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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

August 13, 2015

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

SE West Building Ground Floor Room W12-140 Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal

Aviation Regulations from 14 C.F.R. 45.23(b);14 C.F.R. Part 21;14 C.F.R.

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a);

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

Dear Sir or Madam, 

I, Stephen L. Gonzalez, president and member of Gonzalez Marketing LLC, am writing 

to request that Gonzalez Marketing, LLC, an owner and operator of small unmanned 

aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so 

that Gonzalez Marketing, LLC, may operate its small unmanned aircraft I lightweight 

unmanned aircraft system (N570HG) or "UAS" commercially in airspace regulated by

the Federal Aviation Administration ("FAA"); as 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 conditions identified and proposed by the applicant are 

drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver for 

Motion Picture and Television Filming. 

As identified and described herein, Stephen L. Gonzalez, and Gonzalez Marketing LLC

are experienced veterans in the broadcast media production industry. Mr. Gonzalez and 

company have been producing television and web media for the broadcast industry for 15 

years. Gonzalez Marketing has long-standing media production service contracts with 

many commercial advertisers including Lithia Automotive Group Alaska Dealerships, 

Chugach Electric Association, Lifemed Alaska, Alaska Lasik Center and others. 

Mr. Gonzalez has flown his DJI Quad-copter since October 2013. In anticipation of FAA 

regulations allowing commercial use of UAS for filmmaking and other uses, Gonzalez 

Marketing, LLC has been actively involved in the technical development of UAS/ UAV 

service applications to provide high definition film quality by aerial cinematography with 

small, unmanned aircraft and lightweight UASs. Gonzalez Marketing, LLC has fully

equipped its small unmanned aircraft for aerial photography and cinematography, 

primarily for use in the television broadcast industry, though given their stability and 

maneuverability, they may be used for other cinematography, such as tower and structure 

inspection, for search and rescue and by other first responders.
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

To date, Gonzalez Marketing LLC has rejected all offers to work with film, television, 

commercial television production companies and directors on locations within the United 

States, to ensure it is in compliance with any applicable FARs. It, like other applicants, 

has done so despite Judge Patrick G. Geraghty's decision in the Raphael Pirker matter and 

his reasoning that no FARs prohibit the use of small unmanned aircraft or lightweight 

UASs like those flown by other peer companies. 

Gonzalez Marketing, LLC exemption request would permit its operation of lightweight, 

unmanned (remotely controlled in line of sight) UASs in tightly controlled and limited 

airspace. Predetermined, specifically marked areas of operation, cordoned off locations 

and corresponding enhancements to current safety controls will allow Gonzalez 

Marketing LLC to operate within current safety parameters and new ones being 

implemented. 

As identified, similar lightweight, remote controlled UASs are legally operated by 

amateurs with no flight experience, safety plan or controls in place to prevent 

catastrophe. Gonzalez Marketing, LLC has developed a process to monitor, evaluate and 

implement all aerial cinematography activities including pre-flight safety check(list) and

flight plan system. 

Further, Gonzalez Marketing LLC records flight data and other information gained 

through permitted flight operations to share with FAA through any required FAA reports 

to assist with future protocol and safety regulations. 

Granting Gonzalez Marketing, LLC request comports with the Secretary of 

Transportation's (FAA Administrator's) responsibilities to not only integrate UASs into 

the national airspace system, but to "... establish requirements for the safe operation of 

such aircraft systems [UASs] in the national airspace system" under Section 333(c) of the 

Reform Act. Stephen L. Gonzalez and Gonzalez Marketing, LLC will conduct its 

operations in compliance with the protocols described herein or as otherwise established 

by the FAA. 

