U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the 

Federal Aviation Regulations, Seeking Exemption from: 

14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 21.191(a); 14 C.F.R. § 45.23(b); 14 

C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.l 19(c); 14 C.F.R. 

§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 

14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b). 

THE AIRCRAFT 

The model UAS that GR Group LLC. intends to use within the scope of the requested

exemptions is the DJI Phantom 2, but Petitioner may not exclusively use this model UAS. 

But in all cases, the UAS vehicle will weigh 55 pounds or less.

Dear Sir or Madam: 

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

GR Group (the operator), Gabriel Ruiz (the applicant), planned operation of Small 

Unmanned Aircraft Systems (UASs) equipped to conduct aerial commercial photography, 

Research and Development (R&D) at Test Sites Controlled by Petitioner, request to use UASs 

for photography utilized in the operation of First Responders, for use by Real Estate and 

construction firms and to enhance public awareness of the utility of UASs.

GR Group LLC. hereby applies for an exemption from Federal Aviation Regulations (FARs) to

allow commercial operation of their 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. 

This requested exemption follows the language of exemptions Pursuant to Section 333 that have 

previously been approved by the FAA. 

As described more fully below, the requested exemption would permit the operation of UASs by 

the applicant for commercial use that would provide the following benefits: 

1. Operations would be performed in an area of operation limited in size suitable to the specific 

use, in advance of flight. 

2. The flight would be planned in advance to minimize hazards to persons and property in the 

air and on the ground. 

3. The operator would reasonably limit or control access to provide safety to those not involved 

in the operation. 

4. Operation of a UAS would provide significant safety, environmental and other 

enhancements not possible by larger sized aircraft. 

5. An FAA licensed airman with a Private grade or higher pilot certificate would operate the 

UAS or an FAA licensed airman with a Commercial grade or higher pilot certificate would 

directly supervise the operation (as per Exemption No. 11157). 

6. Provide a beneficial and currently unavailable service to government organizations and the 

general public that would serve the public interest. 

GR Group LLC

October 21, 2015 Page 1 of 10 
Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the 

safe operation of such aircraft systems in the national airspace system” Section 333(c) of the 

Reform Act. 

It is possible to operate UASs so to not create a hazard to users of the National Airspace System 

(NAS), the public or pose a threat to national security if done so safely and responsibly. The 

applicant has demonstrated their willingness to act safely and responsibly by not engaging in 

commercial UAS operations. The applicant currently holds an FAA, ATP Rotorcraft Helicopter 

(3293667) and a current FAA Flight Instructor Certificate (CFI) (Rotorcraft- Helicopter, Instrument, 

NVG). This demonstrates that the applicant has a high regard to safe operations, as well as a necessary 

high-level understanding of the NAS and FARs. The experience these FAA certificates represent, 

serves to add significantly to the level of safety in any operation performed by the applicant or 

the applicant’s employees. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics of UAS and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or higher level of safety to operations under the current 

regulatory structure as the proposed operations represent a safety enhancement to the already 

safe aerial commercial photography and survey operations conducted with conventional aircraft. 

The UASs planned to be operated are rotorcraft, each weighing 55 or fewer pounds including 

payload. They would operate, under normal conditions, at a speed of no more than 87 knots. 

Operations will be performed by a qualified UAS PIC, as outlined below, to insure that the 

UAS will “not create a hazard to users of the national airspace system or the public.” Given the 

small size of the UASs involved and the pre-planned environment within which they will 

operate, the applicant believes that these operations fall squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UASs to commence immediately. Also, operation in a 

researched (to include applicable NOTAMs), pre-defined area will prevent the possibility of a 

national security issue. The operation of UASs by knowledgeable professionals with experience 

in the NAS will serve to enhance safety, add to the public benefit and reduce environmental 

impacts related to current methods of aerial photography and survey. 

Listed below are the limitations and conditions to which the operator, or its employees, acting as 

UAS PIC agrees to be bound when conducting commercial operations under an FAA 

issued exemption: 

1. Safety will be the first and foremost consideration in any UAS operation. 

2. The UAS pilot will be an FAA licensed airman with at least a Private Pilot 

certificate or the UAS pilot will be directly supervised by an FAA licensed airman 

with at least a Commercial Pilot certificate (as per Exemption No. 11157). 

