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November, 5 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 

and Part 11 of the Federal Aviation Regulations from: 14 CFR 

Part 21, Subpart H, 14 CFR 91.7 (a), 14 CFR 91.9 (b), 14 CFR 

91.103, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151 (a),

14 CFR. 91.203 (a) (b), 14 CFR 91.405 (a), 14 CFR 91.407(a), 

14 CFR 91.409(a), 14 CFR 91.417(a) (b) 

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform 

Act”) and 14 C.F.R. Part 11, Ramon Pagan Rivera an operator of Unmanned Aircraft 

Systems (“UASs”), hereby applies for an exemption from the Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUAS (small Unmanned Aerial 

System). 

This exemption would permit commercial and professional operations which will use:

 3D Robotic Iris+

 3D Robotic X8-M Copter 

to conduct UAS workshop for education, general photography and videography, real 

estate photography and videography, film and movie production, wildlife surveys, pipeline 

patrols, infrastructure and industrial inspections, news gathering, agricultural surveys, 

demonstration flights, and any other related entities/activities that can utilize the safe and 

efficient operation of sUAS aircraft. Ramon Pagan Rivera operation under the exemption 

will be subject to strict operating conditions and requirements to ensure a level of safety 

equivalent to that of currently authorized operations using manned aircraft and under 

conditions as may be modified by the FAA as required by Section 333. 
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Contents

I. Petitioner's Description ..........................................................................................................................3

II. Relevant Statutory Authority ................................................................................................................3

III. Qualifications for Approval under Section 333 of the Reform Act.................................................4

IV. Description of Proposed Operations .................................................................................................5

V. Regulations From Which Exemption is requested ...........................................................................6

a. 14 CFR Part 21, Subpart H Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) ..................6

b. 14 CFR 91.7 (a) Civil Aircraft Airworthiness ..................................................................................6

c. 14 CFR 91.9 (b) (2) Civil Aircraft Flight Manual, Marking, and Placard Requirements ..........6

d. 14 CFR 91.103 Preflight Actions .....................................................................................................6

e. 14 CFR 91.119 Minimum Safe Altitudes: General........................................................................6

f. 14 CFR 91.121 Altimeter Settings....................................................................................................7

g. 14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions ........................................7

h. 14 CFR. 91.203 (a) (b) Civil Aircraft: Certifications Required.....................................................8

i. 14 CFR 91.405(a) Maintenance required........................................................................................8

VI. Public Interest .......................................................................................................................................8

Movies and Videography.................................................................................................................8

Newsgathering..................................................................................................................................9

Real Estate........................................................................................................................................9

Search and Rescue/First Responders..........................................................................................9

Law Enforcement .............................................................................................................................9

Agriculture and Conservation.......................................................................................................10

VII. Privacy ................................................................................................................................................10

IX. Conclusion...........................................................................................................................................10
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I. Petitioner's Description

Ramon Pagan Rivera is located Portales del Prado Albizu Campos Ave H8 in Ponce, 

Puerto Rico. The intentional purpose is offer services for commercial and professional 

use of Unmanned Aerial Systems (AUSs).

All communications may be directed to:

With copy to: 

Ramon Pagan Rivera Jose Enrique Garcia Torres

(787) 454- 4845 (787) 648-2220

Information System Engineer Mechanical Engineer 

ramon.ramonpagan@gmail.com joseegt1@gmail.com

Ramon Pagan Rivera goal is to operate in an accident-free environment by:

 Being proactive when performing pre-flight operations and identifying any 

potential safety hazards.

 Demonstrating the ability to identify and appropriately eliminate hazards and 

risks to the aircraft as well as persons involved in the flight.

 Identifying the area of ground station and AUS equipment with safety and 

warning signs to let the people around know about the activity. 

Ramon Pagan Rivera respectfully submits this request for an exemption due to its 

operation of sUASs. The FAA can have confidence that Ramon Pagan Rivera’s 

operations will be conducted at an equivalent level or greater level of safety than that of 

sUASs counterparts of larger manned aircraft. Approval of this exemption would 

therefore enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system.”

II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to 

consider whether certain unmanned aircraft systems may operate safely in the National 

Airspace (NAS) before completion of the formal UAS rulemaking, based on the UAS 

Notice of Proposed Rulemaking:
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Sections:

 The weight, speed, and operational capability of the UASs

 Operating the UAS in a relatively close proximity to airports or other populated 

areas

 UAS will be in direct visual line-of-sight (VLOS) with the observer and pilot

If the Secretary determines that such vehicles "may operate safely in the National 

Airspace System, the Secretary shall establish requirements for the safe operation of 

such aircraft in the National Airspace System".