For the reasons stated herein, I, Stephen L. Gonzalez, President and Member of Gonzalez 

Marketing, LLC respectfully request the grant of an exemption allowing operation of 

lightweight, remote controlled UAS's.
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

I. Contact Information: 

Stephen L. Gonzalez, Gonzalez Marketing LLC

4450 Cordova Street Suite 110, Anchorage, Alaska 99503

II. The Specific Sections of Title 14 of the Code of Federal Regulations, Gonzalez 

Marketing LLC Requests Exemption are: 

14 CFR 21;

14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 

14 CFR 407 (a)(1); 

14 CFR 409 (a)(2); and, 14 CFR 417 (a) & (b). 

III. The Extent of Relief Gonzalez Marketing, LLC Seeks and the Reason It Seeks 

Such Relief: 

I Stephen L. Gonzalez of Gonzalez Marketing, LLC submit this application in accordance 

with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently

applicable FARs operating to prevent Gonzalez Marketing, LLC contemplated

commercial cinematic, research and other flight 2 operations within the national airspace 

system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public's interest to do so. 

Gonzalez Marketing, LLC lightweight UASs meet the definition of "small unmanned 

aircraft" as defined in Section 331 and therefore the integration of Gonzalez Marketing, 

LLC lightweight UASs are expressly contemplated by the Reform Act. Gonzalez 

Marketing, LLC would like to operate its lightweight UASs prior to the time period by

which the Reform Act requires the FAA to promulgate rules governing such craft. The 

Reform Act guides the Secretary in determining the types of UASs that may operate 

safely in our national airspace system. Considerations include: The weight, size, speed 

and overall capabilities of the UAS; Whether the UAS will be operated near airports or 

populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 

333 (a). Each of these items militates in favor of an exemption for Gonzalez Marketing, 

LLC. 

Gonzalez Marketing, LLC UASs utilizes four counter-rotating propellers for extreme 

balance, control and stability. They each weigh less than 15 pounds, including cinematic 

or other equipment. 

Gonzalez Marketing, LLC UAS are designed to primarily hover in place and operate at 

less than a 50 knot maximum speed. They are capable of vertical and horizontal 

operations but operate only within the line of sight of the remote control pilot. 
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

In addition to the remote control pilot, Gonzalez Marketing, LLC uses a spotter and a 

technician, such that, at minimum, three Gonzalez Marketing, LLC personnel govern the 

safe flight of an Gonzalez Marketing, LLC aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and 

twenty minutes. Gonzalez Marketing, LLC does not operate its UASs with less than 

twenty five percent battery capacity. Safety systems in place include a GPS mode that 

allows Gonzalez Marketing, LLC UASs to hover in place if communication with the 

radio control pilot is lost and then slowly descend the UAS at twenty five percent battery 

capacity. Further, Gonzalez Marketing, LLC UAS is programmed to slowly follow a 

predetermined set of waypoints to return to a safety point if communications are lost. 

Gonzalez Marketing, LLC does not operate its UASs near airports and generally does not 

operate them near populated areas. Gonzalez Marketing, LLC only operates its UAS in 

predetermined areas and only in compliance with well-regarded safety protocols such as 

those contained within the well-established and commonly known Motion Picture and 

Television Operations Manual. 

Gonzalez Marketing, LLC operation of UAS will not "create a hazard to users of the 

national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and 

weight of Gonzalez Marketing, LLC UAS, combined with operation in cordoned off and 

well-controlled areas, Gonzalez Marketing LLC UAS is within Congress's contemplated 

safety zone when it promulgated the Reform Act and the corresponding directive to 

integrate UASs into the national airspace system.

Indeed, Gonzalez Marketing, LLC UAS have a demonstrable safety record and do not 

pose any threat to the general public or national security. The FAA has the authority to 

issue the exemption to Gonzalez Marketing, LLC pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act"). 

IV. Commercial and Public Benefits 

Granting Gonzalez Marketing, LLC exemption request furthers the public interest. First, 

Congress has already pronounced that it is in the public's interest to integrate 

commercially flown UASs into the national airspace system, hence the passing of the 

Reform Act. 

