info@orlandonegron.com /	787-405-4067	/	Flamboyan	Garden		F-34	calle	8		Bayamon,	PR	00959

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July	1,	2015

Orlando	Negron

Orlando	Negron	Photography

Flamboyan	Garden

F-34	calle	8

Bayamon,	PR	00959

Email:	info@orlandonegron.com

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	2012

Attachments:

1)	Phantom	3	User	Manual	V	1.2	(can’t	attach	it	because	of	the	size.	More	than	10	MB.)	

Please,	refer	to	this	link:	http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_e

n.pdf

2)	Safety Guidelines Disclaimer

References:

1)	FAA	Exemption	No.	11138,	Regulatory	Docket	No.	FAA20140481	

						in	the	matter	of	the	petition	of	DOUGLAS	TRUDEAU

2)	FAA	Exemption	No.	11136,	Regulatory	Docket	No.	FAA–2014–0508	in	

						the	matter	of	the	petition	of	ADVANCED	AVIATION	SOLUTIONS	LLC

3)	FAA	Exemption	No.	11080	Regulatory	Docket	No.	FAA20140355	

						in	the	matter	of	the	petition	of	FLYING	CAM	INC	

Dear	Sir	or	Madam,

In	accordance	with	the	FAA’s	Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012,	I,	Orlando	Negron,	DBA	as	

Orlando	Negron	Photography, referred	to	hereafter	as	the	petitioner,	request	exemption	

from	the	following	sections	of	Title	14,	Code	of	Federal	Regulations§§:	61.113(a) ; 61.113(b) 

; 91.119(c) ; 91.121; 91.151(a) ; 91.405(a) ; 91.407(a) (1) ; 91.409(a)(1) ; 91.409(a) (2) ; 

91.417(a) & (b) ; in	order	to	operate	small	unmanned	aircraft	systems	(UAS)	commercially	

in	the	National	Airspace	System	(NAS)	regulated	by	the	Federal	Aviation	Administration	

(FAA)	for	the	purposes	of	aerial	photography,	videography,	and	other	flight	operations	that	

could	be	performed	safely	and	more	cost	effectively	with	the	use	of	small	UAS	at	low	

altitude	within	the	U.S.	NAS	as	compared	to	a	manned	aircraft.	
info@orlandonegron.com /	787-405-4067	/	Flamboyan	Garden		F-34	calle	8		Bayamon,	PR	00959

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Commercial	operations	will	be	performed	only	at	the	request	of,	and	with	the	authorization	

and	permission	of	clients	or	their	authorized	agents	in	order	to	facilitate	commerce	and	

raise	awareness	of	the	beneficial	uses	of	small	unmanned	aircraft	systems.	Operations will 

be conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. The conditions identified and proposed by the petitioner are 

drawn from references 1-3. 

The	FARs	

The petitioner seeks exemption from the above mentioned FARs for the following 

reasons;	

61.113(a) & (b) ;

The petitioner requests relief in order to facilitate the utilization of an experienced UAS 

operator with the addition of a trained observer. All pre-flight inspection, maintenance and flight 

logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for 

review; with the purpose of safely integrating civil UAS operation in the National Airspace 

System. 

91.119(c) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer 

than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential 

persons, or objects that would not be possible without additional relief. The petitioner requests 

modification, waiver or exemption and clarification concerning the terms “congested areas”	and 

“densely populated”. The petitioner requests waiver for this condition to allow reasonable and 

responsible operations in areas of subdivisions and neighborhoods if required. 

The petitioner will primarily operate the UAS between ground level and 200 feet AGL,

but never above 300 feet AGL. The UAS will be operated over designated properties with the 

owner’s consent and while maintaining a safe distance from persons. The petitioner will compile 

flight data from the logs. This data may assist the FAA in development of regulations for 

commercial operations in low-risk, controlled environments.

