FAA Exemption Rule Making Section 333 of the 

FAA Reform Act and Part 11

Prepared by Waner Del Rosario 

D/B/A Eyes Over Paradise (a sole proprietorship) 

239-677-4903 / eyesoverparadise@gmail.com

11/20/2015
Waner Del Rosario d/b/a Eyes Over Paradise – UAV Petition for Exemption

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Waner Del Rosario

d/b/a Eyes Over Paradise

1350 Monroe St

#2823

Fort Myers, FL 33902

239-677-4903/ eyesoverparadise@gmail.com

FAA Issued Private Pilot Certificate: Issue Date 05/20/2014

Attention: United States Secretary of Transportation

Mr.Anthony R. Foxx 

1200 New Jersey Ave, SE

Washington, DC 20590 

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

Federal Aviation Regulations from 14 CFR 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); 91.409 (a) (2); 91.417 (a) & (b)

Dear Mr. Secretary,

Pursuantto Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and

14 CFR Part 11, Eyes Over Paradise, a Company and operatorof Small UnmannedAircraft Systems

(“sUAS”) equipped to conduct Aerial Data Collection, Marketing, Private Social Events, Real

Estate Inspection and surveying, construction inspections, agriculture, and education 

operations, hereby applies for an exemption from the listed Federal Aviation Regulations

(“FARs”) to allow commercial operation of its sUAS, so long as such operations are conducted

within and underthe conditions outlined herein or as may be established by the FAA as required

by Section 333.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)

limited 2) predetermined and 3) controlled as to access. Approval of this exemption would

thereby fulfill the Secretary of Transportation’s(the responsibilitiesto “...establish requirements

for the safe operation of such aircraft systems in the national airspace system.” Section 333 (c)

of the Reform Act.

Waner Del Rosario, d/b/a Eyes Over Paradise, respectfully requests the FAA to determine that 

good cause exists to dispense with publication of the summary of this 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.
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The name and address of the applicant is:

Waner Del Rosario

d/b/a Eyes Over Paradise 

Phone: 239-677-4903 

Email: EyesOverParadise@gmail.com

1350 Monroe St #2823 Fort Myers, FL 33902

Regulationsfrom which the exemption is requested:

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333

(a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider

whether certain unmanned aircraft systems may operate safely in the national airspace system

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In

making this determination, the Secretary is required to determine which types of UASs do not

create a hazard to users of the NAS or the public or pose a threat to national security in light of

the following:

• The UAS’s size, weight,speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas;

• Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers.
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Reform Act §333 

(a). Lastly, if the Secretary determinesthat such vehicles “may operate safely in the national

airspace system, the Secretary shall establish requirementsfor the safeoperation of such

aircraft in the national airspace system.” Id. §333 (c) (emphasis added). The Federal Aviation

Act expressly grantsthe FAA the authority to issue exemptions. This statutory authority by its

termsincludes exempting civil aircraft, as the term is defined under §40101 of the Act; that

includes sUASs, from the requirementthat all civil aircraft must have a current airworthiness

certificate. The Administratormay grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if

the Administratorfinds the exemption in the public interest. 49 U.S.C. §44704; 14 CFR §91.203

(a) (1).

Eyes Over Paradise’sUAS(s) are DJI’s Phantom 3 Professional, weighing less than 10 lbs including

payload. We operate their rotorcraft, under normal conditions at a speed of no more than 31

knots, usually 3-5 knots, and have the capability to hover, and move in the vertical and horizontal

plane simultaneously.We will manually operate only in Visual Line of Sight and will operate only

within the operating parameters as described in the section titled “Flight” Operating Manual

attached as Attachment 3.

Adherence to the Operating Manual will insure that the UAS will “not create a hazard to the

national airspace system or the public.” A pre-flight will be conducted to confirm the sUAS is 

airworthy and free of defects and mechanical issues. All persons involved in the flight will be 

briefed on safety procedures. Each and every flight will have a predetermined flight path, or 

area of flight.

Given the small size and weight of the sUAS involved and the restricted sterile environment

within which they will operate, the applicant falls squarely within that zone of safety (an

equivalentlevel of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due to the size of the UASs and

the areas in which the relevant sUAS will operate, approval of the application presents no

nationalsecurity issue. Given the clear direction in Section 333 of the Reform Act, the authority

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety,

surrounding the proposed operations, and significant public benefit, including enhanced safety,

reduction in environmental impact, including reduced emissions associated with allowing UASs

for educational and marketing operations, (as opposed to full scale aircraft), the granting of the

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests

that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposesthat the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for

at least an equivalent or possibly higherlevel of safety to operations under the currentregulator
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structure because the proposed operationsrepresent a safety enhancementto the already safe

filming operations conducted with conventional aircraft. These limitations and condition to

which Eyes Over Paradise agreesto be bound when conducting commercial operations under an

FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. (DJI Phantom 3 weighs 2.82 lbs)

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew

(Spotter/ Observer). 