Second, Gonzalez Marketing, LLC conducts research into safe UAS operations every

time it flies one of its UASs. Flight data, visual inspections, recorded observations and 

flight analyses are compiled to further enhance current safety protocols. Allowing 

Gonzalez Marketing, LLC to log more flight time directly relates to its research and its 

ability to further enhance current safety measures. 
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

Third, the public has an interest in reducing the danger and emission associated with 

current aerial cinematic capture methods, namely, full size helicopters. Gonzalez 

Marketing, LLC UASs are battery powered and create no emissions. If a Gonzalez 

Marketing, LLC UAS crashes there is no fuel to ignite and explode. The impact of 

Gonzalez Marketing, LLC lightweight UASs is far less than a full size helicopter, 

notwithstanding the statistically noteworthy safety record of full size helicopters used in 

motion picture capture. The public's interest is furthered by minimizing ecological and 

crash impacts by permitting motion picture capture through Gonzalez Marketing, LLC 

lightweight UASs. Progression of the arts and sciences has been fundamental to our 

society since its inclusion in the United States Constitution. Indeed, Congress mandated 

the integration of UASs into our national airspace system, in part, to achieve progression 

in this noteworthy, and inevitable, field. Permitting Gonzalez Marketing, LLC to 

immediately fly within the United States furthers these goals. 

Whether it is the amalgam of scientific discoveries applicable to feature film making 

(including those drawing upon architecture, physics, engineering and cultural 

inclusiveness) to advancements in publicly usable technologies or advancements in 

equipment available to law enforcement personnel and first responders that does not cost 

millions of dollars, granting Gonzalez Marketing, LLC exemption request substantially

furthers the public's interest in ways known and currently unknown. 

V. Reasons Why Gonzalez Marketing, LLC Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To 

Existing Rule: 

Gonzalez Marketing, LLC exemption will not adversely affect safety. Quite the contrary, 

for the reasons stated, supra, permitting Gonzalez Marketing, LLC to log more flight time 

in FAA controlled airspace will allow Gonzalez Marketing, LLC to innovate and 

implement new and as of yet undiscovered safety protocols. In addition, Gonzalez 

Marketing, LLC submits the following representations of enhancements to current aerial 

motion picture capture techniques: 

• Gonzalez Marketing, LLC UASs weigh less than 15 pounds complete with GoPro Hero 

 4+ camera; 

• Gonzalez Marketing, LLC only operates its UASs below 300 feet (well within the 400 

 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); 

• Gonzalez Marketing, LLC UASs only operate for 10-15 minutes per flight;

• Gonzalez Marketing, LLC lands its UASs when they reach 25% battery power;

• Gonzalez Marketing, LLC remote control pilots operate Gonzalez Marketing, LLC 

 UASs by line of sight; 

• Gonzalez Marketing, LLC remote control pilots have video backup should they

 somehow lose sight of the UAS; 

• Gonzalez Marketing, LLC staffs each flight with a remote control pilot, technician and 

 spotter with communication systems enabling real time communication between them;
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

• Gonzalez Marketing, LLC UASs have GPS flight modes whereby they hover and then 

 slowly land if communication with the remote control pilot is lost or battery power is 

 below 25%;

• Gonzalez Marketing, LLC actively analyzes electronic flight data and other sources of 

 information to constantly update and enhance safety protocols;

• Gonzalez Marketing, LLC only operates in secured areas that are strictly controlled, are 

 away from airports and populated areas;

• Gonzalez Marketing, LLC conducts extensive briefings prior to flight, during which 

 safety carries primary importance; 

• Gonzalez Marketing, LLC always obtains all necessary permissions and permits prior to 

 operation;

• Gonzalez Marketing, LLC has procedures in place to abort flights in the event of safety 

 breaches or potential danger. 

Gonzalez Marketing, LLC provides a level of safety at least equal to existing rules, and in 

nearly every instance, greater than existing rules. It is important to note that absent the 

integration of commercial UASs into our national airspace system, helicopters are the 

primary means of aerial motion picture capture. While the safety record of such 

helicopters is remarkably astounding, it is far safer to operate a battery powered 

lightweight UAS. 

 First, the potential loss of life is diminished because UASs carry no people on 

board and Gonzalez Marketing, LLC only operates them in specific areas away 

from mass populations. 

 Second, there is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished. 

 Third, the small size and extreme maneuverability of Gonzalez Marketing, LLC

UASs allow our remote control pilots to avoid hazards. 

