1 | P a g e

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 Unmann ed 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 Robot ic 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, n ews 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 333.2 | P a g e

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 Alti tudes: 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) Main tenance required

................................ ................................ ........................ 8

VI. Public Interest

................................ ................................ ................................ ................................ ....... 8

Movies and Videography

................................ ................................ ................................ ................. 8

Ne wsgathering

................................ ................................ ................................ ................................ .. 9

Real Estate

................................ ................................ ................................ ................................ ........ 9

Search and Rescue/First Responders

................................ ................................ .......................... 9

Law Enforcement

................................ ................................ ................................ ............................. 9

Agriculture and Conservation

................................ ................................ ................................ ....... 10

VII. Privacy

................................ ................................ ................................ ................................ ................ 10

IX. Conclusion

................................ ................................ ................................ ................................ ........... 103 | P a g e

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 peopl e around know about the activity

.

Ramon Pagan Rivera r espectfully 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 :4 | P a g e

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 expedi ted 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. P redetermined;

2. E xercises 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 p ounds 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

r estricted 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.5 | P a g e

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 requ ested

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 equi valent 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

- o f

- 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 altitu de 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 wai ver 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 oper ations at a particular location.

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

t he P ilot will concu r 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. P ilot and Visual Observer will at all times be able to communicate by voice

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

possess the requir ed minimum skills and education

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

and land at a pre

- determined l ocation

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

communication b etween the p ilot and observer

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

emergencies

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

controlling authority prior to operating in airspace other than Class G.6 | P a g e

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

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

operation, it is unnecessar y 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 r equest to fly without an airworthiness certificate, no standard

will exist to deter mine their airworthiness. Given our AUS s 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 sect ion requires an aircraft flight manual in the aircraft. As there are no pilots, crew

or passengers, and g iven the size of our UAS, this r egulation 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 t he 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 taki ng all

pre

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

requirements, landing and takeoff distanc es before initiation a flight.

In addition

, Ramon Pagan Rivera will be offer ing 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 any7 | P a g e

person, vessel, v ehicle or structure. As set forth herein, our UAS wil l never operate at

higher than 4 00 feet AGL at congested or populated areas.

In the majority of cases our flight s will be between 100 and 35 0 feet (AGL) due to the

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

4 00 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 ro ute 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 t elemetry 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 oper ations 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

origin al 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 operati on 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.8 | P a g e

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

This section provides for the carryin g 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 prescri bed 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 ope rator 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.

Maintenan ce 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

. T he 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 be st 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 exempti on 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 educa tion 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 excessive9 | P a g e

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 pr ogressed 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 traditiona l 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 e nforcement 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.10 | P a g e

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, t he 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 prio r 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 request ed 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 cr ew

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 p hone: (787) 454

- 4845

Email: ramon.ramonpagan@gmail.com11 | P a g e

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 Checklist12 | P a g e13 | P a g e14 | P a g e15 | P a g e

Appendix B: X8 + Flight Checklist16 | P a g e17 | P a g e

Appendix C: Example U A V Maintenance Log

Date Frame Engine Electrical RC GCS Description Technician

Appendix D: Example U A V 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