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 the 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 (hereinafter petitioner or operator) 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 exists for 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 Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for 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 material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

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

 They are similar in all material respects to relief previously requested 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 situation 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 in the 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 petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, Luxury Aerial Shots, LLC is hereafter referred to as the operator. 
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Failure to comply with any of the conditions and 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 exemption 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 petition 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 restriction. 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 the 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 PIC 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 permitted 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 ensure 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 between the conditions and 

limitations in this exemption and the procedures 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 revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
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documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised 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 which 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 affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior 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 functional 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. The 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 manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot 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 PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate 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 distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-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 experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants 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 meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility 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 flight 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 the 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 to the 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 essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller 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 Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

If this exemption permits operations for the 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. 
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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-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder 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 than 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 all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

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

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards 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 of the 

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 of properties 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 of reduced 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 U AS 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, 

Bryan 

~A--~ Gonzalez, CEO . 

Luxury Aerial Shots, LLC 

(352) 361-1932