January 25, 2016 

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 Modernization and 

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

We represent Jorge Delgado and are submitting this Petition for Section 333 Exemption on his 

behalf under Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”). 

Applicant Information:

The name of the applicant: Jorge Delgado 

The primary contact for this application, with a copy to me at the address above, is: 

 Jorge Delgado 

16840 SW 278th Street 

 Homestead, FL 33031 

 

Jorge Delgado is a United States citizen residing in the State of Florida. Pursuant to Section 333 

of the FMRA, Jorge Delgado hereby requests a determination by the Secretary of Transportation 

authorizing commercial operations of UAS for the purposes of aerial photography, aerial 

videography, data collection and other work related to aerial photography in the NAS. Jorge 

Delgado does not intend to use for closed set filming. Conduct of UA operations will be with 

respect to FMRA Section 333(c) and the UAS “Blanket COA”. Petitioner is seeking an 

exemption to commercially operate sUAVs makes and models, as follows: 

1. 3D Robotics Aero – M 101. HexaCrafter HQ-850 

2. 3D Robotics Fixed Wing 102. HexaCrafter HQ-1150 

3. 3D Robotics Iris 103. HobbyKing Bixler 2 

4. 3D Robotics Solo 104. Hoverfly – Livesky 

5. 3D Robotics X8 105. HSE UAV – DRASS Q1000 

6. 3D Robotics X8+ 106. Hubsan – X4 Microdrone 

7. 3D Robotics X8-M 107. Inova Drone – Inova One 
January 25, 2016 

Page 2 of 13 

8. 3D Robotics Y6 108. Intuitive Aerial – Aerigon IAH 3 

9. AeroCamera - SR 15 109. Kespry Drone Systems 

10. Aerial Pixels - Fx8Pro Elite 110. KongCopter FQ700 

11. Aerialtronics Altura Zenith 111. Latitude Arcturus Jump-15 

12. AeroCine Kopterworx Hammer X12 112. Latitude Arcturus Jump-20 

13. AeroLogix – Geostar 113. Latitude HQ-20 

14. Aeronavics SkyJib-8 Ti-QR 114. Latitude HQ-40 

15. Aeronavics X4 Titanium 115. Latitude HQ-60 

16. Aerosky – RoboSurfer 116. Latitude Sensitel Silverfox HQ 

17. AeroVironment Puma 117. Leptron – Avenger 

18. AeroVironment Qube 118. Lockheed Martin – Desert Hawk III 

19. AeroVironment Shrike 119. Lockheed Martin – Indago 

20. Aeryon Scout 120. Mavinci – Sirius Pro 

21. Aeryon Sky Ranger 121. Microdrones MD4 

22. AgEagle 122. Microdrones – MD4-200 

23. Agribotix Enduro Quad 123. Microdrones – MD4-1000 

24. Agribotix Hornet Drone 124. Microdrones – MD4-3000 

25. Aibotix X – 6 125. MikroKopter – ARF OctoXL 

26. AirCover ORT-825 126. MLB- Super-Bat UAV 

27. AirCover QR-425 127. Multirotor G4 

28. Airfield – Extreme Surfer Power Glider 128. MultiRotor – G4 Blackbird V2 

29. AirRobot AR 100-B 129. MultiRotor – G4 Skycrane 

30. AirRobot AR 100-C 130. Parrot – AR Drone 2 

31. AirRobot AR 180 131. ParkZone – Radian RTF 

32. AirRobot AR 200 132. Parrot – Bebop 

33. Airwing UAV – Talon 133. PrecisionHawk – Lancaster 

34. Align M690L Multicopter 134. Precision Drone – PaceSetter 

35. Altavian Nova F6500 135. Prioria – Hex 

36. Altus UAS Delta X-4 136. Prioria – Hex Mini 

37. Altus UAS Delta X-8 137. Prioria – Maveric UAS 

38. American Drones – Eagle 550 138. ProJet – RC Drone 

39. American Drones – Falcon 450 139. ProJet – RQ-11 Raven 

40. American Drones – Nighthawk 550 140. Pulse Aerospace – Scout B1-100 

41. American Drones – Phoenix 650 141. Pulse Aerospace – Vapor 

42. Arch Aerial – Atlas-1 142. RangeVideo – Jet 

43. Arch Aerial – OCTO 143. RF70 Aircraft 

44. ARRIS – M680 Hexa 144. RIEGL RiCopter 

45. Ascending Technologies – AscTec Falcon 8 145. Ritewing - Drak 

46. Birdseyeview – FireFly 6 146. Ritewing - Spade 70" 

47. Blade 350 QX3 147. Ritewing - Zephyr 3 Spade 

48. Blade Chroma 148. SenseFly eBee 

49. Bormatec – Maja UAV 149. SenseFly – eXom 
January 25, 2016 

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50. Bumblebee Carbon Fiber Quadcopter 150. Sensurion Aerospace – Magpie 