3. The UAS FAA licensed airman will be considered Pilot in Command (PIC), 

whether flying or supervising, and will be responsible for safe operation of the 

flight. 

GR Group LLC

October 21, 2015 Page 2 of 10 
4. Flights will be operated within visual line of sight (VLOS) of the PIC and visual 

observer (VO). 

5. The UAS will weigh less than 55 lbs total. 

6. Flights will be operated in Class G airspace whenever possible. If operation in 

other airspace is required, the relevant controlling agency will be notified at least 

24 hours prior to the operation and, if required, any necessary permission 

obtained. 

7. Flights will be operated under visibility and cloud clearance requirements 

equivalent to Visual Flight Rules (VFR). 

8. The UAS will at all times give way to any aircraft carrying persons. 

9. Minimum crew for each operation will consist of the UAS PIC and visual observer 

(VO). The observer and PIC will at all times be able to communicate by voice. 

10. Prior to a UAS flight, an area of operation will be established. This area of 

operation will include a defined lateral and vertical area, where the UAS will 

operate. Safety procedures will be established for persons, property and 

applicable airspace within the area of operation. 

11. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the UAS or appropriate timing. 

12. The UAS aircraft used will utilize GPS navigation, failsafe, return-to-home (RTH) 

and/or flight abort safety features. 

13. A briefing will be conducted in regard to the planned UAS operations prior to 

operation at each new location. All personnel who will be performing duties within the 

boundaries of the area of operation will be present for this briefing. 

14. All required permissions and permits will be obtained from appropriate state, county 

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

governmental agencies. 

15. Written (to include electronic, and/or oral) permission from the relevant property 

owners will be obtained prior to an operation. 

16. The UAS pilot will be trained in advance for the safe operation of the UAS to be 

operated. Prior to operations the PIC will have accumulated and logged a minimum of 5 

hours as UAS pilot operating the make and model of UAS as well as 3 takeoffs and 

landings in the proceeding 30 days. Specific training will include normal and 

emergency modes of operation and will include familiarization with the operation manual 

published by the UAS manufacturer. Training will also include types of maneuvers to be 

performed during operations including safe operation in relation to persons, property and 

applicable airspace. 

17.The UAS PIC will establish a working relationship with a representative at the local 

FSDO with which to annually review safety procedures and other operations to further 

enhance safety. 

GR Group LLC

October 21, 2015 Page 3 of 10 
18. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the UAS will not be operated until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

 Station will be included in the preflight inspection. All maintenance and alterations will 

be properly documented in the aircraft records. 

19. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, will 

undergo a functional test flight. The PIC who conducts the functional test flight will 

make an entry in the aircraft records. 

20. The pre-flight inspection section in the operating documents will account for all 

potential discrepancies, e.g. inoperable components, items, or equipment, not already 

covered in the relevant sections of the operating documents. 

21. The operator will follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

22. The operator will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts will be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

23. Each UAS operated under this exemption will comply with all manufacturer Safety 

Bulletins. 

24. The authorized person will make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

It is the applicant’s belief that the size, speed, operating environment, limitations and 

level of applicant’s experience in the NAS outlined provides an “equivalent level of 

safety” or better when operating a UAS for the public interest as outlined in Section 333 

in the FAA Modernization and Reform Act of 2012. It is requested that the FAA issue an 

exemption to permit safe, legal, commercial UAS operation by the applicant as soon as 

possible. 

Sincerely, 

Gabriel Ruiz, President 

ATP & CFI Rotorcraft Helicopter, 

Instrument, NVG

GR Group LLC

20251 Bella Gardens Circle

Ponchatoula LA 70454

321-624-1673

GR Group LLC

October 21, 2015 Page 4 of 10 
Appendix A 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

GR Group LLC, requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of UASs: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for UAS, we request an 

experimental certificate be issued for the UASs operated by the applicant under either or both of 

the following provisions: 21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property and will only fly under strict operational 

requirements. Combined with the fact that any aircraft operated would be light weight and is 

constructed primarily out of plastic, we propose that a UAS will be at least as safe, if not safer, 

than a conventionally certificated aircraft performing the same function. 

