May 8, 2015

Exemption No. 11513 Regulatory Docket No. FAA–2015–0470

Mr. Bryan Gonzalez Chief Executive Officer Luxury Aerial Shots, LLC 6826 Northeast Jacksonville Road Ocala, FL 34479

Dear Mr. Gonzalez:

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

By letter dated February 23, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Luxury Aerial Shots, LLC (hereinaft er petitioner or operato r) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct aerial photography of real estate and other possible flight operations.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause existsfor not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Flamewheel F550.2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification proceduresfor products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pres ented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No. FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gives the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is inthe public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, Luxury Aerial Shots, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e )(4) and (5), 61.113( a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405( a), 91.407(a)(1), 91.409(a)(1 ) and (2), and 91.417(a) and (b), to the extent necessary to allow the pe titioner to operate a UAS to perform aerial data collection. This exemption is subject to th e conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Luxury Aerial Shots, LLC is hereafter referred to as the operator.3

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of ex emption are limited to the DJI Flamewheel F550 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petiti on to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of th e PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not pe rmitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists betweenthe conditions and limitations in this exemption and the pro cedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised4

documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g., replacement of a flight critical component, must undergo a functional test flight prio r to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency mustbe logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available tothe Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on-s cene operation of the UAS; d. Make, model, and serial or N

−Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming; f. A statement that the operator has obtain ed permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;
g. Signature of exemption holde r or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely, /s/ John S. Duncan Director, Flight St andards Service(February 23, 2015)

U.S. Dept. of

**Transportation~** Docket Opemtions
West Building Ground 

### Floor, Room wl2-140
1200 New Jersey Avenue, SE Washington, DC 20590 ; ; Luxury Aerial Shots, LLC

**CEO~** Bryan Gonzalez 6826 NE Jacksonville Rd Ocala, Florida 34479

PH; (352)361-1932

Re: Exemption. Request onder Section 333 of the FAA Refonn. Act and Part 11 of the Federal Aviation Regulations.

Dear Sir or Madam,
Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the ••Reform Act") and 14 C.F.R. Part 11

**~Luxury** Aerial Shots, LLC seeks an exemption from Federal Avi.ation Regulations {"'F

**ARs~;)** detailed below for the foUowing described

**U~anned** Aircraft System

..



### THE UNMANNED AIRCRAFTSYSTEM (UAS) DETAILS:
The manufacturer is DJI. It is model F550 lightweight (5.3 lb gross weight fully

**equipped)~** battery only operated 6 motor craft in the form of a hexacopter that takes off and lands vertically. It has been modified to carry the following equipment in flight;

• An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based 

### tran.smitter/controller.

• An on-board camera capable of capturing images in the form of full color, high definition still photos and videos.

• It is equipped to send flight data from the on-board flight computer to the on-board radio ttansmitter including altitude

**AGL~** horizontal and vertical speed, compass direction of flight and direction back to its launch 

### site.

• A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the onboard camera plus all the flight data from the telemetry 

### system described above.luxury Aerial Shots, LLC

**CEO~** Bryan Gonz.alez 6826 NE Jacksonville Rd Or::ala, !=lorida 34479

PH:

**(352)361~1932**

The Unmanned Aircraft System will be operated in the 

### field with a PIC in accordance with FAA Policy N 8900.227 Secti.on 14 "Operational Requirements for UAS". Luxury Aerial Shots respectfully requests the grant of exemption allowing 

### to operate lightweight, remote controlled UAS's lavvfully and safely. Luxury Aerial Shots also respectfully requests Exempti.on Request Section 333 from (but not limited to) the Specific Sections ofTitle 14 of the Code ofFederaJ Regulations and part ll ofthe Federal Aviation. Regulations listed below.
14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119;

**91.121~** 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)

The extent of relief Luxury Aerial Shots seeks and the reason why: Luxury 

### Aerial Shots is seeking relief 

### from any applicable F ARs operating to prevent Luxury Aerial Shots from conducting low level aerial shots of real estate and other possible legal flight operations. The weight of the UAS meets the definition of''small unmanned aircraft" found in section 331 oC¢The Reform

**Act~'.** Luxury Aerial Shots seeks to operate legally as a small business that caters to real estate agents. Realto:rs are not allowed to use UAS's or hire unless

**they~** or the person they hire, is rulowed by the FAA to fly a VAS. Luxury Aerial Shots would satisfy the need for safe and affordable aerial shots.
At less than 6 pounds, Luxury Aerial Shots uses a UAS that jt considerably Jess than 55 pounds including the camera that is attached. The UAS will be used at speeds under 30mph because of the nature of the business and the limited physical capabilities of the UAS. It is designed to hover 

### and take pictures. 

### The UAS will be in accordance with 

### fl.ying well below 400ft. The UAS in which Luxury Aerial Shots would be using only utilizes battery power for its operations. Ther.e are no combustible fuels used in the UAS that Luxury Aerial Shots uses. The maximum flight time for our particular UAS is 18 minutes battery life. It will fly no more than 15 minutes maximrun at one time at one location. The amount of time the UAS will be in the air, under 400ft, is 

### very minimal.

A Safety system in place for Luxury Aerial Shot's UAS includes a GPS mode that allows the UAS to hover in place 

### if communication is lost. Further, the GPS onboard a11ows the UAS to return back to its launched position 

### if the battery life of the UAS is low. Another safety protocol for Luxury Aerial Shot's UAS is that it can fly and land with :five motors. IF one of the six were to 

### fail, it can rp.ak.e it back safely.1HE GROUND STATION PART OF THE SYSTEM: Luxury Aerial Shots, LLC CEO- Bryan Gonzalez 6826 NE Jacksonville Rd Ocala, Florida 34479

PH: (352)361-1932

• A Pilot in Command (PIC) in operational control of a flight operation from 

### beginnmg to end and who controls the UAS while in the air. Additionally, the line of site ofthe UAS will not leave the sight of the PIC.