51. CarbonCore – Cortex ARTF 151. Skycatch 

52. CineStar – 6 MK Heavy Lift RTF 152. Skyhunter 

53. Cinestar 8 Octo 153. Skywalker X-8 

54. Cyber Technology – Cyber Quad 154. Splash Drone 

55. Delair-Tech – DT – 18 155. SteadiDrone – Flare 

56. DJI-F450 156. SteadiDrone – Mavrik 

57. DJI-F550 157. SteadiDrone – Vader 

58. DJI - Inspire 1 158. Swift Radioplanes – Lynx 

59. DJI – Matrice 100 159. T-Rex 800E Pro 

60. DJI - Phantom 2 160. Tactical Robotics – InstantEye Mk2 

61. DJI - Phantom 3 161. Tarot – 450 

62. DJI – Spreading Wings S800 162. Tarot – 690 

63. DJI – Spreading Wings S900 163. Tarot – 960 

64. DJI – Spreading Wings S1000 164. Tarot- 680 Pro 

65. DJI – Spreading Wings S1000+ 165. Tarot – T18 

66. DraganFlyer - Commander 166. Tarot – T810 

67. DraganFlyer - Guardian 167. Tayzu Robotics – Quadra 

68. DraganFlyer - X4-ES 168. Tayzu Robotics – Titan X8 

69. DraganFlyer - X4-P 169. TBS Caipirinha V2 

70. DraganFlyer – X6 170. Trimble UX5 

71. Event 38 - E384 171. Trimble UX5-HP 

72. Finwing – Penguin 1720 172. Trimble ZX5 

73. FlyPro PX400 173. Turbo Ace – Cinewing 6 

74. FoxTech FPV – D130 X8 V2 174. Turbo Ace – Matrix G 

75. FoxTech FPV – K130 V3 175. Turbo Ace – Matrix I 

76. Freefly – Alta 176. Turbo Ace – Matrix E 

77. GB-250z 177. Turbo Ace – Matrix S 

78. GB-450z 178. Turnigy Talon Quad 

79. Germap – G47-X8 179. UAV Solutions – Phoenix 30 

80. Germap – G65-Y6 180. UAV Solutions – Phoenix 60 

81. Germap – G180 181. UAV Solutions – Phoenix 60LE 

82. Germap – G212 182. Vanguard Defense Industries ShadowHawk 

83. Germap – SmartOneC 183. Viking UAS – Patriot X4 

84. Gryphon Dynamics – Dodeca 184. Viking UAS – Patriot X8 

85. Gryphon Dynamics – Hexa 185. Viking UAS – Ranger EX 

86. Gryphon Dynamics – Octo 186. Viking UAS – VikingOne 

87. Gryphon Dynamics – X8 187. Viking UAS - VK X6 Model 800 

88. Gryphon Dynamics – Y6 188. Volt Aerial Robotics - Venture 

89. Hawkeye 1700 189. Vulcan – Black Widow 

90. Hawk UAS – Silex Systems F15 190. Vulcan – Mantis 

91. Helipal - Storm Drone AntiGravity 191. Vulcan – Raven 
January 25, 2016 

Page 4 of 13 

92. Helipal - Storm Drone 4 192. Walkera – QR X350PRO 

93. Helipal - Storm Drone 4 Mini 193. Walkera – QR X800 

94. Helipal - Storm Drone 4 Naza 194. Walkera – QR X900 

95. Helipal - Storm Drone 6 Naza 195. Walkera – Scout X4 

96. Helipal - Storm Drone 8 Naza V2 196. Walkera – Tali H500 

97. HexaCrafter HC-650 197. Walkera – Voyager 3 

98. HexaCrafter HC-800 198. Yamaha RMAX 

99. HexaCrafter HC-1100 199. Yuneec - Tornado H920 

100. HexaCrafter HO-1250 200. Yuneec - Typhoon Q500 

Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment. 

Equipment operation manuals for each sUAV are included for your reference and are considered 

confidential information for each respective company’s UAS and are affixed separately in these 

documents labeled Appendix, which has been sent to the FAA electronically by email. The 

referenced Appendixes are confidential and proprietary and is not to be publicly disclosed. 

Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. 

The attached documentation includes detailed exemption requests that demonstrate how these 

exemptions are in the public interest and will maintain at least an equal level of safety to existing 

regulations. Authorizing Jorge Delgado to conduct commercial UAS operations will result in less 

disruptive, safer, and more cost effective solutions than manned aviation equivalents due to the 

low altitude environment, given the size, speed and inherent risk of traditional commercial 

