regulated	by	the	Federal	Aviation	Administrati on	(“FAA”). As	described	herein	I,	Corey	Molina,	am	a	fulltime	filmmaker	based	out	of	California; experienced	in	flying	hobby	helicopters	for	recreational	purposes.	I	am	also	a current	private	pilot	with	over	250	hours	of	flight	in	fixed	wing	single	engine aircraft.	I	have	added	a	Dji	Inspire	1	UAS	to	my	inventory	with	intent	for	aerial videography/cinematography	to	enhance	our	corporate	video	productions	along with	ambitions	to	film	aerial	real	estate	listing	videos;	following	exemption	and approval	by	the FAA.	I also	have	an	additional	UAS

, Tayzu	Robotics	Titan	X8 ,	which
has comparable	safety	capabilities.

I	have	flown	small	RC	electric	helicopters	for	over	five	(5 )	years	without	incident. Committed	to	safety	with	each	flight.	My,	Corey	Molina's,	exemptio n	request	would permit	operation	of	ultra	light	weight,	unmanned	(piloted	by	remote	control)	and comparatively	inexpensive	UAS(s)	in	tightly	controlled	and	limited	airspace. Being	a private	pilot	I	am	able	to	determine	the	airspace	that	I	am	operating	in	a nd	can effectively	avoid	violating	controlled	airspace	along	with	other	hazard	areas.

For	the	reasons	stated	below	I,	Corey	Molina,	respectfully	request	the	grant	of	an exemption	allowing	me	to	operate	ultra	light	weight,	remote	controlled	UAS’s	for

corp orate	and real	estate	listing	videos	for clients who	cannot	afford	expensive manned	aircraft	for	the	same	purpose.	Both	of	which	will	promote	local	economic growth	through	increased	employment	and	increased	tax	base.

I.	Contact	Information: Corey	Cruz	Mo lina
7451	Dallas	Dr. La	Palma,	CA	90623
Email: corey@safetysourceproduction.com

II.	The	Specific	Sections	of	Title	14	of	the	Code	of	Federal	Regulations	From	Which Corey	Molina	Requests	Exemption	are : 14	CFR	21; 14	C.F.R.	45.23(b); 14	CFR	61.113	(a)	&	(b);	14	C.F.R.	91,	et	seq.;14	CFR	407	(a)	(1);

14	CFR	409	(a)	(2);	and,	14	CFR	417	(a)	&	(b). 4	Appendix	D

- Personal	Protocols	and	Controls

III.	The	Extent	of	relief	Corey	Molina	seeks	and	the	Reason He	Seeks	Such	Relief: I,	Corey	Molina,	submit	this	application	in	accordance	with	the	Reform	Act,	112	P.L. 95	§§	331

- 334,	seeking	relief	from	any	currently	applicable	FARs	operating	to prevent	me,	Corey	Molina,	contemplated	commercial	cinematic,	academic	a nd	other flight	operations	within	the	national	airspace	system.	The	Reform	Act	in	Section	332 provides	for	such	integration	of	civil	unmanned	aircraft	systems	into	our	national airspace	system	as	it	is	in	the	public’s	interest	to	do	so.	My,	Corey	Molina’s, ultra light	weight	UAS	meets	the	definition	of	“small	unmanned	aircraft”	as	defined	in Section	331	and	therefore	the	integration	of	my	ultra	light	weight	UAS	is	expressly contemplated	by	the	Reform	Act.	I	would	like	to	operate	my	ultra	light	weight	UAS

prior	to	the	time	period	by	which	the	Reform	Act	requires	the	FAA	to	promulgate rules	governing	such	craft.	Thereby,	providing	direct	experience	and	valuable information	for	formal	regulation	that	can	be	administered	uniformly	to	all	related
UAS	aerial	video and	photography.	The	Reform	Act	guides	the	Secretary	in determining	the	types	of	UAS's	that	may	operate	safely	in	our	national	airspace system.	Considerations	include:	The	weight,	size,	speed	and	overall	capabilities	of the	UAS's;	Whether	the	UAS	will	be operated	near	airports	or	heavily	populated areas;	and,	Whether	the	UAS	will	be	operated	by	line	of	sight.	112	P.L.	95	§	333	(a). Each	of	these	items	reflect	in	favor	of	an	exemption	for	me,	Corey	Molina.	My	UAS utilizes	four	(4)	counter

