Richard Carranza 

Township Property Management LLC. 

30 Summithill PI 

Spring TX 77381 

February 21 , 2016 

US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. , SE 

Washington DC 20590 

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

Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 

CFR 91 .7(a); 14 CFR 91.9(b)(2); 14 CFR 91 .103; 14 CFR 91.109; 14 CFR 91 .119(c); 14 

CFR 91 .121 ; 14 CFR91.151(a); 14 CFR 91 .203(a) and (b); 14 CFR 91.405 (a); 14 CFR 

91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR91.417(a) and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform 

Act") and 14 CFR Part 11 , Richard Carranza, "Township Property Management LLC" 

operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the 

listed Federal Aviation Regulations ("FARs") to allow commercial operations of designated 

UAS, provided such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would provide professional services in the following manner: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government has requested it by contract or donation. 

6. Training to persons individually or belonging to both private and/or public organizations 

to increase awareness and improve safety for current and future UAS operations within 

the NAS 
As described fully below, the requested exemption would permit the operation of designated 

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would 

increase public awareness of UAS operations and enhance safety to aid in fulfilling the 

Secretary of Transportation's (the FAA Administrator's) responsibilities to "establish 

requirements 

for the safe operation of such aircraft systems in the national airspace system." 

The name and address of the applicant is: 

Richard Carranza "Township Property Management" 

Ph: 832-594-0545 

Email: rcarranza45@gmail.com 

Address: 30 Summithill Pl. 

Spring, TX 77381 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

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 (c) 

14 CFR 91 .121 

14 CFR 91 .151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

Richard Carranza "Town ship Property Management" will operate one or more of the 

following model UAS: 

1. Yuneec Model 0500 Typhoon, specifications to follow below: 

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PRODUCT SPECIFICATIONS 

TYPHOON Q500 4K Aircraft 

Flight Time Up to 25 Minutes 

Height 21 Omm (9.45 in) 

Width 420mm (16.54 in) 

Diagonal length without Rotor Blades 510mm (20 in) 

Propeller/Main Rotor Diameter 330mm (13.0 in) 

Weight with Battery and Payload 60.0 oz (1700g) 

Weight Without Battery and Payload 1130g (40.0 oz) 

BatterY 5400mAh 3S 11 .1 V LiPo 

Charge 3S 11 .1V LiPo DC Balancing Smart Charger 

with AC Adapter 

Transmitter 1 0-channel 2.4GHz with 5.8GHz video 

downlink 

3 Flight Modes Smart, Angle and Home Modes 

Maximum Flyer Height Default 400 Feet Above Ground Level 

(1 22m) (Adjustable via the 0500 GUI) 

Maximum Rotational Velocity 65°/s 

Maximum Roll Angle 35° 

Operating Temperature Range -5° C to 80 co 

Maximum Descent Rate in Smart and 2mls 

Angle Mode 

Maximum Flight Speed 17 mph I 27 kph (Angle Mode), 22 mph I 35 

kph (Follow Me/Watch Me) 

Radio Control Frequency Band 2.4GHz 

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CG03 4k Gimbal Camera System 

Type CG03 

Weight 6.9oz (195g) 

Focusing System Aerial Optimized Fixed Focus 

Video Field of View 115° 

Video Resolution UHD 4K at 30FPS,2. 7K at 30FPS, 2.5K at 

30FPSFULL HD: 1 080p24/25/30/48/50/60/120 

Photo Resolution 12 Megapixels 

Storage {memory) Micro SO Class 10- 4 to 128GB 

Control Angle Accuracy ±0.02 

White Balance Automatic or manual Settings 

Transmission Band 5.8GHz. 

Input/Operating Voltage 12V 

Working Temperature -10° c - 50° c 

Storage Temperature -20° c - 60° c 

Angular Vibration Range ±0.02 

Control Range Pitch: between -90° and oo 

Microphone Yes 

Camera Lens 14 mm f/2.8- no distortion 

Sensor 1 2.3" CMOS 

ST1 0+ Personal Ground Station 

Type ST10+ 

Operating System AndroidTM 

Number of Channels 10 

Control Transmission Range (Optimum FCC Compliance: Up to BOOm (2624.67 ft) 

Conditions) CE Compliance: Up to 400m (1312.34 ft) 

Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at 

All Times. 