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be

terminated at 35% battery power reserve should that occur prior to the 20 minute limit. 

4. Flights will be operated at an altitude of no more than 200 feet AGL, though most operations

will be conducted within 100 feet of the ground. A separate CoA will be obtained to operate 

from 200- 400 ft.

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and Spotter / 

Observer. In most cases the third aircrew member will serve as the Safety Officer. 

6. The sUAS Pilot is Waner Del Rosario who is an FAA certificated Private Pilot. (Please see 

attachments for scanned copy of Pilot Certificate.) The spotter (Observer) will be over 18 years 

of age, with a valid drivers’ license.

7. The sUAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder, other than the

sUAS Pilot, possessesthe necessaryPIC qualifications and is also present,that person can also be

designated as PIC.

8. The sUAS will only operate within an area as defined in the Manual section “Flight Limits and 

No Fly-Zones”. Additionally,the sUAS will only operate under 200ft AGL, and outside a 5 statute 

mile radius of any airport. The sUAS will never enter any MOA or Restricted Airspace, nor shall it

violate any TFR as outlined by the FAA. The Restrictions set by the FAA will supersede any 

restrictions set in the Manual. A spate COA will be applied for operations above 200ft and below 

400AGL. The sUAS will never fly above 400ft AGL.

9. A pre-flight briefing will be conducted in regard to the planned sUAS operation prior to each

day’s flying / recording activities. It will be mandatory that all personnel who will be performing

duties as “flight crew” be present for this briefing. 

10. The Operator will obtain the consent of all persons involved in the filming and ensure that

only consenting persons will be allowed within 100 feet of the flight operation, and this radius

may be reduced to 30 feet based upon an equivalent level of safety determination.
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11. Pilot, and Spotter (Observer) will have been trained in operation of sUAS generally and

received up-to-date information on the particularsUAS to be operated.

12. Spotter (Observer) and Pilot will at all times be able to communicate by voice.

13. Written and/or oral permission from the relevant property holders will be obtained. 

14. If the sUAS loses communicationsorlosesits GPS signal,the UAS will have capability to return

to a pre-determined location and land. 

15. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section

333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement

capability, and proximity to airports and populated areas of the particular UAS. In all cases, an

analysis of these criteria demonstrates that the UAS operated without an airworthiness

certificate, in the restricted environment and under the conditions proposed will be at least as

safe, or safer, than a conventional aircraft (fixed-wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 6.5 lbs. fully loaded, carries either a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a limited radius area as set out in the pre-flight briefing / VLOS operations. Unlike other

civil aircraft, operations under this exemption will be tightly controlled and monitored by both

the Operator, pursuant to safety requirements, and under the requirements and in compliance

with local public safety requirements,to provide security forthe area of operation asis now done

with conventional aircraft. These safety enhancements, which already apply to civil aircraft

operated in connection with video production, provide a greater degree of safety to the public 

and property owners than conventional operations conducted

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly,

application of these same criteria demonstrates that there is no credible threat to national

security posed by the UAS, due to its size, speed of operation, location of operation, lack of

explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:
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When marks include only the Roman capital letter “N” and the registration number is displayed

on limited,restricted or light-sport category aircraft or experimentalor provisionally certificated

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit,

or pilot station, in letters not lessthan 2 inches nor more than 6 inches high,the words “limited,”

“restricted”, “light-sport,” “experimental,” or “provisional,” as applicable.

Even though the UAS will have no airworthiness certificate, an exemptionmay be needed as the

UAS will have no entrance to the cabin, cockpit or pilotstation on which the word “Experimental”

can be placed. Given the size of the sUAS, two-inch lettering will be difficult. The word 

“Experimental” will be placed on the fuselage in compliance with §45.29 (f)

If the FAA rules that an N-Number be required for sUAS operation the lettering will be written as 

large as possible on all units.