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be “displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.” A UAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent 

level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for 

this aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose the use of the 

UAS’ unique manufacturers serial number, and a contact telephone number be mounted on the 

UAS on a placard of reasonable size in relation to the UAS. In the event that a unique 

manufacturers serial number is not available, the previously mentioned placard will be affixed to 

the UAS consisting of the model name and number of the UAS, as well as a contact telephone 

number. 

GR Group LLC

October 21, 2015 Page 5 of 10 
14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display “N” and the aircraft’s registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

“EXPERIMENTAL” in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. A UAS does not have an entrance in which the word “EXPERIMENTAL” can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word “EXPERIMENTAL” on the top or 

side of the aircraft, in the form of a placard. The label will be of a size that will not overwhelm 

the aircraft, but will be reasonably readable to someone near the UAS. The placard outlined in 

the previous paragraph will provide sufficient identifiability should someone discover the aircraft 

on the ground. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. The intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to 

this requirement since the UAS cannot carry such a manual, and if the UAS did carry such 

manual, it would be unavailable to the crew for review. To obtain an equivalent level of safety 

and meet the intent of 91.9, we propose that a current, UAS operation manual or equivalent be 

available the crew at the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight 

tests. 

The regulation provides that “No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” The controls for a UAS do 

not currently have a set of fully functioning dual controls. If a UAS pilot is being trained, the 

pilot performing the training would be directly supervising and could take over the controls from 

the pilot in training if the need arose. This would be similar to the technique of a “throw-over 

type” control wheel in some fixed wing aircraft. We feel that this technique meets the intent of 

91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this UAS 

would be photography or survey of persons, vessels, vehicles or structures it would be necessary 

to operate closer than 500 feet to the items listed. Operations will only be flown over property or 

persons where permission has been obtained, and careful pre-planning has been performed. 

Further, UAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much 

space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and 

careful pre-planning would provide an equivalent level of safety. 

14 CFR 9l.l21Altimeter settings. 

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The UAS will always fly below 500 

feet AGL, and in line of sight of the PIC and visual observer (VO). This line of sight operation 

GR Group LLC

October 21, 2015 Page 6 of 10 
will provide separation from other aircraft, obstructions and terrain, and would override the use 

of an altimeter for such a purpose. We feel that this will provide an equivalent level of safety. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph it to provide a reasonable 

reserve of energy to plan for a safe landing should there be a delay in landing. The close 

proximity to the ground station, the ability for both rotorcraft and small fixed wing aircraft to 

land in a very small space and the built in energy level monitoring of the UAS we feel provide 

an equivalent level of safety if the flight is planned to be completed with 20% battery energy 

remaining. We request an exemption to the word “fuel” and ask for an equivalent interpretation 

with the word “energy”. 

14 CFR Subpart E (91.401 -91.4171- Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be “approved for return to service by a person authorized under 43.7” 

after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and “be authorized to approve the aircraft for return to service.” Prior to 

every flight, the PIC will inspect the aircraft to ensure that it is in an airworthy condition. Any 

general maintenance procedures or replacement of consumable items outlined by the UAS 

manufacturer, if applicable, will be complied with by the PIC. In no circumstance will a UAS 

be operated in a condition that is deemed, or suspected to be, unsafe. If such a determination is 

reached, and the problem cannot be remedied to the satisfaction of the PIC, the UAS will not be 

operated until consulting with the manufacturer or one of its authorized dealers to complete 

necessary repairs. We feel that due to the size, construction, and simplicity of the aircraft, the 

PIC can ensure an equivalent level of safety. 

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer 

Medical. 

This policy provides that both the PIC and observer must have a valid FAA second-class medical 

certificate issued under Part 67 in order to perform as a pilot or observer. Requiring the crew to 

meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft 

is an unnecessary burden. We propose that the minimum medical requirements for the PIC be a 

valid FAA third-class medical certificate and for the visual observer (VO) be vision corrected to 

20/20 and a valid, state-issued driver’s license. The risk of both the PIC and observer becoming 

incapacitated at the same time and suddenly is very low. Further, since the UAS is operating 

close to the ground, it could be brought in for landing in a very short time if incapacitation was 

suspected. Finally, the UASs used will be equipped with an automatic return to home feature 

which would provide a final level of safety. We feel this would provide an equivalent level of 

safety. 