helicopter operations. These commercial operations often occur in the unsafe areas of the heightvelocity diagram requiring special precision and skill. Jorge Delgado will conduct the 

commercial UAS operation in a manner that will meet, and in many cases exceed, the current 

level of safety of commercial helicopter operations. UA that are under 55 lbs., have a low noise 

signature, and carry no volatile fuel, will limit collateral damage in the event of catastrophic 

failure. The low expense of operation compared to cost prohibitive manned aviation alternatives 

allow a greater economic benefit to businesses. For these reasons, granting an exemption under 

FMRA Section 333(c) is in the public interest. UAS technology used for these commercial 

purposes benefit the public interest in the following ways: 

 Reduces the collateral damage risks to life and property associated with low altitude 

helicopter operations in undesirable portions of the height-velocity envelope. 

 Increased economic wellbeing to local businesses via cost reductions. 

 Enabling aerial business solutions to be available to a larger market. 
January 25, 2016 

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Table of Contents 

I. Exemptions Requested 

II. Commercial Operation/Operator 

III. Unmanned Aircraft System (UAS) 

IV. UAS Pilot-in-Command (PIC) 

V. Public Interest 

VI. Summary 

VII. List of Attachments 

I. Exemptions Requested 

Pursuant to 14 C.F.R. § 11.81(e), Jorge Delgado requests exemption from the following 

regulations: 

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates 

o Establishes: The procedural requirements for the issuance of airworthiness 

certificates as required by 14 C.F.R. § 91.203(a)(1) 

Given the small size of the UA and the safeguards that will be taken as outlined below, an 

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

under Part 11 and Section 333 of the FMRA with consideration “of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the 

particular UAS.” 

 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

o 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. 

Jorge Delgado will ensure compliance with § 45.29(f) to meet the intent of the regulation 

by displaying the registration number in the largest practicable lettering. 

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private and 

Commercial Pilot Privilege and Limitations

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this 

section, no person who holds a private pilot certificate may act as pilot in 

command of an aircraft that is carrying passengers or property for compensation 

or hire; nor may that person, for compensation or hire, act as pilot in command of 

an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or employment. 
January 25, 2016 

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o 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a 

commercial pilot certificate may act as pilot in command of an aircraft – (ii) For 

compensation or hire, provided the person is qualified in accordance with this part 

and with the applicable parts of this chapter that apply to the operation. 

o 14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may 

not act as pilot in command of an aircraft: 

 For compensation or hire; 

 In furtherance of a business; 

UA operations will employ a PIC who holds, at a minimum, a recreational or sport pilot 

certificate of any category or class and a valid driver’s license. 

