A lbert R ivera

Ag

- View

5721 N. Wheeler Ave. Fresno, CA 93722

559

- 374

- 7916 rivera_albert@comcast.net

June 24 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Feder al 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,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C .F.R. Part 11, I, A lbert Rivera , an owner and operator of 2 Small Unmanned Aircraft Systems “( UAS”) equipped to con duct aerial photos and videos in the Fresno county area to help farmers

scout & survey their fields, monito r & manage water usage. I also intend to use the UAS for insurance claim & inspection purpose

.

I hereby am app lying for an exemption f rom the listed Federal Aviation Regulations (“FARs”) to al low commercial operation of my UASs, so long as such operation s are conducted within and under the

conditio ns outlined herein or as may be established by the FAA as required by Section 333.

I, Albert Rivera , am a commercial insurance agent in Fowler CA

, and I speci alize in Ag

- Business

Insurance . I have been a licensed Commercial agent since 1995. I have been flying r adio control airplanes & helicopt ers for over 20 years for recreational purposes

.

I have purchased a Phantom Vision 2 plus & a Phantom 3 Professional drone with the intent of utilizing

these UAS ’s for assisting our farmi ng customers in various ways. F irst to help with scouting and to

survey their crops & f

ields. The images taken by the UAS helps them identify troubled areas of the crops with greater accuracy & speed . I only intend to f ly the UAS ’s on these pr ivate farms with owner’s written

consent. Another benefit from this technology is with the handling of insurance claims. A great deal of our Ag customers turn in crop damage claims & with the use of the UAV I can obtain detailed aerial images of the damaged crops & forward them to the claims adjuster & speed up the claims process for the

customer.

Granting this exemption would allow me to provide this much needed service to our local farmers. M y small U AS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft . This would greatly reduce the use of mann ed aircrafts for farming operations that require a greater expense , & reduce the safety risk i n volved of manned aircraft

.

I plan to operate a UAS, the PHANTOM 2 Vision+ and a PHANTOM 3 P rofessional , which is comprised of an unmanned aircraft (UA S or PHANTOM) and a transportable ground station. The PHANTOM isreferred to as a quad

- copter with a maximum gross weight of about 3 pounds. It is equipped with four

rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 20

knots & b oth UAS ’s will have a sma l l ultra

- lightweight HD camera

.

The Pilot, Albert Rivera , will provide the following levels of safety: I will only operate in reasonably safe environments th at are strictly controlled, are away from power lines, elevated ligh ts, airport s and actively populated areas ; I will conduct extensive preflight inspections and protocols, during which safety carries primary importance. I have a pre

- flight & post

- flight check list in order to make sure all safety precautions are met at all times.

I will operate the UAS below 2 00 feet and within a radius distance of 1000 feet from the controller to both

aid in direct li ne of sight visual observation; I will operate the UAS for 5

- 15 minutes per flight; I will land his UAS prior to the manufacturers recom mended minimum level of battery power; I will operate his UAS only with in visual line of sight (VLOS); I will use the UAS global positioning system (GPS) flight s afety feature whereby it hovers and then slowly lands if communication with th e remote control pilot is lost; I will conduct all oper ations under my personal and fli ght safety protocols (including posting a warning sign reading: Attention Aerial Photography in Progress Remain Back 150 feet) contained in the operating documents a nd will actively analyze flight data and other sources of

information to constantl y update and en hance the safety protocols; I will contact respective airports if operations will be with in 5 miles to advise them of my estimated flight time, flight duration, elevatio n of flight and other pertinent information; I will always obtain all necessary permissions prior to operation.

Granting this request would not adversely affect safety since operations would be in accordance with

current UAS rules. Based on the size of the craft, experience of the pilot, and operational goals, this
request appears to be well suited for approval using the current criteria outlined in Section 333 of the FAA

Modernization and Reform A ct of 2012 (including new interim policies)

Sincerely

Albert Rivera