III. Qualifications for Approval under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied. The proposed operations would permit Ramon Pagan Rivera the 

use of sUAS under controlled conditions in airspace that is: 

1. Predetermined; 

2. Exercises controlled access; and that 

3. Provides an increased level of safety beyond existing comparable operations 

when fixed or rotary winged aircraft are used.

Ramon Pagan Rivera uses sUASs that are:

1. multi-rotor, 

2. Weighing less than 25 pounds including payload. 

3. They operate, under normal conditions, at speeds not to exceed 45 mph. 

4. They have the capability to hover in a location and move in the vertical and 

horizontal plane. 

Ramon Pagan Rivera sUASs will operate:

1. in line-of-sight, 

2. under VFR flight conditions, 

3. and within the guidelines of a safety environment

Ramon Pagan Rivera will operate at or below 500 feet Above Ground Level (AGL) and 

will generate a log for each flight operated in controlled airspace. All required 

permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies prior to operating a sUAS. Given the small size of the UASs involved and the 

restricted safety environment that they will operate in, this exemption falls within the

zone of safety and demonstrates an equivalent level of safety. Also, due to the 

aforementioned conditions, approval of the application presents no hazard in the NAS.
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Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, the grant of the requested 

exemptions is also in the public interest.

IV. Description of Proposed Operations

To assist the FAA in its safety assessment said proposal, below is a summary of 

operational limitations and conditions that will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds

2. Ramon Pagan Rivera Unmanned Aerial Systems will designate a Pilot for each

mission

3. Flights will be operated within line-of-sight of the Pilot and observer

4. Maximum total flight time for each operational flight will be limited to the amount 

of time the sUAS can be flown and still maintain a reserve battery power of no 

less than 20%

5. Flights will be operated at an altitude of no more than 500 feet AGL

6. Flights will be operated at a lateral distance of least 100 feet from any inhabited

structures, buildings, vehicles, vessels, people not associated with the operation 

or who have not signed a waiver in advance of the operation

7. Minimum crew for each operation will consist of the sUAS Pilot and a Visual

Observer (VO)

8. A site inspection will be conducted prior to the operations at a particular location.

On the day of the mission, the management person with operational control and 

the Pilot will concur on dispatching of the mission

9. All sUASs will be maintained in accordance with inspection program specified in 

the manufacturer’s guidelines

10.In the event of an accident involving Ramon Pagan Rivera sUAS, that mission’s 

operations will cease and the accident reported to the FAA

11.Pilot and Visual Observer will at all times be able to communicate by voice

12.Pilot, Visual Observer, and any additional required operational personnel will 

possess the required minimum skills and education

13.If the sUAS loses communications signal, the sUAS have the capability to return

and land at a pre-determined location

14.Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the pilot and observer

15.The sUAS has the capability to abort a flight in case of unpredicted obstacles or

emergencies

16.The Pilot will contact the Air Traffic Control (ATC) facility or appropriate airspace 

controlling authority prior to operating in airspace other than Class G.
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V. Regulations From Which Exemption is requested

a. 14 CFR Part 21, Subpart H Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Section 91.203 (a) (1) requires all civil aircraft to have a certificate of airworthiness. Part

21, Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR 91.203

Size of our UAS (less than 25 lbs) and the limited operating area associated with its 

operation, it is unnecessary to go through the certificate of airworthiness process under 

Part 21 Subpart H to achieve or exceed current safety levels. Our UASs provide an 

equal level of safety of operations.

b. 14 CFR 91.7 (a) Civil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. Should the exemption be granted allowing commercial operation of

the UAS included in this request to fly without an airworthiness certificate, no standard

will exist to determine their airworthiness. Given our AUSs size and the description of 

proposed operations, an equivalent level of safety will be provided on our daily basics.

c. 14 CFR 91.9 (b) (2) Civil Aircraft Flight Manual, Marking, and Placard Requirements

This section requires an aircraft flight manual in the aircraft. As there are no pilots, crew

or passengers, and given the size of our UAS, this regulation is inapplicable. 

An equivalent level of safety will be achieved by maintaining an operations log flight at 

PIC’s Ground Control Station (GCS) during any operation. 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A.

d. 14 CFR 91.103 Preflight Actions

It is a most the PIC, before start a flight, be familiar with all available information 

regarding the flight. An equivalent level of safety will be achieved by the PIC taking all 

pre-flight actions as mentioned above, including reviewing weather, flight battery 

requirements, landing and takeoff distances before initiation a flight. 