91.121 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for 

altitude information.
info@orlandonegron.com /	787-405-4067	/	Flamboyan	Garden		F-34	calle	8		Bayamon,	PR	00959

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91.151(a) 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior 

relief has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has 

been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS 

provides battery power remaining in percent to the PIC. The UA batteries provide approximately 

18 minutes of powered flight. Information provided in the operating documents discusses 

procedures regarding remaining battery power management. Those documents contain a

condition in which the PIC will initiate a landing procedure when battery remaining reaches a 

specified level. Given the limitations on proposed operations and the location of those proposed 

operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR 

conditions was reasonable. No UAS operations will be conducted at night, as defined by Federal 

Aviation Regulations. 

91.405(a) ; 91.407(a) (1) ; 91.409 (a) (1) & (2) ; 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to 

inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating 

documents. The FAA found that adherence to the petitioner’s operating documents and the 

conditions and limitations specified, describing the requirements for maintenance, inspection, 

and recordkeeping, were sufficient to ensure that safety would not be adversely affected. 

The UAS 

The DJI Phantom 3 is a highly successful consumer grade small rotorcraft in the quad 

copter configuration with an advertised weight of less than 45 Ounces (1280g) designed 

primarily to carry a high definition camera. It has an advertised maximum speed of less than 31

knots (16m/s) and a maximum climb rate of less than 984 feet per minute (5 m/s). It is powered 

by four electric motors with a distance between motors of less than 14 inches (350mm). It 

utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented 

with global positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) unit. Real time video and 

telemetry information is transmitted back to a ground control station allowing the operator and/or 

PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera 

imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or 

GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can 

be preprogrammed by the PIC. Battery life limits flight times to approximately 23 minutes. The 

onboard flight controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. An automatic termination of flight and landing will be initiated 

when the battery reaches a predetermined low state. It is anticipated that flights will usually last 

less than 12 minutes. More information is available in attachment 1. 
info@orlandonegron.com /	787-405-4067	/	Flamboyan	Garden		F-34	calle	8		Bayamon,	PR	00959

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Risk mitigation 

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be utilized in 

order to manage and mitigate risk and ensure public safety. A preflight checklist will be 

developed and employed to ensure that the UA airworthiness will be verified before launch. 

Airworthiness will be maintained by performance of routine inspections before each flight,

maintaining flight and maintenance logs to record time on failure prone components. These 

documents will be made available to the FAA and SoT to assist in future implementation of 

safety standards and regulations. The petitioner will only operate the UAS over designated 

properties with the owner’s consent. Flight plans will be predetermined to limit the UASs flight 

time and limit safety concerns. The petitioner will take into account distance from persons and 

potential flight obstacles prior to operating the UAS. UAS operation will always be within 

VLOS of the PIC and the observer. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to 

facilitate commerce could lead to economic growth. Operations for this petition will enable 

service for property owners or their designees seeking an enhanced perspective for 

characteristics, amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level videography/photography. Aerial photography is a valuable 

marketing tool that can lead to increased commerce and enhance personal photography. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric estimations and 

reduce risks. The petitioner will provide clients with photographic data for these purposes on a 

‘for hire’	basis acting as an independent contractor. A visual observer will be utilized. Flight data 

including UA flight time, Control Unit operation time, incident, accident, and details concerning 

any deviations from normal operations will be available to FAA for use in collecting data 

regarding the use of UAS as part of this application. This data may be submitted to FAA via 

traditional means or other means as required. 
info@orlandonegron.com /	787-405-4067	/	Flamboyan	Garden		F-34	calle	8		Bayamon,	PR	00959

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Conclusion 

The petitioner is requesting this exemption for the purposes of “aerial photography, 

videography, inspections and other similar flight operations”. The petitioner's business model is 

based on the idea of offering ad hoc small UAS services to individuals or companies who wish to 

employ these services as a safe, effective, and legal option to enhance their business or hobby. 

The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose 

of seeking this exemption is to obtain the capability to offer those services while remaining in 

compliance. The petitioner is a Professional Photographer owner of Orlando Negron 

Photography for more than 10 years and a few years practiced multi-rotor UAS video and 

photography as a hobbyist. 

Respectfully submitted, 

Orlando	Negron

Orlando	Negron	Photography

www.orlandonegron.com

info@orlandonegron.com

787-405-4067