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

o No person may operate a civil aircraft unless it is in an airworthy condition. 

The PIC will conduct daily pre and post flight inspections in accordance with 

manufactures maintenance manual(s) and guidance. During flight, the PIC will adhere to 

§ 91.7(b) and abort air operations immediately upon identification of an in-flight 

emergency or other unsafe condition. By complying with procedures outlined by the 

manufacturer, an equivalent level of safety will be achieved. 

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements

o (b)(2) prohibits operation of U.S.-registered civil aircraft 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. 

By keeping all operating documents, manuals, authorizations and exemptions in a binder 

co-located with the GCS, Jorge Delgado meet the intent of the regulations and therefore 

achieve an equivalent level of safety. 

 14 C.F.R. 91.109(a) – Flight Instruction 

o 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.

The majority of sUAS by design are developed with single operational control through 

the use of pre-determined GPS enabled waypoints programmed before or during flight in 

addition to the use of a single hand held transmitter or control station controlled by the 

PIC. The design does not allow for dual controls during flight training and therefore the 

exemption is requested to train operators, build experience, and maintain proficiency. An 

equal level of safety will be achieved by conducting all training in sterile environments. 

Training sessions will be accomplished separately from flights conducted for 

compensation or hire. 
January 25, 2016 

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 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes 

o Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: (b) Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 feet 

above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If 

the operation is conducted without hazard to persons or property on the surface— 

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA.

Commercial UAS operations will be conducted at or below the maximum altitude 

authorized by COA. Given the size, weight and lack of fuel; combined with operation 

limitations listed below, the operation will be conducted with a greater level of safety 

than exists with current manned aviation operations. 

 14 C.F.R. 91.121 – Altimeter Settings

Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating... 

SUAS are equipped with Global Positioning System (GPS), which provide altitude and geolocation data to the operator without utilizing an altimeter. Due to this fact, an exemption is 

required. GPS are precise within a few feet and combined with fail-safes and a visual observer the 

operation will meet an equivalent level of safety. 

 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions 

o No person may begin 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;

This regulation is written based on the capabilities of a traditional aircraft, which have 

flight times of several hours or greater; therefore, with the majority of sUAS which have 

flight times of only an hour or less, this regulation would effectively deny the ability of 

the air vehicle to operate. 

The PIC will achieve an equivalent level of safety by complying with all manufacturer 

guidelines and the manufacturers’ low battery failsafe system. 
January 25, 2016 

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 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Equipment and 

Use. 

o All airspace. Unless otherwise authorized or directed by ATC, no person may 

operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of 

this section, unless that aircraft is equipped with an operable coded radar beacon 

transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A 

interrogations with the code specified by ATC, or a Mode S capability, replying 

to Mode 3/A interrogations with the code specified by ATC and intermode and 

Mode S interrogations in accordance with the applicable provisions specified in 

TSO C-112, and that aircraft is equipped with automatic pressure altitude 

reporting equipment having a Mode C capability that automatically replies to 

Mode C interrogations by transmitting pressure altitude information in 100-foot 

increments. This requirement applies—

(1) All aircraft. In Class A, Class B, and Class C airspace areas; 

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in 

appendix D, section 1 of this part from the surface upward to 10,000 feet MSL; 

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not 

originally certificated with an engine-driven electrical system or which has not 

subsequently been certified with such a system installed, balloon or glider may 

conduct operations in the airspace within 30 nautical miles of an airport listed in 

appendix D, section 1 of this part provided such operations are conducted— 

(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area 

designated for an airport or 10,000 feet MSL, whichever is lower; and 

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries 

of a Class B or Class C airspace area designated for an airport upward to 10,000 

feet MSL; and 

(5) All aircraft except any aircraft which was not originally certificated with an 

engine-driven electrical system or which has not subsequently been certified with 

such a system installed, balloon, or glider— 

(i) In all airspace of the 48 contiguous states and the District of Columbia at and 

above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the 

surface; and 
January 25, 2016 

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(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile 

radius of any airport listed in appendix D, section 2 of this part, excluding the 

airspace below 1,200 feet outside of the lateral boundaries of the surface area of 

the airspace designated for that airport. 