Robust Radio Control Modulation 

Yuneec Protocol 

Robust Radio Control Modulation Yuneec Protocol 

Video Link Frequency Band 5.8GHz 

Video Transmission Range (Optimum FCC Compliance: Up to 600m (1968.5ft) CE 

Conditions) Compliance: Up to 300m (984.25 ft) 

Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at all 

Times 

Flight System Telemetry Data on Screen Yes 

Display {OSD) 

LED Backlit LCD Screen Capacitive Multi-touch 5-5" 

Tactile {Vibrating) and Audible Feedback Yes 

Built-in LiPo Battery Voltage /Capacity Yes 3.6v/5200mAh 18. 72Wh 

Screen Resolution 854 x 480px 

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Given the small size of the UAS in scope and the controlled environment provided, the 

proposed operations will adhere to the Reform Act's safety requirements. The approval of 

this application presents no national security issues. Regarding the level of safety 

surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the 

requested exemption is in the public interest. Accordingly, the applicant graciously requests 

that the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because of 

these limitations of our operations, will further enhance the safety of the persons and/or 

property using conventional aircraft. 

1. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the 

Flight Operations Manual (FOM) include: 

2. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with 

battery and camera. 

3. The UAS, depending on the model in operation, will have a maximum operating speed of 

no more than 50mph. 

4. A visual Observer (VO) may be utilized when the Pilot in Command (PIC) deems 

necessary to assist in safe operation of the flight. 

5. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO). 

6. Maximum flight time for each operational flight will be depending on the UAS model in 

operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight time whichever occurs first. 

7. Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned. 

8. Minimum crew for each operation will consist of the UAS Pilot and a Visual Observer 

(VO) that will maintain constant communication during the flight operation. 

9. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a 

minimum of 20 hours on the designated UAS. The (PIC) must hold an Airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will also have a current 

FAA airmen medical certificate. 

10. A safety briefing will be performed prior to each day's UAS operations consisting of all 

the days' production activities. 

11. All flight activities will be logged. 

12. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

13. The flights will occur in Class G airspace no closer than a 5-mile radius of the 

geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport. 

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14. If operations are required to be within a 5 mile radius or the geographical center/Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport. The respective airport 

will be contacted advising them of the estimated flight time, flight duration, elevation of the 

flight and other pertinent information. If requested by the airport manager or ATC Facility, 

a flight service station will be contacted for the appropriate filing of a Notice to Airmen 

(NOT AM) of authorized UAS activities. 

15. The operator will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 1 00 feet of the 

flight operation, and the radius may be reduced to 30 feet based upon an equivalent 

level of safety determination, as U.S. Department of Transportation required under the 

FOM. With the advanced permission of the FSDO, operations at closer range may be 

approved. 

16. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

17. The PIC and VO will be able to communicate by voice and/or radio at all times. 

18. Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies as appropriate to flight operations. 

19. If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously. 

20. The UAS will have the capability to abort a flight in case of emergencies with an 

automated "Return Home and Landn function. 

21 . The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies such as low battery. 

14 C.F.R. Part 21 , Subpart H: Airworthiness Certificates 14 C.F.R. §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 for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational 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 UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured and designated area. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator and 

under the requirements and in compliance with local public safety requirements. These 

safety enhancements provide a greater degree of safety to the public and property owners 

than conventional operations 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. 

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14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 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 exemption may be needed 

as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the UAS, two-inch lettering will be 

impossible. The word "Experimental" will be placed on the fuselage in compliance with 

§45.29 (f). 

US Department of Transportation February 20, 2015 The equivalent level of safety will be 

provided by having the UAS marked on its fuselage as required by §45.29 (f) where the 

pilot, observer and others working with the UAS will see the identification of the UAS as 

"Experimental." 

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Pursuant to 14 CFR 61 .113 (a) & (b), no person who holds a private pilot certificate may 

act as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire. Richard Carranza "Township Property Management" The 

proposed UAS operations may achieve an equivalent level of safety as achieved by current 

Regulations because the applicant's UAS do not carry any pilots or passengers nor 

property. The risks attendant to the operation of UAS is far less than the risk levels inherent 

in the commercial activities outlined in 14 CFR 61 . The PIC of the UAS will be, or be under 

the direct supervision of, a FAA Certificated Private Pilot with current Third Class or higher 

medical certificate. It is believed that the operation and limitations set forth in the FOM will 

equate to the safe operation of the UAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

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

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

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

Given the size of the aircraft for maintenance and use of safety checklists prior to each 

flight, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a 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 UAS, 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 equivalent level of safety 

will be maintained by keeping the flight manual at the ground control point where the pilot 

flying the UAS will have immediate access to it. 