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as

required by §45.29 (f) where the Pilot, Spotter (Observer) and others working with the sUAS will

see the identificationof the UAS as “Experimental.” The FAA hasissued the following exemptions

to this regulation to ExemptionsNos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations – Pilot in Command (PIC)

Sections 61.113 (a) & (b) limit private pilotsto non- commercial operations. Because the UAS will

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of

safety of current operations by requiring the PIC operating the aircraft to have a sport pilot’s

license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional

aircraftthat carriesthe pilot and passengers,the sUAS is remotely controlled with no living thing

on board. The area of operation is controlled and restricted, and all flights are planned and

coordinated in advance as set forth in the Operating Manual. The level of safety provided by the 

requirementsincluded in the Operating Manual meetsthat provided by single individual holding

a commercial pilot’s certificate operating a conventional aircraft. The risks associated with

commercial operations contemplated by Part 61 when drafted, that allowing operations of the

sUAS as requested with a Sport’s Pilot Certificate as the PIC exceeds the present level of safety

achieved by 14 CFR §61.113 (a) & (b). Waner Del Rosario is a Certificated Airman with an FAA 

issued Private Pilot Certificate. Date of issue is 05/2014. A copy of the License is attached.

14 CFR §91.7 (a): Civil Aircraft Airworthiness

The regulation requiresthat no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, this exemption

should be granted, no FAA regulatory standard will exist for determining airworthiness.Given

the size of the aircraft and the requirements contained in the Operating Manual for 

maintenance and use of safety checks prior to each flight, as set forth in the Operating Manual,

an equivalent level of safety will be provided.
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14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: 

U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual,

approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on

the aircraft, not only because there is no pilot on board, but because there is no room or capacity

to carry such an item on the aircraft.

The equivalentlevel ofsafety will be maintained by keeping the OperatingManual at the ground

control point where the pilot flying the sUAS will have immediate accessto it. The FAA hasissued

the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A,

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

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the

safety of flight. As FAA approved rotorcraftflight manuals will not be provided for the aircraft an

exemption will be needed. An equivalent level of safety will be provided as set forth in the

Operating Manual. The PIC will take all actions including reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight.

14 CFR §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. SUASs and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicateswith

the aircraft via radio communications. The FAA has approved exemptions for flight training

without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety

provided by the fact that aircraft will be piloted by a certificated Private Pilot who has previously

trained in remote flight areas before attempting flight within filming distance of any vessel, 

vehicle, or structure.
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14 CFR §91.119: Minimum Safe Altitudes

Section 91.119 establishessafe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicoptersto be operated at lessthan the minimums prescribed, provided the person operating

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this

exemption is for a sUAS, Eyes Over Paradise requests authority to operate at altitudes up to 200

ft. AGL; an exemption may be needed to allow such operations. As set forth herein, the UAS will

never operate at higher than 200 ft. AGL. It will however be operated in a controlled area where

buildings and people will not be exposed to operations withouttheir pre-obtained consent. Eyes 

Over Paradise understands that a separate COA will be needed to fly above 200 but below 400 

ft AGL. The sUAS will never operate above 400ft AGL.

The equivalentlevel of safety will be achieved given the size, weight,speed of the UAS as well as

location where it is operated. No flight will be taken without the permission of the property

owner. Because of the advance notice to the property owner and participants in the 

photographic activity, all affected individuals will be aware of the planned flight operations as

set forth in the Operating Manual. Compared to flight operations with aircraft or rotorcraft

weighing far more than the maximum 5 lbs. proposed herein and the lack of combustible fuel,

any risk associated with these operations is far less than those presently presented with

conventional aircraft operating at or below 500 ft. AGL. In addition, the low-altitude operations

of the sUAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeterthatis set “...to the elevation ofthe departure airport or an appropriate

altimeter setting available before departure.” As the sUAS will not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety

will be achieved by the operator, pursuant to the Operating Manual and Safety Check list, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR §91.151 (a): Fuel Requirementsfor Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions)there is enough fuel to fly

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 25 minutes of powered flight. To meet

the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be difficult to 

impossible with today’s consumer technology.Given the limitationson the UAS’s proposed flight
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area and the location of its proposed operations within a predetermined area, a longer time

frame for flight in daylight or night VFR conditionsis reasonable.

Petitioner believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

compliancewith FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only

people and property owners or official representativeswho have signed waivers will be allowed,

with less than 30 minutes of reserved fuel, does not engenderthe type of risks that

Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS.