The sUAS to be used in the proposed operation does not come equipped with a 

transponder. No transponder exists for the sUAS, which can be installed. The petitioner 

requests relief from the exemption to the extent required to operate in areas in which a 

transponder is required according the applicable regulations in this part. 

The PIC will achieve an equivalent level of safety by complying with all provisions of 

the COA under which operations are to be conducted. By issuing appropriate NOTAMS 

and prior ATO coordination, an equivalent level of safety can be achieved as other 

manned aircraft, which receive authorization to fly in airspace where a transponder is 

required but not operable. In order to give proper notice to the ATO, the PIC will comply 

with the provisions of 91.215(d)(3). The sUAS flown under this exemption will comply 

with all altitude limits and airport standoff distances required by COA, which mitigate 

hazards to aircraft controlled by the ATO in congested airspace. 

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance 

Inspections 

o 91.405(a) States: Each owner or operator of an aircraft—(a) 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

o 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has 

been approved for return to service by a person authorized under § 43.7 of this 

chapter

o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no 

person may operate an aircraft unless, within the preceding 12 calendar months, it 

has had—(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection performed under paragraph 

(b) of this section may be substituted for any inspection required by this 

paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance 

records.

o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 

91.411 and 91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i 

– iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for 

the periods prescribed: (paragraphs 1 – 3)
January 25, 2016 

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The PIC will conduct Pre/Post flight inspections and maintenance in accordance with the 

manufacturer’s guidance as stated in the operations manual. If maintenance is required, 

the PIC will conduct a dedicated test flight will be conducted to ensure safety before 

resuming commercial operations. All inspection, maintenance and alterations will be 

documented and maintained in a record. These actions will meet the intent of the 

regulations from which exemption is being requested and lead to an equivalent level of 

safety. 

II. Commercial Operator/Operation 

Any UA flown under this exemption will be controlled by a certificated PIC. The PIC will hold, 

at a minimum, a recreational or sport pilot certificate. 

For each flight, Jorge Delgado: 

 Will contact the controlling air traffic organization to issue a NOTAM. 

 Will conduct a comprehensive worksite inspection and analysis, identifying limits of 

customer property or authorized access areas. 

 Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

 Will operate in those areas only with the consent of the landowner or designated 

representative. 

 Will identify potential obstructions or other hazards to safe operation. 

 Will clear the area of personnel or bystanders that are non-essential to the operation, 

maintaining at a minimum, 500 feet away from non-participating persons. 

 Will conduct a preflight safety briefing to Visual Observer (VO) and participating 

persons. 

 Will at all times yield to manned air traffic. 

 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communications with VO and participating persons.

 Will operate under visual flight rules, in visual meteorological conditions, for the airspace 

in which the flight is conducted.

 Will not exceed the maximum altitude as defined in the COA under which flight 

authorized, as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder colocated with the GCS.

 Will immediately terminate flight, in the safest manner possible, when safety to persons 

or property become compromised. 

 Will terminate flight, in the safest manner possible, when unable to comply with these 

limitations or any other limitations granted as part of this exemption.

In order to remain at an altitude at or below the attitude prescribed by the applicable COA, relief 

is needed from Section 91.119 (c). By following these operating standards, the commercial 

operation will meet an equivalent level of safety to the regulation in which relief is sought. 
January 25, 2016 

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III. Unmanned Aircraft System 

Jorge Delgado seeks exemption to operate sUAS as outlined above. Other UAS types may be 

requested in future amendments. The UA will be flown via a combination of RC control and 

tablet GCS. All UA types are GPS equipped with a navigation and control system and auto-pilot 

that allows it to execute very accurate pre-programmed flights. Lithium-polymer batteries power 

the sUAS. 