 Lastly, given their small size and weight, even when close enough to capture 

amazing images, Gonzalez Marketing, LLC UASs need not be so close to the 

objects they are focused on. 

Accordingly, Gonzalez Marketing LLC UASs have operated and will continue to operate 

at and above current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The 

Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation to 

FAR § 91.203(a)(l). The size, weight and enclosed operational area of Gonzalez 
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

Marketing LLCs UASs permits exemption from Part 21 because Gonzalez 

Marketing LLC UASs meet an equivalent level of safety pursuant to Section 3 3 3 

of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt U ASs from the airworthiness certificate requirement in consideration of 

the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. Gonzalez Marketing LLC UASs meet or exceed each of 

the elements. 

14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the F ARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no pilots or passengers, and given the size of the UASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

manual at the flight operations center. The FAA has previously issued exemptions 

to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as 

Gonzalez Marketing LLC UASs utilize electronic global positioning systems and 

internal gyroscopes to provide spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining 

such certifications and registrations at the Gonzalez Marketing LLC flight 

operations center. 

 B. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-

-commercial operations. Gonzalez Marketing LLC can achieve an equivalent 

level of safety as achieved by current regulations because it’s UAS does not carry

any pilots or passengers. Further, while helpful, a pilot license will not ensure

remote control piloting skills. The risks attended to the operation of Gonzalez 

Marketing LLC UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing Gonzalez Marketing 

LLC to operate it’s UAS meet and exceed current safety levels in relation to 14 

C.F.R. §61.113 (a) & (b).
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. Gonzalez 

Marketing LLC UASs will never operate at an altitude greater than 400 AGL. 

Gonzalez Marketing LLC will, however, operate its UASs in cordoned off areas 

with security perimeters, providing a level of safety at least equivalent to those in 

relation to minimum safe altitudes. Given the size, weight, 7 maneuverability and 

speed of Gonzalez Marketing LLC UASs, an equivalent level of safety will be 

achieved. 

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

Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to "have [the] 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." 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Gonzalez Marketing LLC UAS should its requested exemption be 

granted. 

Gonzalez Marketing LLC conducts an extensive maintenance program that involves 

regular software updates and constant inspection for assessment of any damaged 

hardware. Therefore, an equivalent level of safety will be achieved. Gonzalez Marketing 

LLC has researched and developed its own designs.

In Summary, Gonzalez Marketing LLC seeks an exemption from the following 

Regulations: 

14 C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 

91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.P.R. § 91.409 (a)(2); 14 C.P.R. § 

91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) & (b) to commercially operate small 

unmanned vehicles and lightweight unmanned aircraft vehicles in motion picture or 

television operations, to conduct its own research and to develop economic platforms for 

law enforcement I first responders, search and rescue. Granting Gonzalez Marketing LLC 

request for exemption will reduce current risk levels and thereby enhance safety. 

Currently, motion picture image capture relies primarily on the use of larger aircraft 

running on combustible fuel. Gonzalez Marketing LLC craft do not contain potentially

explosive fuel, are smaller, lighter and more maneuverable than conventional motion 

picture aircraft. Further, Gonzalez Marketing LLC operates at lower altitudes and in 

controlled airspace. Gonzalez Marketing LLC has been analyzing flight data and other 

information in compiling novel safety protocols and the implementation of a flight 
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Gonzalez Marketing LLC, Anchorage, AK – Section 333 Exemption Petition

operations manual that exceeds currently accepted means and methods of safe flight. 

There are no people on board Gonzalez Marketing LLC UASs and therefore the 

likelihood of death or serious bodily injury is significantly limited. Gonzalez Marketing 

LLC operation of its UASs, weighting less than 55 pounds and traveling at speeds lower 

than 50 knots in cordoned off areas will provide at least an equivalent level of safety as 

that achieved under current F ARs. Gonzalez Marketing LLC respectfully requests that 

the FAA grant its exemption request without delay. The FAA has the authority to issue 

the exemption sought by Gonzalez Marketing LLC pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act").

Respectfully, 

Stephen L. Gonzalez

Member, Gonzalez Marketing LLC

4450 Cordova Street Suite 110

Anchorage, AK 99516