- rotating	propellers	for	balance,	control	and	stability.	My UAS	is	equipped	with	GPS	and	auto	return	safety	techn ology.	Weighing	less	than	the
maximum	55

- pound	limit;	including	camera	with	gimbal. I,	Corey	Molina, consider safety	foremost	with	each	flight.	My	small	unmanned aircraft	is	designed	to	hover	in	place	via	G PS. Built	in	safety	systems	include	a	GPS mode	that	allows	my	UAS	to	hover	in	place	when	radio	controls	are	released.	When pilot	communication	is	lost	UAS	is	designed	slowly	descend	to	point	of	take	off.	I	do

not operate	my	UAS	near	airports,	Hospitals	nor	Police	heliports,	and	do	not	operate near	areas	where	general	public	is	within	fifty	to	one	hundred	(50

- 100)	yards depending	on	location,	conditions	and	weather.	I	am	constantly	on	alert	for	any
manned	aircraft (Police/Medical	helicopters,	etc.)	and	prepared	to	land/abort immediately	to	the	nearest	and	safest	ground	point	should	a	manned	aircraft approach	my	location	or	I	suspect	manned	aircraft	may	approach	near	my	location. My	UAS	is	capable	of	vertical	and	horizontal	operations,	and	are	flown	only	within my	line	of	sight	of	me,	as	the	remote	control	pilot.	Utilizing	battery	power	rather than	combustible	fuels,	flights	generally	last	between ten	(10 )	to twenty	(20 ) minutes,	with	an	altitude	under four hundred	( 4 00 )	feet.

I	do	not	operate	my	UAS	at	or	below	manufacture	recommend	minimum	charge levels	for	operation;	preferring	to	remain	well	within	a	safe	operating	range	to insure	adequate	communication	between	radio	control	and	UAS	to	eliminate potential	for	cra sh,	loss	of	control	or	hazard.	Reserve	batteries	are	at	hand	with	each exercise	to	insure	replacement	for	sufficient	safe	level	of	operation.	I	do	not	believein	taking	risks that	may	cause an incident	that co uld	create	hazard	to	the	public,

property	and m anned aircraft.	I	have	clocked	numerous	practice	flights	in	remote areas	as	a	hobbyist	simulating	flights	for	future	commercial	use	to	gain familiarization	with	the	characteristics	of	this	specific	UAS's	performance	under different	temperature	and	weather conditions.	I	also	practice	computerized simulated	flights	to	maintain	adequate	ski lls	and	response	reflex	time,	al l	for	the sake	of	safety.

I,	Corey	Molina’s,	am	extremely	cautious	when	operating	of	my	UAS/ultra	light weight	unmanned	aircraft	and	will	no t	“create	a	hazard	to	users	of	the	national airspace	system	or	the	public.”	112	P.L.	95	§	333	(b).	Given	the	small	size	and	weight of	my	UAS	it	falls	well	within	Congress’s	contemplated	safety	zone	when	it promulgated	the	Reform	Act	and	the	corresponding	d irective	to	integrate	UAS's	into the	national	airspace	system.	Corey	Molina’s	UAS,	used	in	hobby	flight,	has	a demonstrable	safety	record	and	does	not	pose	any	threat	to	the	general	public	or national	security.

IV.	How	Corey	Molina’s	Request	Will	Benefit the	Public	As	A	Whole: Aerial	videography	for	geographical	awareness	and	for	real	estate	marketing	has been	around	for	a	long	time	through	manned	fixed	wing	aircraft	and	helicopters.	For companies	and	clients	on	a	budget aerial	videography was cost	prohibitive.	Only large	companies	and	high budgets or	luxury	homeowners	can	afford	to	absorb	such expense.	Depriving everyone	else	of	a valuable	marketing	tool.	Manned	aircraft	pose a	threat	to	the	public	through	potential	catastrophic	crash	and	with	fuel	on	boar d the	potential	for	loss	is	much	greater

. My,	Corey	Molina's,	UAS	pose	no	such	threat since	size	and	lack	of	combustible	fuel	alleviates	any	potential	threat	to	the	public. My	ultra lightweight 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.