Additionally, limiting sUAS flights would greatly reduce the utility for which the exemption will

be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20

minutes or 35% of battery power whichever happens first. This restriction would be more than

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating

area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,

10673, and 10808.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation providesin pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it

the following:

(1) An appropriate and current airworthiness certificate... (b) No person may operate a

civil aircraft unless the airworthiness certificate required by paragraph (b) of this section

or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 6.5 lbs. and is operated without an onboard Pilot. As

such, there is no ability or place to carry certification and registration documents or to display

them on the sUAS.

An equivalentlevel of safety will be achieved by keeping these documents at the ground control

point where the Pilot flying the sUAS will have immediate accessto them, to the extent they are

applicable to the sUAS, and should they be issued. The FAA has issued numerous exemptionsto

this regulation. A representative sample of other exceptions includes Exemption Nos. 9565,

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
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14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that 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...,” and othersshall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator; pursuant to the Operating manual. An equivalent level of safety will be achieved

because these small UASs are very limited in size and will carry a small payload and operate only

in restricted areas for limited periods of time. If mechanical issues arise the UAS can land

immediately and will be operating from no higherthan 400 ft. AGL. As provided in the Operating

Manual, the PIC (operator) will ensure that the UAS is in working order prior to initiating flight, 

and perform requiredmaintenance.Moreover,the operatoris the person most familiar with the

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

equivalentlevel of safety.

********* 

Pursuant to 14CF R, summary is provided for publication in the Federal Register, should it be

determined that publication is needed:

Applicantseeks an exemption from the following rules:

 

14 CFR § 21,subpart H; 14 CFR § 45.23 (b); 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) and 91.417 (a) & (b) to operate commercially or for hire, a small unmanned

vehicle (6.5lbs or less) in Aerial Data Collection, Marketing, Private Social Events, Real Estate

Industry, Construction, inspection, agriculture, and education operations.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior

consent and knowledge, or over remote public land. Image capture of people will rarely take

place, but in the event they are, they will have consented prior to being filmed or otherwise

have agreed to be in the area where data collection will take place.

Flight Operations and Public Benefit

With regard to airborne filming, Eyes Over Paradise adheresto all FAA regulations. Further, Eyes 

Over Paradise’s airborne teams operate under the principal of: “Safety Above All Else” When 
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approved by the FAA it is Eyes Over Paradise’s mandate to treat all sUAS operations the exact

same level of professionalism and gravity as that of conventional aircraft.

Approval of exemptions allowing commercial operations of sUAS for aerial data collection 

operations will enhance safety by reducing risk. Conventional filming operations, using turbine 

or piston powered aircraft present the risks associated with vehicles that weigh in the

neighborhood of 2,000lbs.+, carrying large amounts of Jet A or 100LL. Such aircraft must fly to

and from photographing location. In contrast, a sUAS weighing fewerthan 10lbs and powered by

batteries eliminates virtually all of the risk given the substantial reduced mass and lack of

combustible fuel carried on board. The sUAS is typically transported to the location via land 

motor vehicle and never flown to the set. The sUAS will carry no passengers or crew and,

therefore, will not expose them to the risks associated with manned aircraft

The operation of small sUAS, weighting less than 10lbs., conducted in the strict conditions

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions

requested herein, including exempting the applicant from the requirements of Part 21 and

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the

ground, and in a sterile environment and, as a result, are far safer than ground than conventional

operations conducted with piston helicopters or fixed wing aircraft operating in relatively close

proximity to the ground and people.

It is anticipated that the airborne data collection will be accomplished exclusively in day time VFR

environments. 

Summary

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight,

speed, operating capabilities, proximity to airports and populated areas and operation within

visual line of sight and nationalsecurity – provide more than adequate justification for the grant

of the requested exemptions allowing commercial operation of the petitioner’ssUAS operations 

in the Aerial Data Collection, Marketing, Private Social Events the real estate industry, 

construction, inspection, agriculture, and education fields, pursuant to the Operating Manual

appended hereto. Eyes over Paradise is eagerly standing by to support the FAA and sUAS

community in its quest to establish properregulations and protocolsfor the safe introduction of

unmanned aircraft into the national airspace.

Submitted Respectfully,

Waner Del Rosario

d/b/a Eyes Over Paradise

1350 Monroe St

#2823

Fort Myers, FL 33902

239-677-4903

EyesOverParadise@gmail.com
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Attachments:

• Waner Del Rosario – FAA Issued Private Pilot Certificate

o Contains confidential information. Sending to secure email (also searchable through 

FAA Airman’s lookup website)

• Waner Del Rosario – FAA Issued Medical Certificate

o Contains confidential information. Sending to secure email

• DJI Phantom 3 User Manual

o https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_

Manual__V1.6.pdf