The UA also has several fail-safes for loss of RC signal, loss of GPS, and low battery as outlined 

in the respective Operation Manuals. The UA display visual and emit an audible low battery 

alerts at which time the UA will automatically engage the landing sequence. Based upon those 

safeguards, I request exemption from Section 91.151(b) Fuel requirements for flight in VFR 

conditions. 

Given the size, weight, speed, and controlled operating area associated with the UA to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 

91.203 (a) and (b) is requested. Exemption is sought from § 45.23 Marking of the aircraft. The 

UA will display the registration number in the largest practicable lettering. Jorge Delgadoseeks 

to be exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

inspections will be conducted according to operations manual and prudent judgment as 

previously outlined to determine the integrity and safety of the UA and associated equipment. 

Further, relief is required from 91.7(a), which prohibits the operation of an aircraft without an 

airworthiness certificate and 91.9(b) (2) requiring an approved flight manual in the aircraft. The 

UA will not be operating with an airworthiness certificate therefore, this would be inappropriate. 

The UAS are too small to carry the operating documents so an equivalent amount of safety can 

be achieved through keeping the operating documents and manuals at the GCS. 

IV. UAS Pilot in Command (PIC) 

Under part § 61, recreational, sport and private pilots are limited to non-commercial operations, 

however Jorge Delgado can ensure UA operations will achieve an equivalent level of safety as 

current regulation because UA do not carry any pilots or passengers. A commercial pilot 

certificate will not ensure RC piloting ability, as the psychomotor skills are different. The 

inherent risks of operating a UAS are far less than in the commercial activities outlined in 14 

CFR part 61, et seq., thus exemption is requested from § 61.101 Recreational Pilot Privileges 

and Limitations. PICs will maintain recent flight experience on the UAS. Training and 

experience flights will be conducted separate from commercial operations. 

V. Public Interest 

Given the above stated evidence, procedures, and precautions operating UAS commercially for 

the purposes of aerial photography, aerial videography, data collection and other work related to 
January 25, 2016 

Page 12 of 13 

aerial photography will ultimately be in the public interest. These operations, when executed 

with prudence, will exceed the current level of safety as the regulations from which exemption is 

sought. UA operations will allow greater access to commercial aerial services that were not 

previously economically feasible for many firms. This will provide a much needed economic 

uplift to the community and hence the public. UA operations are associated with less risk of 

collateral damage to persons and property while limiting disruptive noise pollution associated 

with low altitude aviation operations. 

VI. Summary 

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform 

Act of 2012”, Jorge Delgado, hereby applies for authorization to conduct commercial unmanned 

aerial systems (UAS) operations for the purposes of aerial photography, aerial videography, data 

collection and other work related to aerial photography listings Rules for which exemption is 

sought: 

 14 C.F.R. Part 21 Subpart H 

 14 C.F.R. § 45.23(b) 

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii) 

 14 C.F.R. § 91.7(a) 

 14 C.F.R. 91.9(b) 

 14 C.F.R. § 91.103 

 14 C.F.R. § 91.109(a) 

 14 C.F.R. § 91.119 

 14 C.F.R. § 91.121 

 14 C.F.R. § 91.151(a) 

 14 C.F.R. § 91.215(b) 

 14 C.F.R. § 91.405(a) 

 14 C.F.R. § 91.407(a)(1) 

 14 C.F.R. § 91.409(a)(2) 

 14 C.F.R. § 91.417(a) & (b) 

VII. Attachments: 

1. Specific Appendixes and UAV manuals. (These documents have been provided 

electronically by email since it is confidential and proprietary and is not to be publicly 

disclosed.) 
January 25, 2016 

Page 13 of 13 

Thank you for your prompt attention and consideration. Traverse Legal and its clients are 

committed to safe UAS operation and ambassadors. Please do not hesitate to contact me 

directly with any questions or concerns at 866-936-7447. 

 Very truly yours, 

 Traverse Legal, PLC

 

 Enrico Schaefer 

 Attorney at Law 

 www.dronelaw.pro 

enrico@traverselegal.com 

ES/cam 

Enclosures