U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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

January 20, 2016

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, Felipe Jaramillo Aragon, seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for a DJI Phantom 3 quadrocopter manufactured by DJI 

Innovations.

The requested FAA 333 exemption would support an application of this drone for commercial 

usage using a Certificate of Authorization to use the National Airspace System for aerial 

photography and video. The DJI Phantom 3 Professional is a compact, battery operated 

quadcopter, which uses a tablet ground based control station and 2.4GHz RC Controller, as well 

as other communications equipment. The aircraft carries an onboard six-axis gimbaled camera 

that allows it to capture photography and videography.

The Unmanned Aircraft System will be operated with a PIC in accordance with FAA Policy N

8900.227 Section 14 "Operational Requirements for UAS". Felipe Jaramillo requests the grant of 

exemption which allows use of lightweight, remote controlled UAS's operations lawfully and 

safely under this provision.

Felipe Jaramillo also respectfully requests Exemption Request Section 333 from (but not limited 

to) the Specific Sections of Title 14 of the Code of Federal Regulations and part ll of the Federal 

Aviation Regulations listed below.

• 14 CFR Part 21; 

• 14 C.F.R.45.23(b); 

• 14 CFR 61.113 (a) & (b); 

• 91.7 (a); 

• 91.417 (a) & (b)

• 91.119; 

• 91.9

• (b) (2);

• 91.103(b); 

• 91.109; 

• 91.121- 91.151(a); 

• 91.203(a) & (b);

• 91.405 (a); 

• 91.407(a) (1); 

• 91.409 (a) (2); 
The reason Felipe Jaramillo seeks exemption:

Felipe Jaramillo is seeking relief from any applicable FARs that prevent Felipe Jaramillo from

conducting aerial real estate photography and other possible legal flight operations such as

cinematography, videography, mapping, surveying, inspections, and other flights that could be

performed safely and less costly by using small UAS at low altitude within the U.S. National 

Airspace System when compared to heavy, fossil fuel burning, noise polluting, manned aircraft. 

The weight of the UAS meets the definition of ''small unmanned aircraft” found in section 331 of 

the "The Reform Act”. Felipe Jaramillo seeks to operate legally as a small business to cater 

mostly to real estate agents and other outdoor events. Real estate agents are not permitted to use 

UAS's for hire unless they possess or hire someone who holds an FAA Airmen certificate. Felipe 

Jaramillo holds FAA Private Pilot Airmen Certificate with Instrument Rating, Third Class 

Medical, and Drivers License. The applicant has experience flying Model Aircraft under the 

AMA code since 2011 and is highly proficient using DJI products.

Felipe Jaramillo would assure safe and affordable aerial photography. The DJI Innovations 

drones weigh considerably less than 55 pounds including cameras and batteries. The sUAS will 

be used at speeds under 100 mph by statue, however the drone is only capable of 35mph due to

the limited performance figures of the sUAS. The DJI drone is designed to hover and take 

pictures using GPS holding, which further adds to flight safety. The DJI Phantom 3 has been 

approved commercially under many other FAA 333 exemptions. The Phantom 3 posses many 

safety sensors which aid to situational awareness including many failsafe’s, auto return to home, 

virtual fencing, altitude limits, intelligent flight controls, vision positioning system, compass, live 

maps, LED indicators, and other sensors. Specifications for the DJI Phantom 3 are attached in a 

separate PDF file. Felipe Jaramillo also seeks to use future DJI products and/or other 

commercially qualifying quadcopters approved by the FCC such as the DJI Inspire, which shares 

many characteristics and flight control user interface with the DJI Phantom 3.

The sUAS will be flown below 400 ft AGL in accordance with the 400 ft maximum altitude 

limit. The UAS carries altitude sensors (Barometer) and Software Altitude limits to ensure this 

rule is followed. The UAS utilizes battery power for all its operations. There are no combustible 

fuels used in the sUAS that Felipe Jaramillo uses. The maximum flight time for our UAS is 23

minutes flight time. It will fly no more than 16 minutes maximum at a time. This is to maintain a 

minimum 30% battery reserve during landing. The amount of time the UAS will be in the air is 

minimal.

A Safety system is in place for Felipe Jaramillo sUAS, including GPS modes that allows the 

sUAS to auto-return home if communication link is lost. Furthermore, the GPS module allows 

the sUAS to return back to its launched position if the battery life and other critical components 

of the sUAS is below target range.
Ground Station:

A Pilot in Command (PIC) will maintain operational control of flight operations from beginning 

to end. Additionally, the line of site of the sUAS will not leave the sight of the

PIC. A 2.4GHz radio telemetry transmitter/controller operated by the PIC to control the UAS

will be used throughout all phases of flight and is certified by the FCC.