Permitting	me,	Corey	Mol ina,	to	immediately	fly	within	national	air	space	furthers economic	growth.	Granting	my	exemption	request	substantial ly	furthers	the economic	impact for	companies	looking	to	relocate	or	build	in California as	well	as individuals	looking	to	relocate	for	car eer	advancement	through	academic	and geographical	awareness.	Both	of	which	serve	as	a	stimulus	to	the	community.

V.	Reasons	Why	Corey	Molina’s	Exemption	Will	Not	Adversely	Affect	Safety	Or	How The	Exemption	Will	Provide	a	Level	of	Safety	At	Least	Equal	To Existing	Rule: My,	Corey	Molina’s,	exemption	will	not	adversely	affect	safety.	Quite	the	contrary, for	the	reasons	stated	permitting	me,	Corey	Molina,	to	log	more	flight	time	in	FAA controlled	airspace,	with communication	with	the	FAA	if	needed. In	additi on	I,	Corey Molina,	submit	the	following	representations	of	enhancements	to	current	aerial videography	and	photography	for	real	estate: My	UAS	weighs	less	than	5 5	pound	weight	limit. I	only	operate	my	UAS	below 400	feet.I	land	my	UAS	prior	to	manufacture r	recommended minimum	level	of	battery

power. I	pilot	my	UAS	through	remote	control	only	by	line	of	sight. My	UAS	has	GPS	a	flight	safety	feature	whereby	it	hovers	and	then	slowly	lands	if communication	with	the	remote	control	pilot	is	lost; I	actively	analyze	flight	data	and	other	sources	of	information	to	constantly	update and	enhance	safety	protocols; I	only	operate	in	reasonably	safe	environment	that	are	strictly	controlled,	are	away from	power	lines,	elevated	lights,	airports	and	actively	populated	are as; I	conduct	extensive	pre

- flight	inspections	and	protocol,	during	which	sa fety	carries primary	importance.

My,	Corey	Molina’s,	safety	protocols	provide	a	level	of	safety	equal	to	or	exceeding existing	rules.	It	is	important	to	note	that	absent	the	inte gration	of	commercial	UAS into	our	national	airspace	system,	helicopters	are	the	primary	means	of	aerial	video and	photography	for	community	awareness	and	real	estate.	While	the	safety	record of	such	helicopters	is	remarkably	astounding,	there	has	been	inc idents involving loss	of	life	as	well	as	extensive	property	damage;	it	is	far	safer	to	operate	a	battery powered	ultra	light	weight	UAS.

First,	the	potential	loss	of	life	is	diminished	because	UAS's	carry	no	peo ple	on	board and	I	only	operate my	UAS	in	sp ecific	areas	away	from	mass	populations.	Second, there	is	no	fuel	on	board	a	UAS	and	thus	the	potential	for	fire	or	explosions	is	greatly
diminished. Third,	the	small	size	and	extreme	maneuverability	of	my	UAS	allow	me to	remotely	pilot	away	from	and	avoid hazards	quickly	and	safely. Lastly,	given	its small	size	and	weight,	even	when	close	enough	to	capture	amazing	images,	my	UAS need	not	be	so	close	to	the	objects	they	are	focused	on	through	the	technology	and use	of	post	editing	software	allowing	pan	and zoom. Accordingly,	my	UAS	has	been experimentally	operated	for	familiarization/competency	and	will	continue	to operate	at	and	above	current	safety	levels.

VI.	A	Summary	The	FAA	May	Publish	in	the	Federal	Register:
A.	14	C.F.R.	21	and	14	C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	The	Like. 14	C.F.R.	21,	Subpart	H,	entitled	Airworthiness	Certificates,	sets	forth	requirements for	procurement	of	necessary	airworthiness	certificates	in	relation	to	FAR	§ 91.203(a)(1).	The	size,	weight	and	enclosed	operational	area	of	my,	Corey	Molina’s, UAS	permits	exemption	from	Part	21	because	my	UAS	meets	(and	exceeds)	an equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform	Act.	The	FAA	is authorized	to	exempt	aircraft	from	the	airworthiness	certificate	req uirement	under both	the	Act	(49	U.S.C.	§	44701	(f))	and	Section	333	of	the	Reform	Act.	Both	pieces	of legislation	permit	the	FAA	to	exempt	UAS's	from	the	airworthiness	certificate requirement	in	consideration	of	the	weight,	size,	speed,	maneuverability	and proximity	to	areas	such	as	airports	and	dense	populations.	My,	Corey	Molina’s, current	and	projected	UAS's	meet	or	exceed	each	of	the	elements.14	C.F.R.	91.7(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness

