U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re : Exemption Request Under Section 333 of the FA A Reform Act and Part 11 of F AR

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 quad ro copter 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 S ystem for aerial photography and video . The DJI Phantom 3 Professional is a compact, batte ry 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.

T he 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 contr olled 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

Aviati on 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

, an d other flights that could be performed safely and less costly by using small UAS at low altitude within the U.S. National Airspace S ystem 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 l egally as a small business to cater mostly to real estate agents and other outdoor events

. Re al estate agents are not permitted to use

UAS's f or hire unless they possess or hir e someone who holds an FAA Airme n certificate. Felipe

Jaramil lo holds FAA Private Pilot Airme n 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 cons iderably less than 55 pounds including camera s and batteries . The s UAS will be used at speeds under 100 m ph by statue, however the drone is only capable of 35mph due to

the limited performance figures of the s UAS. The DJI drone is designed to hover and ta ke 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 Jaramill o 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 s UAS 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 limit s to ensure this

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

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

minutes flight time . It will fly no more than 1 6 minutes maximum at a time. This is to maintain a

minimum 30% battery reserve during landing. The am ount of t ime the UAS will be in the air is

minimal.

A Safety system is in place for Felipe Jaramillo s UAS , including GPS mode s that allows the

s UAS to auto

- return home if communication link is lost. Further more, the GPS module allows

the s UAS to return ba ck to its launched position if the battery life and other critical components

of the s UAS is be low target range.Ground Station :

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

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

PIC. A 2.4GHz radio telemetry transmitter/controller opera ted by the PIC to control the U AS

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 s UAS, 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

fr om 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 cu stomers use helicopters and small pla nes 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 s UAS all ows fut ure generations of realtors and other third parties to be able to afford the service.

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

Situational awareness is of upmost importance . The areas where Felipe Jara millo 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 s UAS, 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 s UAS with the appropriate exemptions for flying a small UAS. DJI Innovations checklist is attached as PDF file. A preflight checkl ist

will be used and employed to ensure that the s UA S airworthiness status is verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, radio checks, and maintainin g 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 s UAS will not be operated in a reckless manner that would enda n ger people in the ground

.

• sUAS will not be flown over densely populated crowds.

• The s UAS will not be operated at air shows

.

• The s UAS will not be ope rated within 5 miles of an airport unless proper authorization

from controlling Air Traffic Control agency is given.

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

• s UAS 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 onl y 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 risk s involved befo re 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 s UAS does not pose a safety of flight issue.

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

• Pre

- flight inspect ion will include items such as checking the battery level of Aircraft, Controller, Aircraft Status, Radio Range Check, and other ite ms relating to safety of flight as per manufacturer recommendations.

• Follow flight guidelines as per DJI training manual.

• Th e 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 capi talize 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 s UAS as a small bus iness within the safety parameters of the FAA, can help small businesses promote growth in the economy for this new industry in the 21 st

century

.

Summary:

Felipe Jaramillo Aragon is petitioning FAA 333 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 com mercially.C ontact information of the applicant i s provided below:

Felipe Jaramillo Aragon

11028 107 th St, 2 nd FL Ozone Park, NY 11417

United States

Phone: +1 (917)

- 561

- 4793

Email: felipejaramillo1@aol.com

Felipe Jaramillo r espectfully requests that the FA A grant its exemption request without delay.

I look forward to working together with you. Thank you for your time.

Best

, Felipe Jaramillo Aragon