Raymond I. Vasquez

Owner- iStudio

3045 Santa Ana Drive

Reno, NV 89502

January 3, 2016

U.S Department of Transportation

Docket Managment System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 

14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 

14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Raymond I. 

Vasquez, operator of small Unmanned Aerial Systems (UAS), hereby applies for an exemption from the listed 

Federal Aviation Regulations to allow commercial operation of a small UAS, 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.

The requested exemption would permit iStudio to pursue commercial interests and services in aerial photography 

and/or video to clients using a small advanced sUAS in the following areas:

• Design/Promotions

• Sales and Marketing

• Real Estate and Architecture

• Special Events/Weddings

• Surveying and Mapping

• Educational Material

As described fully below, the requested exemption would permit the operation of small UAS under controlled 

conditions in the NAS that would be a.) limited b.) controlled c.) predetermined and d.) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. 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.”
Contact for the applicant is:

Name: Raymond I. Vasquez

Address: 3045 Santa Ana Drive, Reno, NV 89502

Phone: 775-813-0192

Email: istudio76@icloud.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113(a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

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) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

The small UAS’s I will be using are multi-rotor craft weighing no more than 55lbs. including payload. Under 

normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and have the ability hover and 

move along a vertical and horizontal plane simultaneously. They will operate in line of sight only and by the 

exempted person only obeying all other local and federal laws.

PUBLIC BENEFIT AND SAFETY

Given the small size of the small UAS and the controlled environment provided the proposed operations will 

adhere to the Reform Act’s safety requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption 

with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The small UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight time whichever occurs first.
4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 

200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), the Visual Observer 

(VO) when needed and may include but not limited to a Camera Operator.

6. A briefing will be performed regarding the planned small UAS operations prior to each day’s flight consisting 

of all the days’ production activities.

7. The PIC will obtain verbal/written consent of all persons involved with the planned operation and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be 

reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With 

the advanced permission or direction of the FSDO, operations at closer range may be approved.

8. The PIC and VO will have been trained in operation of small UAS and receive up-to-date information for the 

particular small UAS to be operated and will be able to show upon request their competent ability to operate 

the small UAS and/or Camera.

9. The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

10. Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies when needed.

11. If the small UAS loses communications or loses GPS signal, the small UAS will have the capability to return 

to a pre-determined location within a designated location and land autonomously.

12. The small UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

SMALL UAS INFORMATION

Small UAS’s to be used are as follows:

1. DJI Phantom 3 Pro

2. 3DR SOLO

3. Yuneec Q500 4K Typhoon

I respectfully request exemption under Section 333 to permit iStudio to conduct efficient, limited, and low-risk 

commercial UAS operations for the activities stated herein while respecting at all times the space and privacy of 

citizens and property, and following the incurred FAA regulations.

Thank you for the consideration of these exemptions.

Sincerely,

Raymond I. Vasquez
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act 

(49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular small UAS. In all cases, an analysis of these criteria 

demonstrates that the small UAS operated without an airworthiness certificate, in the restricted environment 

and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The small UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and 

designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator and under the requirements and in compliance with local public safety 

requirements. These safety enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security 

posed by the small UAS, due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter “N” and the registration number 

is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.

Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the small UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given 

the size of the small UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the 

fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the small UAS 

marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the small UAS 

will see the identification of the small UAS as “Experimental.”

14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command of 

an aircraft that is carrying passengers or property for compensation or hire. Our small UAS do not carry any pilots 

or passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s 

license will not ensure remote control piloting skills. The risks attendant to the operation of small UAS is far less 

than the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations 

set forth in the FOM will equate to the safe operation of the small UAS.

The safe operation and control of the UAS as described in this application does not depend on the type of FAA 

license held by the PIC. That knowledge can be and is gained primarily through practice and experience and 

not through flight training in fixed wing or rotor aircraft, nor is it dependent on the acquisition of a commercial 
or private pilot’s certificate. Those certificates demonstrate knowledge of the factors and skills needed for the 

safe operation of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that any type of pilot, 

approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned 

aerial vehicle, operating at 400 AGL or lower, within strictly controlled pre-approved airspace. From a practical 

standpoint, there are relatively few licensed full-scale aircraft pilots who are also qualified to fly the type of UAS 

that are utilized for infrastructure image- capture operations. There are even fewer pilots that can fly these UAS – 

to the point that to do both is considered rare.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there 

will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety 

checklists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane 

or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a 

current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof. The small UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual 

at the ground control point where the pilot flying the small UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The 

OPERATOR will take all actions including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls. Small UAS and remotely piloted 

aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use 

of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions 

for flight training without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any 

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a small UAS that is a helicopter 

and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an 
elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set 

forth herein, the small UAS will never operate at higher than 400 AGL with the exception that in circumstances 

where the small UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the small 

UAS will not be operated more than 100’ above the highest point on the structure. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to operations without their 

pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the small 

UAS as well as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable

fuel, any risk associated with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the small UAS will ensure 

separation between these small- UAS operations and the operations of conventional aircraft that must comply 

with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available 

before departure.” As the small UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) 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 battery powering the small UAS provides approximately 

30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights 

would be limited to approximately 10 minutes in length. Given the limitations on the small UAS’s proposed flight 

area and the location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) 

falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, with less than 

30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate 

given the size and speed of the small UAS. Additionally, limiting small UAS flights to 10 minutes would greatly 

reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 30 minutes or 25% of battery power— whichever happens first. This restriction 

would be more than adequate to return the small UAS to its planned landing zone from anywhere in its limited 

operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .
(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.

The small UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there 

is no ability or place to carry certification and registration documents or to display them on the small UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the small UAS will have immediate access to them; to the extent they are applicable to the small UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require 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...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with 

an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by 

the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be 

operating from no higher than 400 feet AGL. The operator will ensure that the small UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, 

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

condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the small UAS Manufacturer’s Manual, as referenced in the Aircraft Operations Manual (AOM). As 

provided in the FOM, the operator will ensure that the small UAS is in working order prior to initiating flight and 

perform required maintenance needed.