certificate.	As	no	such	certi ficate	will	be	applicable	in	the	form	contemplated	by	the FARs,	this	Regulation	is	inapplicable. 14	C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are no	on	board	pilots	or	passengers,	and	given	the	size	of	the	UAS's,	th is	Regulation	is inapplicable.	An	equivalent	level	of	safety	will	be	achieved	by	maintaining	a safety/flight	manual	delineating	areas	of	where	safety	can	be	defined.

The	FAA	has	previously	issued	exemptions	to	this	regulation	in	Exemption	Nos. 8607,	8737, 8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	10700	and

32827. 14	C.F.R.	§	91.121	regarding	altimeter	settings	is	inapplicable	insofar	as	my	UAS utilizes	electronic	global	positioning	systems	with	a	barometric	sensor. 14	C.F.R.	§	91.203	(a)	and	(b )	provides	for	the	carrying	of	civil	aircraft	certifications and	registrations.	They	are	inapplicable	for	the	same	reasons	described	above.	The equivalent	level	of	safety	will	be	achieved	by	maintaining	any	such	required certifications	and	registrations	by me,	Corey	Molina. 14	C.F.R.	§	45.23:	Marking	of	The	Aircraft. Applicable	Codes	of	Federal	Regulation	require	aircraft	to	be	marked	according	to certain	specifications.	My	UAS	are,	by	definition,	unmanned.	They	therefore	do	not have	a	cabin,	cockpit	or	pil ot	station	on	which	to	mark	certain	words	or	phrases. Further,	two

- inch	lettering	is	difficult	to	place	on	such	small	aircraft	with dimensions	smaller	that	minimal	lettering	requirement.	Regardless,	I	will	mark	its UASs	in	the	largest	possible	lettering	by placing	the	word	“EXPERIMENTAL”	on	its fuselage	as	required	by	14	C.F.R.	§45.29	(f)	so	that	I	the	pilot,	or	anyone	assisting	me as	a	spotter	with	the	UAV	will	see	the	markings.	The	FAA	has	previously	issued exemptions	to	this	regulation	through	Exemptions Nos.	8738,	10167,	10167A	and

10700. 14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC. Pursuant	to	14	C.F.R.	§§	61.113	(a)	&	(b),	private	pilots	are	limited	to	non

commercial	operations.	I,	Corey	Molina,	can	achieve	an	equivalent	level	of safety	as achieved	by	current	Regulations	because	my	UAS	does	not	carry	any	pilots	or passengers.	Further,	while	helpful,	a	pilot	license	will	not	ensure	remote	control piloting	skills.	The	risks	attended	to	the	operation	of	my	UAS	is	far	less	than	the	ris k levels	inherent	in	the	commercial	activities	outlined	in	14	C.F.R.	§	61,	et	seq.	Thus, allowing	me,	Corey	Molina,	to	operate	my	UAS	meet	and	exceed	current	safety	levels in	relation	to	14	C.F.R.	§61.113	(a)	&	(b).
14	C.F.R.	91.119:	Minimum	Safe	Altitudes

. 14	C.F.R.	§	91.119	prescribes	safe	altitudes	for	the	operation	of	civil	aircraft.	It allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.	My	UAS will	never	operate	at	an	altitude	greater	than 400 AGL.	I,	Corey	Molina,	will	however operate	my	UAS	in	safe	areas	away	from	public	and	traffic,	providing	a	level	of	safety at	least	equivalent	to	or	below	those	in	relation	to	minimum	safe	altitudes.	Given	the size,	weight,	maneuverability	and	speed	of	my	UAS,	an	equivalent	or	higher	level	o f safety	will	be	achieved. 14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections.C.

D.

