AntonioL.Lucio7954DepewSt.Arvada,CO80003Tel:720-436-6264Email:alucio33@gmail.comOctober16,2015U.S.DepartmentofTransportation,DocketOperationsWestBuildingGroundFloor,Roomw12-1401200NewJerseyAvenue,SE.,Washington,DC20590Re:ExemptionRequestSection333oftheFAAReformActandPart11oftheFederalAviationRegulations.Towhomitmayconcern,PursuanttoSection333oftheFAAModernizationandReformActof2012(theReformAct)and14C.F.R.Part11,AntonioLucio,acurrentprivatepilot(Certificatenumber3803202)andprofessionalinthevideoandbroadcastindustry, herebyappliesforanexemptionfromthelistedFederalAviationRegulations("FARs")toallowhimtooperateasmallUnmannedAircraftSystem("sUAS")undertheconditionsandlimitationssetforthinthisPetition.Therequestedexemptionwouldpermittheoperationofsmall,unmannedandrelativelyinexpensivesUASundercontrolledconditionsinairspacethatis(1)limited,(2)predetermined,3)controlledastoaccessand4)wouldprovidesafetyenhancementstothealreadysafeoperationsinthetelevisionindustrypresentlyusingconventionalaircraft.ApprovalofthisexemptionwouldtherebyenhancesafetyandfulfilltheSecretaryofTransportation's(theFAAAdministrator's)responsibilitiesto"...establishrequirementsforthesafeoperationofsuchaircraftsystemsinthenationalairspacesystem."Section333(c)oftheReformAct.Thenameandaddressoftheapplicantis:AntonioLucio7954DepewSt.Arvada,CO80003Phone:720-436-6264Email:alucio33@gmail.comRegulations from which the exemption

is requested: 14 CFR Part 21 14 C

. F.R

. 45.23{b) 14 CFR 61.113
(a) 

### & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C

. F.R. 91.109 14 C

. F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151
(a) 14 CFR 91.203 (a) 

### & (b) 14 CFR 91.405
(a) 14 CFR 407 (a) (1) 14 CFR 409 (a) {2) 14 CFR 417 (a) 

### & (b) This exemption application

is expressly submitted

to fulfill Congress' goal
in passing Section 333(a) through

(c) of the Reform Act. This law directs the Secretary

of Transportation

to consider whether certain unmanned aircraft systems may operate safely

in the national airspace system (NAS) before completion

of the rulemaking required under Section 332 of the Reform Act

. In making this determination,

the Secretary

is required

to determine which types of UASs do not create

a hazard
to users of the NAS or the public or pose

a threat to national security

in light of the following: • The UAS's size, weight, speed, and operational capability; • Operation

of the UAS in close proximity

to airports and populated areas; and • Operation

of the UAS within visual line of sight of the operator. Reform Act§ 333 (a). Lastly,

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."
o Reform Act §333(c) The Federal Aviation Act expressly grants the FAA the authority

to issue exemptions.
This statutory authority

by its terms includes exempting civil aircraft,

as the term

is defined under §40101
of the Act, that includes sUASs, from the requirement that all civil aircraft must have

a current airworthiness certificate.Antonio Lucio,

a professional

in video and broadcast industry with

a current pilot's certificate.

I would like combine the knowledge
and skills of both industries. The opportunity

to expand his career
as a video professional
and an aviation enthusiast

is present.
As a video professional

for 15 plus years working
on a variety of productions from corporate videos
to broadcasting sporting events, holding

a range of positions from cameraman

to engineer, there

is a great value to be had as a Pilot
in Command (PIC) of a small Unmanned Aircraft System ("sUAS").

If granted exemption from the listed FAR's,

I would seek contract

to hire and/or Full time position

as Pilot in Command (PIC) of a small Unmanned Aircraft System ("sUAS"). The demand for sUAS pilots with the ability to produce

a high quality video product

at a reasonable price

is rapidly growing. The desire to develop new technology
and educated the public through video has always been

a passion.

As a pilot of general aviation aircraft,

I have had my own encounters with sUAS.

I am well aware of the safety concerns involving sUAS and general aviation

in the national airspace system.

I will ensure the safety of the public on the ground and in the air. A number
of colleagues

in the video community have approached

me due to my pilot certificate and have asked me to fly their sUAS for video production purposes.

As an aviator

I want to make certain

I am in full compliance with the FAA FAR's

. I have read the congressional mandate

in sections 332 and 333 of the FAA Revitalization

and Reform Act of 2012 that the FAA move quickly
to accommodate

the economic and societal benefits that can result from widespread deployment

of sUAS technology. Accordingly,

I'm applying for authorization under the Federal Aviation Act, and the FARs rules to undertake
the following activities for commercial purposes. Antonio Lucio will operate sUAS weighting

55 or fewer lbs. including payload. The sUAS operate under normal conditions

at a speed of no more than 50 knots and have the capability

to hover, and move

in the vertical and horizontal plane simultaneously.
They will operate only
in line of sight insuring that the sUAS will "not create

a hazard
to users of the national airspace system
or the public." Per Reform Act Section 333 (b). Given the small size of the sUAS's involved and in the line of sight environment within which they will operate, the applicant falls 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 sUAS's
to commence immediately. Also due to the size of the sUAS's and the areas
in which the relevant sUAS's will operate, approval

of the application presents
no national security issue. Given the clear direction

in Section 333 of the Reform Act, the authority contained

in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations,
and the significant public benefit, including enhanced safety, reduction

in environmental impacts, including reduced emissions associated with allowing UASs for television operations,
the grant of the requested exemptions

is in the public interest. Accordingly,
the applicant respectfully requests that the FAA grant the requested exemption without delay.AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics

and that operate with the limitations listed herein. These limitations provide for at least an equivalent

or even higher level of safety to operations under the current regulatory structure because the proposed operations represent

a safety enhancement

to the already safe Video and television operations conducted with conventional aircraft

. These limitations and conditions

to which Antonio Lucio agrees
to be bound when conducting commercial operations under an FAA issued exemption include: 1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated

at an altitude
of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming

is planned. 5
. Minimum crew for each operation will consist
of the sUAS Pilot and
a Visual Observer. 6
. sUAS pilot will be an FAA licensed airman with at least

a private pilot's certificate and third class medical. 7. A briefing will be conducted

in regard
to the planned sUAS operations prior to each day's production activities.

It will be mandatory that all personnel who will be performing duties within the boundaries

of the safety perimeter

be present for this briefing. 8. Pilot and observer will have been trained

in operation

of UAS generally and received up-to-date information

on the particular UAS to be operated. 9
. Observer and pilot will at all times be able to communicate

by voice and/or text

. 10. Written and/or oral permission from the relevant property holders will be obtained. 11. 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. 12.
If the sUAS loses communications

or loses its GPS signal, the UAS will have capability

to return to a pre-determined location within the Security Perimeter and land. 13

. The sUAS will have the capability

to abort

a flight
in case of unpredicted obstacles

or emergencies. Antonio Lucio proposed operations satisfy the criter

i a provided

in Section 333 of the Reform Act relating to size, weight, speed, operating capabilities, proximity

to airports and populated areas and operation within visual line of sight and national security- provide more than adequate justification

for the grant of the requested exemptions allowing commercial operation

of applicant's UAS
in the television industry. Antonio Lucio Freelance Videographer