In addition, Ramon Pagan Rivera will be offering a recap before each flight and all 

personnel who will be performing duties will be required to attend.

e. 14 CFR 91.119 Minimum Safe Altitudes: General

Specifically, 91.119 (c) limits aircraft flying over areas other than congested areas to an 

altitude of 500 feet above the ground, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated closer than 500 feet to any 
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person, vessel, vehicle or structure. As set forth herein, our UAS will never operate at 

higher than 400 feet AGL at congested or populated areas. 

In the majority of cases our flights will be between 100 and 350 feet (AGL) due to the 

nature of the services that we will offer. Actually, we will never need to fly at more than 

400 feet (AGL). Because our operations must be accomplished at relatively low 

altitudes and at altitudes less than 500 feet AGL, it is required an exemption from

Section 91.119(c).

f. 14 CFR 91.121 Altimeter Settings

This regulation requires that each person operating an aircraft shall maintain the 

cruising altitude or flight level of that aircraft, as the case may be, by reference to "the 

current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft.” 

Ramon Pagan Rivera seeks an exemption because our UASs does not have a 

barometric altimeter, but rather a GPS altitude read out. The UAS will be programmed 

to remain below 150 feet AGL regardless of PIC control input, thus ensuring operation 

at safe altitudes. In addition, R/C transmitter box have telemetry monitor with all of the 

information needs to fly UAS safely such as altitude, flight speed, distance, direction 

and other.

g. 14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

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

unless (considering wind and 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 least 45

minutes."

The batteries powering our UAS provide approximately 30 minutes of flight time. 

Training operations will be limited to a minimum voltage to ensure appropriate reserve 

battery to maintain an equivalent level of safety at all times. If the PIC fails to land the 

UAS prior to the allotted minimum voltage, the UAS will autonomously return to its 

original launch position.

We will never make flight operations at night. Operating the UAS in controlled areas 

where only people and property owners or official representatives who have signed 

waivers will be allowed, with less than 20 minutes of flight operation time, does not give 

rise to the type of risks that Section 91.151 (a) was intended to alleviate particularly 

given the size and speed of the UAS.
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h. 14 CFR. 91.203 (a) (b) Civil Aircraft: Certifications Required

This section 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 such certifications and registrations at the PIC’s 

Ground Control Station (GCS) box during any operation.

i. 14 CFR 91.405(a) Maintenance required

14 CFR 91.407(a) (1) Operation after maintenance, preventive maintenance, 

rebuilding or alteration 14 CFR 91.409(a) (2) Inspections 14 CFR 91.417(a) (b) 

Maintenance records

Section 91.405 (a) requires 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...” Section 91.407 similarly makes 

reference to requirements in Part 43; Section 91.409 (a) (2) requires an annual 

inspection for the issuance of an airworthiness certificate.

Section 91.417(a) requires the owner or company operator to keep records showing

certain maintenance work that has been accomplished by certificated mechanics, under

Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance will be performed by the UAS operator following rigorous inspection prior 

each flight. An equivalent level of safety will be achieved because UAS are small in 

size, will operate only in restricted predetermined areas, and is not a complex 

mechanical devise. The PIC and our maintenance crew will ensure that the UAS is in 

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

of any maintenance, repair or replacing parts that is performed. Moreover, the PIC is the 

person most familiar with the UAS and is best suited to maintain the aircraft in an 

airworthy condition and to ensure an equivalent level of safety.

VI. Public Interest

Public interest is furthered with granting Ramon Pagan Rivera’s exemption request. 

Congress’s national policy favors early integration of UAS into the national airspace in 

controlled, safe working environments such as those proposed in this petition. Ramon 

Pagan Rivera’s goals are to help facilitate and promote the safe integration of sUASs 

into the NAS, while providing education and awareness of sUAS operations and 

capabilities. 

The following is not an exhaustive list of areas of interest:

Movies and Videography

Small-unmanned aerial systems provide unparalleled capability in their ability to quickly

adapt to any situation. Unlike traditional filming methods that can require excessive
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amounts of time to change camera angles for different views, sUASs are light, stabilized

platforms that can quickly maneuver through the air into position for capturing every

angle in high definition video.