### • A 1OOm W, 2.4GHz radio 

### transmitter/controller operated by 

### the PIC to control 

### the U.AS while in flight;

• A radio receiver 

### receiving live video and flight data from the 

### on-board. camera and ·computer. It projects it 

### all 

### in. one screen to 

### the Pilot in Command.

The UAS, weighing less than 6lbs fully loaded, is 

### powered by battedes and operates with no people on 

### board which 

### lowers the likelihood 

### of death or serious bodily injury. 

### With a small payload consisting of harmless electronics such as a camera and GPS, the UAS;s only purpose is to be used as a tool to take pictures and videos.

Low level aerial photos and video from several angles are far more effective than ground based photos. Low level aerial video and pictures show the layout ofproperties with the advantage of seeing more in one photo or short video.

Current applicants have chartered helicopters and small planes for this purpose. As an ex Aviation Logistics Specialist in the U.S. Navy, the cost of fuel, time, and emissions of such aircraft (helicopters and. planes) is not efficient enough for most customers to afford.
The benefits ofreduced cost and improved efficiency of the UAS allows future customers to afford this service with a faster turnaround time at a lesser cost.

**Additionally~** I respectfully request that Luxury Aerial Shots be allowed to use the UAS to benefit possible first responders 

### in. my area for actions that could benefit the public. Such as, forest fires and/or search and rescue.Luxury Aerial Shots, LLC CEO- Bryan Gonzalez 6826 NE Jacksonville Rd Ocala, Florida 34479

PH: (352)361-1932

Luxury Aerial Shots will not operate a UAS near aitports and generally does not fly over crowds. Situational awareness is key. The areas where Luxury Aerial Shots conducts aerial photography is predetermined which allows for a controlled environment to operate safely. With allowing Luxury Aerial Shots to conduct business with a light weight UAS, it could very well help the economy and benefit people in first response situations. Further, Luxury Aeri.al Shot's UAS is considerably lighter than the alternative which is a helicopter or small plane. Currently, Luxury Aerial Shots has only one 

### UAS which 

### only operates off 18 minutes of battery power. Therefore, the UAS used by Luxury Aerial Shots would only have a flight time of 

### 5

- 15 minutes at on.e time. The likelihood of injury or even death with such a small unmanned aircraft, compared to an aircraft 

### fl.o-wn 

### by a person loaded with combustible 

### fuel, is considerably low.



### SUMMARY:

Luxury Aerial Shots is more than willing to follow the safety guidelines of the FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS' 1 with the appropriate exemptions for flying a small UAS.
(a) No flight will be made with a UA Gross weight exceeding 55 poWlds; 

### (b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no tnore than 25 knots and no further than 3/4 NM from the Pilot 

### In Charge; (c) Operations will be restdcted to flights over private property with the permission of the property owner; (d) All required permits will be obtained from state and local government prior to operation; (e) The UAS will not be operated over densely populated areas; (f) The UAS will not be operated at air

**shows~** (g) Th.e UAS 

### wi.JJ not be operated over any open-air assembly of people; (h) The UAS will n.ot be operated over heavily trafficked roads; (i) The UAS will not be operated within 

### 5 NM of an airport or heliport; (j) The UAS will not be operated over properties smaller than two acres in size;
(1<) Operations will be res1ricted to day only and weather conditions equivalent to VFR; (1) The PIC will btiefthe property owner about the operation and risk before the first flight at each new location;Luxury Ael'ial Shots, LLC CEO- Bryan Gonzalez 6S.26 NE Jacksonville Rd Ocala, Florida 34419

PH: {352)361-1932

(m) No flight may be made without a Pre-Flight Inspection 

### by the PIC before each operation to ascertain that the UAS i.s in a condition safe for flight (see Appendix A).



### My operations 

### a.bove, [(a) through (m)], are the bare 

### minimum. safety requirements Luxury Aerial Shots 

### will follow. Luxury Aerial Shots is also more than willing to follow any additi.onal safety requirements 

### if not listed above.

As stated by President Barak Obama 

### i.n .his recent memorandum 

### for the heads of executive departments and ageneies concerning VAS's, published on February 15,2015. "As compared to manned aircraft, UAS may provide lower-cost operation and augment existing capabilities while reducing risks to human life. Estimates suggest the positive economic impact to U.S. industry of the integration ofUAS into the NAS could be substantial and likely will grow for the

**forese~able** future". 

### Luxury Aerial Shots believes flying its UAS as a small

**business~** within the safety parameters of the FAA. can. help people and promote the economy.

The name and contact information of the applicant are: Luxury Aerial Shots, LLC 

### Attn; Bryan Gonzalez

Phone:

**352~361-1932** 

### Email: LuxuryAeriaJShots@hotmail.com or Bgonza8304@live.com
With prior mjlitary experience as an Aviation Logistics Specialist in the Navy, I understand safety is paramount in. dealing with the airspace and the settings below. Please contact me at any time if au;y 

### additi.onal infonnation is needed or any questions transpire. Luxury Aerial Shots respectfully requests that the FAA grant its exemption request without delay. I do look forwar:d to working with you gu,ys. Thank you for your time.

Respectfully,



# ~A--~ Bryan Gonzalez, CEO

. Luxury Aerial Shots, LLC (352) 361-1932