A visual radio receiver aid “live video”, and flight data from the onboard computer will also be 

used to help situational awareness.

The sUAS, weighs less than 4 lbs when fully loaded, is powered by batteries only, and operates 

with no people on board. This lowers the likelihood of death or serious bodily injury. With such 

a small payload consisting of harmless electronics such as a camera and GPS, the sUAS’ 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 will be able to show the layout of properties with the advantage of multiple angles which 

traditionally would require a full size helicopter.

Current customers use helicopters and small planes for this purpose; however, the cost of fuel, 

time, and CO2 emissions of such aircraft is not efficient enough for most customers to afford.

The benefits of reduced cost and improved efficiency of the sUAS allows future generations of 

realtors and other third parties to be able to afford the service.

Felipe Jaramillo will not operate a sUAS near airports and generally does not fly over crowds. 

Situational awareness is of upmost importance. The areas where Felipe Jaramillo conducts aerial 

photography is predetermined using FAA sectional maps, after carefully reviewing No Fly 

Zones, Weather conditions, and appropriate preflight action. This allows us to maintain a 

controlled environment at all times and thus to operate safely.

Allowing Felipe Jaramillo to conduct business with a light weight sUAS, could very well help 

the economy, reduce manned aircraft pollution emissions, aid safety, and is in the public’s best 

interest. 

Felipe Jaramillo is more than willing to follow the safety guidelines of the FAA Policy 

N 8900.227 Section 14 "Operational Requirements” for sUAS with the appropriate exemptions 

for flying a small UAS. DJI Innovations checklist is attached as PDF file. A preflight checklist 

will be used and employed to ensure that the sUAS airworthiness status is verified before launch. 

Airworthiness will be maintained by performance of routine inspections before each flight, radio 

checks, and maintaining maintenance logs.

Furthermore:

• No flight will be made with a UA Gross weight exceeding 55lbs

• We will always have Visual Line of Sight (VLOS).

• All required permits will be obtained.
• The sUAS will not be operated in a reckless manner that would endanger people in the 

ground.

• sUAS will not be flown over densely populated crowds.

• The sUAS will not be operated at air shows.

• The sUAS will not be operated within 5 miles of an airport unless proper authorization 

from controlling Air Traffic Control agency is given.

• The sUAS will not be operated above 400 ft AGL under any circumstances.

• sUAS will always give right of way to manned aircraft.

• NOTAMS and COA will be followed accordingly.

• METARS and TAF will be obtained before each flight.

• Operations will be restricted to day only and VFR weather conditions as per statue. (2000 

ft horizontal, 1000 ft above, 500 ft below)

• The PIC will notify, give a privacy and safety briefing to any third parties involved 

regarding the operation and risks involved before the first flight at each location.

• No flight may be made without a Pre-Flight Inspection by the PIC before each operation

as to ensure the sUAS does not pose a safety of flight issue.

• Additionally, the equipment will be checked thoroughly every 100 flight hours.

• Pre-flight inspection will include items such as checking the battery level of Aircraft, 

Controller, Aircraft Status, Radio Range Check, and other items relating to safety of 

flight as per manufacturer recommendations.

• Follow flight guidelines as per DJI training manual.

• The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight 

operations”. The reason for such a general and broad based request is that the petitioner 

wishes to utilize a business strategy of horizontal integration and thus maximize 

economies of scope in order to capitalize on new opportunities as the needs may arise in

the future without the requirements of long turnaround time associated with acquiring

additional exemptions.

Our operations listed above are the minimum we are bound by, however, we seek to go above 

and beyond these minimum safety standards. Safety is of upmost importance and with that said, 

we have a great compromise to our fellow citizens.

We are also more than willing to follow any additional safety requirements if not listed above.

Felipe Jaramillo believes flying its sUAS as a small business within the safety parameters of the 

FAA, can help small businesses promote growth in the economy for this new industry in the 21st

century.

Summary:

Felipe Jaramillo Aragon is petitioning FAA333 exemption for 14 CFR Part 21; 14 

C.F.R.45.23(b); 14 CFR 61.113 (a) & (b); 91.7 (a); 91.417 (a) & (b)91.119; 91.9(b) 

(2);91.103(b); 91.109; 91.121~91.151(a); 91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 

(a) (2); to conduct sUAS aerial photography and videography commercially.
Contact information of the applicant is provided below:

Felipe Jaramillo Aragon

11028 107th St, 2nd FL

Ozone Park, NY 11417

United States

Phone: +1 (917)-561-4793

Email: felipejaramillo1@aol.com

Felipe Jaramillo respectfully requests that the FAA grant its exemption request without delay.

I look forward to working together with you.

Thank you for your time.

Best,

 Felipe Jaramillo Aragon