Newsgathering

Helicopters have been utilized in newsgathering for many years. They have provided 

the ability to easily maneuver into positions that allow for multiple viewing angles of a

scene. However, the technology has now progressed to allow for much smaller, cost

effective sUAS aircraft to capture breaking news with much less risk to persons or

property. Since sUAS are dramatically smaller in size and weight in comparison to

manned aircraft, carry no fuel, and operate within sterilized areas, they provide an

increased margin of safety that is unrivaled.

Real Estate

Real estate is an area that sUAS platforms have grown in popularity. Whether the real

estate professional is listing commercial or residential properties, the sUAS enables 

them to capture dramatic shots for each property that would otherwise require costly 

and noisy helicopter operations. In addition to being able to capture spectacular exterior 

photos and video, Ramon Pagan Rivera’s sUAS platforms possess internal sensors for 

stabilization while operating in areas where a GPS signal is not available. This 

adaptability gives real estate professionals a high quality, cost effective, safe, and 

simple solution to an otherwise costly and neighborhood-disrupting endeavor.

Search and Rescue/First Responders

Search and rescue/first responder personnel will also benefit from sUASs capabilities of

real-time video and surveys that Ramon Pagan Rivera provides. The sUASs ability to 

inspect dangerous or unstable areas without placing personnel at risk is monumental in 

saving lives. In addition, the sUASs can survey large areas of land to identify areas of 

interest at an expedited rate when compared to search and rescue personnel on foot. 

The sUAS excels over traditional manned aircraft during these instances in both cost 

and the safety of personnel on the ground.

Law Enforcement

Small-unmanned aerial systems are designed for rapid deployment and covering 

specific areas of interest; these are key components for law enforcement officers. 

Recent developments in sUAS platforms are allowing for easy transition between HD 

photos and video. Utilizing a sUAS would prove useful by increasing officer safety when

identifying areas of interests with potential threats as well as accident scene

investigations and monitoring undercover operations from greater distances.
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Agriculture and Conservation

Ramon Pagan Rivera will demonstrate to farmers the advancements in agriculture 

analysis that a sUAS can provide in soil property and moisture analysis, plant counting, 

crop stress analysis, erosion analysis, 3D mapping, and other areas of agricultural land 

management. The sUAS can fly pre-programmed missions that allow the operator to 

gather precise data. While the sUAS is in flight, the pilot can assume full control to 

inspect areas of interest.

Once it has been examined, the sUAS will resume its flight plan from the last point

analyzed. Equipped with an IR camera, the sUAS can also provide farmers with real 

time video of locations of wildlife that potentially threaten their crops.

VII. Privacy

All flights will be conducted in accordance with any state, federal, or local laws 

regarding privacy. Also, will occur over private or controlled access property with the 

property owner’s prior consent and knowledge. Filming will be of people who have also 

consented to being filmed or otherwise have agreed to be in the area where filming will 

take place.

IX. Conclusion

In meeting the criteria provided in Section 333 of the Reform Act of 2012, considering 

the size, speed, capabilities, utilization of visual line-of-sight, and operating constraints 

around controlled airspace and populated areas, Ramon Pagan Rivera has 

demonstrated justification for the grant of the requested exemptions to operate sUASs 

in the defined areas. Approval of this exemption requested will allow Ramon Pagan 

Rivera to conduct commercial operations with small-unmanned aerial systems. Due to 

each of the sUASs size, weight, lack of flammable fuel, and lack of passengers or crew 

on board, the risk to the general public and property owners are virtually eliminated.

If you have any questions or require any additional information, please do not hesitate 

to contact me.

Regards,

__________________________________

Ramon Pagan Rivera

Cell phone: (787) 454-4845

Email: ramon.ramonpagan@gmail.com
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Links and Appendices:

https://3drobotics.com/kb/iris/ (Portal with safe, configuration and manuals info)

https://3drobotics.com/kb/x8/ (Portal with safe, configuration and manuals info)

Appendix A: Iris+ Flight Checklist
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Appendix B: X8+ Flight Checklist
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Appendix C: Example UAV Maintenance Log

Date Frame Engine Electrical RC GCS Description Technician

Appendix D: Example UAV Fight Log

Date Fight 

Job 

name

Flight 

Type

Flight 

conditions

PIC 

name

Start End Cumulative 

flight time

(hrs/mins)

PIC

initials

VO

initials

Remarks 

(incidents, 

malfunction, 

etc)

The above are submitted as Confidential Documents under 14 C.F.R. § 11.35(b) and 

exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., 

and any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act