GR Group LLC

October 21, 2015 Page 7 of 10 
FLIGHT RESTRICTIONS 

(a) No flight will be made with a UAS Gross weight exceeding 55 pounds; 

(b) Most operations will occur in FAA Class G airspace at no more than 400’ AGL, at an airspeed of 

no more than 87 knots and within visual line of sight (VLOS) of the PIC; 

(c) All operations will utilize a visual observer (VO). The VO and PIC will be able to communicate 

verbally at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property 

owner; 

(e) The PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum 5 hours as UAS pilot operating the make and model of UAS as well as 3 takeoffs 

and landings in the proceeding 30 days. 

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The UAS System will not be operated over densely populated areas; 

(h) The UAS System will not be operated at air shows; 

(i) The UAS System will not be operated over any open-air assembly of people; 

(j) The UAS System will not be operated over heavily trafficked roads; 

(k) The UAS System will not be operated within 5 NM of an airport or heliport unless the operator 

has a Coa with the airport operator and within 48 hours, but not more than 72 hours issues an 

appropriate NOTAM; 

(l) Operations will be restricted to day only and weather conditions equivalent to VFR; 

(m) The PIC will brief the VO and property owner about the operation and risk before the first flight 

at each new location; 

(n) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UAS is in a condition safe for flight. 

PRE-FLIGHT CHECKLIST 

(1) Determine that UAS battery is fully charged in order to prevent unexpected premature descent; 

(2) Check all wiring connections are tight; 

(3) Check all propellers are undamaged and no cracks exist in any structural members of the UAS; 

(5) Turn on radio controller, check for adequate voltage, set it to connect to the UAS, move all 

control switches the appropriate preflight position; 

(6) Connect the UAS main battery, check for radio contact with UAS’s radio receiver; 

(7) At a location different from previous flight, re-set GPS and compass to current location; 

(8) Turn on transmitter, gimbal and camera. 

OPERATING DOCUMENTS 

Petitioner submits its Operations Manual and Training Syllabus as Confidential documents under 

14 C.F.R. § l l.35(b) as they contain proprietary information that Petitioner has not and will not 

share with others. The documents contain operating conditions and procedures that are not 

available to the public and are protected from release under the Freedom of Information Act, 5 

U.S.C. § 552. 

GR Group LLC.

October 21, 2015 Page 8 of 10 
The petition and the following supporting documentation are referred to as the operating 

documents: 

1) Training Syllabus including: 

Cautions, Warnings, Basic Flight Maneuvers, Advanced Flight Maneuvers as per 

the DJI Pilot Training Guide and Mission Specific Flight Maneuvers 

2) Operations Manual including: 

Phantom 2 User Manual

Phantom Quick start guide

Smart Flight Battery Safety Guidelines 

3) Forms including: 

GR Group LLC Job Safety Assessment form 

GR Group LLC Preflight Briefing Sheet 

Materials to be readily available to the PIC: 

Operations Manual including: 

• Phantom 2 User Manual

• Smart Flight Battery Safety Guidelines 

• Sectional and TAC Aeronautical charts 

• 	 	 UAS logbook and Defect Sheet(s) 

• Personal pilot logbook

GR Group LLC

October 21, 2015 Page 9 of 10 
It is not the intention of GR Group LLC. to provide commercial UAS training. 

The training outlined in this document is for in-house training of a new 

employee if needed.

 Petitioner submits its Operations Manual and Training Syllabus as 

Confidential documents under 14 C.F.R. § l l .35(b) as they contain 

proprietary information that Petitioner has not and will not share with 

others. The documents contain operating conditions and procedures that are 

not available to the public and are protected from release under the Freedom 

of Information Act, 5 U.S.C. § 552. 

CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security, provide more than adequate justification for the grant of the requested 

exemption allowing operation of Petitioner's UAS for aerial photography and survey for real estate 

and real estate and various industries pursuant to the Operations Manual. 

Please do not hesitate to contact 

Gabriel Ruiz

Ruizg1115@gmail.com

321-624-1673

with any questions about this filing. 

Sincerely, 

														 Gabriel Ruiz

ATP CFI 3293667

CEO GR Group LLC

Attachments: 

GR Group LLC. Confidential Operations Manual, 

GR Group LLC. Training Syllabus 

All relevant forms 

GR Group LLC.

October 21, 2015 Page 10 of 10