Albert Rivera

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 Federal Aviation Regulations from 

14C.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, Albert Rivera, an owner and operator of 2 Small Unmanned Aircraft 

Systems “(UAS”) equipped to conduct aerial photos and videos in the Fresno county area to help farmers 

scout & survey their fields, monitor & manage water usage. I also intend to use the UAS for insurance 

claim & inspection purpose.

I hereby am applying for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of my UASs, so long as such operations are conducted within and under the 

conditions 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 specialize in Ag-Business 

Insurance. I have been a licensed Commercial agent since 1995. I have been flying radio control 

airplanes & helicopters 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 farming customers in various ways. First to help with scouting and to 

survey their crops & fields. The images taken by the UAS helps them identify troubled areas of the crops 

with greater accuracy & speed. I only intend to fly the UAS’s on these private 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. My 

small UAS 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 manned aircrafts for farming

operations that require a greater expense, & reduce the safety risk involved of manned aircraft.

I plan to operate a UAS, the PHANTOM 2 Vision+ and a PHANTOM 3 Professional, which is comprised 

of an unmanned aircraft (UAS or PHANTOM) and a transportable ground station. The PHANTOM is 
referred 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 & both UAS’s will have a small ultra-lightweight HD camera.

The Pilot, Albert Rivera, will provide the following levels of safety:

I will only operate in reasonably safe environments that are strictly controlled, are away from power lines, 

elevated lights, airports 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 200 feet and within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation; I will operate the UAS for 5-15 minutes per flight;

I will land his UAS prior to the manufacturers recommended minimum level of battery power; I will 

operate his UAS only within visual line of sight (VLOS); I will use the UAS global positioning system 

(GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote 

control pilot is lost; I will conduct all operations under my personal and flight safety protocols (including 

posting a warning sign reading: Attention Aerial Photography in Progress Remain Back 150 feet) 

contained in the operating documents and will actively analyze flight data and other sources of 

information to constantly update and enhance the safety protocols; I will contact respective airports if 

operations will be within 5 miles to advise them of my estimated flight time, flight duration, elevation 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 Act of 2012 (including new interim policies)

Sincerely

Albert Rivera