E.10	Appendix	E

- Safety/Flight	Manual

The	above

- cited	Regulations	require,	amongst	other	things,	aircraft	owners	and operators	to	“h ave	[the]	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.	.	.	.” These	Regulations only	apply	to	aircraft	with	an	airworthiness	certificate.	They	will not,	therefore,	apply	to	my,	Corey	Molina's,	UAS.	However,	as	a	safety	precaution	I inspect	my	UAS	before	and	after	each	flight. A	Summary	The	FAA	May	Publish	in	the	Federal	Register:	A. 14	C.F.R.	21	and	14 C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	The	Like.	14	C.F.R.	21,	Subpart	H, entitled	Airworthiness	Certificates,	sets	forth	requirements	for	procurement	of necessary	airworthiness	certificates	in	relation	to	FAR	§	91.203(a)(1) .	The	size, weight	and	enclosed	operational	area	of	my	UAS	permits	exemption	from	Part	21 because	my,	Corey	Molina’s,	UAS	meets	an	equivalent	level	of	safety	pursuant	to Section	333	of	the	Reform	Act.	The	FAA	is	authorized	to	exempt	aircraft	from	the

airwo rthiness	certificate	requirement	under	both	the	Act	(49	U.S.C.	§	44701	(f))	and Section	333	of	the	Reform	Act.	Both	pieces	of	legislation	permit	the	FAA	to	exempt UAS's	from	the	airworthiness	certificate	requirement	in	consideration	of	the	weight, size,	sp eed,	maneuverability	and	proximity	to	areas	such	as	airports	and	dense populations.	My	UAS	meets	or	exceeds	each	of	the	elements.	14	C.F.R.	91.7(a) prohibits	the	operation	of	an	aircraft	without	an	airworthiness	certificate.	As	no
such	certificate	will	be applicable	in	the	form	contemplated	by	the	FARs,	this Regulation	is	inapplicable.	14	C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual in	the	aircraft.	As	there	are	no	pilots	or	passengers,	and	given	the	size	of	the	UAS's, this	Regulation	is	inappli cable.	An	equivalent	level	of	safety	will	be	achieved	by maintaining	a	manual.	The	FAA	has	previously	issued	exemptions	to	this	regulation in	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	9565B,	10167, maintenance	program	that	involves	regular	softwa re	updates	and	curative measures	for	any	damaged	hardware.	Therefore,	an	equivalent	level	of	safety	will	be
achieved. In	summary,	Corey	Molina	seeks	an	exemption	from	the	following	Regulations: 14	C.F.R.	21,	subpart	H;	14	C.F.R.	45.23(b);	14	C.F.R.	§§	61.1 13	(a)	&	(b);	14	C.F.R.	§ 91.7	(a);	14	C.F.R.	§	91.9	(b)(2);	14	C.F.R.	§	91.103(b);	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)	and	(b);	14 C.F.R.	§	91.405	(a);	14	C.F.R.	§	91.407	(a)(1);	14	C.F .R.	§	91.409	(a)(2);	14	C.F.R.	§ 91.409	(a	)	(2);	and,	14	C.F.R.	§§	91.417	(a)	&	(b)	to	commercially	operate	my,	Corey Molina's,	small	unmanned	vehicle/lightweight	unmanned	aircraft	vehicle	in community	awareness ,	corporate	video and	real	estate	operations ,	and	to	develop economic	platforms	for	real	estate	to	enhance	th e	experience	of	those	seeking	an affordable	aerial	imaging	solution .	Currently,	area	awareness	and	real	estate	aerial videography/photography	relies	primarily	on	the	use	of	larger	aircraft	ru nning	on combustible	fuel.	Posing	potential	risk	to	the	public.	Granting	my,	Corey	Molina’s,request	for	exemption	will	reduce	current	risk	levels	and	thereby	enhance	safety.

My	UAS	craft	do	not	contain	potentially explosive	fuel,	is	smaller,	lighter	and	m ore maneuverable	than	conventional	real	estate	video	and	photographic	aircraft	with much	less	flight	time.	Further,	I	operate	at	lower	altitudes minimizing	potential public	risk.	I,	Corey	Molina,	have	been	informally	analyzing	flight	information	and
will	c ompile	safety	protocols	and	the	implementation	of	a	flight	operations	manual for	real	estate	usage	that	exceeds	currently	accepted	means	and	methods	for	safe flight.	There	are	no	personnel	on	board	my,	Corey	Molina’s,	UAS	and	therefore	the
likelihood	of	de ath	or	serious	bodily	injury	is	significantly	diminished.	Accordingly	I, Corey	Molina,	respectfully	request	that	the FAA	grant	my	exemption.

Respectfully	submitted,

Corey Cruz Molina