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14 C.F.R. § 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 rotorcraft flight manuals will not be provided for 

the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM 

in Section 4 under Normal Procedures including but not limited to reviewing weather, flight 

battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight 

14 C.F.R. §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. UAS 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 communicates with 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. The equivalent level of safety is provided 

by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size 

and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91 .119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than 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 UAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which filming is planned, an exemption may be needed to 

allow such operations. As set forth herein, the UAS will never operate at higher than 400 

AGL with the exception that in circumstances where the UAS is used to survey or 

photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated 

more than 200 feet above the highest point on the structure. It will however be operated in 

a restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the filming activity, all affected individuals will be aware 

of the planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 551bs. proposed herein and the lack of flammable 

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

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

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

operations of conventional aircraft that must comply with Section 91 .119. 

14 C.F.R.§91.121 Altimeter Settings. This regulation requires each person operating an 

aircraft to maintain cruising altitude by reference to an altimeter that is set " ... to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an U.S. exemption may be needed. An equivalent level of safety will be achieved 

by the operator, pursuant to the safety check list and live flight data monitoring, confirming 

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

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14 C.F.R. § 91.151(a ): Fuel Requirements for 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 applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. Operating the UAS in a tightly controlled area where only people 

and property owners or official representatives who have signed waivers will be allowed 

does not engender the type of risks that Section 91.151 (a) was intended to alleviate given 

the size and speed of the small UAS. The applicant believes that an equivalent level of 

safety can be achieved by limiting flights to 30 minutes or 25% of battery power -

whichever happens first. This restriction would be more than adequate to return the UAS to 

its planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in 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 (a) 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 well under the proposed 55-lb limit 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 UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UAS will have immediate access to them, to the 

extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 41 7(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 others shall 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 flight manual and operating handbook. An equivalent level 

of safety will be achieved because the UAS is very limited in size and will carry a small 

payload and operate only in restricted areas for a limited period of time. If mechanical 

issues arise the UAS can land immediately and will be operating from no higher than 400 

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, 

the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual. As provided in the 

FOM, the operator will ensure that the UAS is in working order prior to initiating flight and 

perform required maintenance needed. 

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Public Interest 

The Exemption request will permit Richard Carranza "Township Property Management" to 

operate UASs commercially for the purpose of aerial filming and photographing inspections of 

infrastructure, aerial acquisition (mapping), real estate, and other applicable areas. Richard 

Carranza "Towns hip Property Management" will provide a service that is beneficial to an 

industry that is already using, and seeking to use, UASs for these purposes with a legal and 

safe option. This will benefit the public with the controlled operation of a UASs and increase 

integration into the National Airspace System (NAS). Richard Carranza "Township Property 

Management Services" UASs are battery powered and serve as a safe. and efficient, and 

economical alternative to the manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a UAS would reduce the amount of manned aircraft in the NAS, 

reduce noise and air pollution, as well as increase the safety of life and property in the air and 

on the ground. 

Conducting aerial acquisition with Richard Carranza "Township Property Management" UASs 

instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of 

air and noise pollution generated during traditional aerial survey flight operations. Previously 

high resolution digital aerial real estate photography was only affordable to a few select 

agencies with adequate funding. Richard Carranza "Township Property Management" would 

like to help change this by employing our UASs and make aerial photography affordable to 

everyone. High quality aerial imagery and data can provide new and enhanced information 

about a location being surveyed, inspected, or otherwise measured. 

Additional Information 

The applicant and primary pilot Richard Carranza, has an in-depth understanding of the 

capabilities and safety concerns involved in using this technology as an asset to the 

community. In addition, Richard Carranza, holds a Commercial Pilot Certificate with single 

engine land instrument airplane, private privileges, airplane single engine sea airplane multi 

engine land, & a Flight Engineer Turbo Jet Aircraft Certificate. Satisfaction of criteria provided 

in Section 333 of the reform Act or 2012 provide more than adequate justification for the grant 

rchard Carranza 

Owner, 

Township Property Management 

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