October 16, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations. 

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, Antonio Lucio, a current private pilot (Certificate number 3803202) and professional 

in the video and broadcast industry, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow him to operate a small Unmanned Aircraft System ("sUAS") under the conditions 

and limitations set forth in this Petition. 

The requested exemption would permit the operation of small, unmanned and relatively inexpensive 

sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, 3) controlled as to access and 

4) would provide safety enhancements to the already safe operations in the television 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." Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

Antonio Lucio 

7954 Depew St. 

Arvada, CO 80003 

Phone: 720-436-6264 Email: alucio33@gmail.com 
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. 
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. 
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 criteria 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