Page 1 of 12

June 29, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 205590

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R . 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) Dear Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Luis E. Martinez dba Martinez Aerial Video Services, a licensed commercial pilot, and operator of Small Unmanned Aircraft Systems ("UAS") equipped to conduct aerial photography for real estate professionals, real estate marketing purposes, Industrial and agricultural clients, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial opera tion of its “UAS,” so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section

333.

As described more fully below, the requested exemption woul d permit the operation of small, unmanned and relatively inexpensive UAS under controlled cond itions in airspace that is 1) limited 2) predetermined and 3) controlled as to access. Appro val of this exemption would thereby fulfill the Secretary of Transportation's (th e responsibilities to " ... establish requirements for the safe operation of such aircraft s ystems in the national airspace system." Section 333 (c) of the Reform Act.

Respectfully,

Luis E. Martinez, M.Ed

515 E. Barrus Place Casa Grande, AZPage 2 of 12

CONTACT INFORMATION:

Luis E. Martinez

515 E. Barrus Place Casa Grande, AZ (520)705-4268 Email: kg7gmk@gmail.com

Commercial Pilot FAA# 2032677 Retired Chief of Police with 32 yrs. experience

THE SPECIFIC SECTIONS OF TITLE 14 OF THE CODE OF FEDE RAL REGULATIONS FROM WHICH LUIS E. MARTINEZ REQUESTS EXEMPTION A RE:

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

14CFR91.119

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 fulfi ll Congress' goal in passing Section 333 (a) through (c) of the Reform Act. This directs the S ecretary of Transportation to consider whether certain unmanned aircraft systems may operate s afely 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 det ermine which types of UAS 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 po pulated areas; and Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. Reform Act §333 (a). Lastly, if the Secretary determines that suc h vehicles "may operate safely in the national airspace system, the Secr etary shall establish requirements for the safe operation of such aircraft in the national airsp ace system." Id. §333 (c) (emphasis added). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its termsPage 3 of 12

includes exempting civil aircraft, as the term is defined u nder §401 01 of the Act; that includes UAS, from the requirement that all civil aircraft mus t have a current airworthiness certificate. The Administrator may gran t 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 Administrator finds t he exemption in the public interest. 49 U.S.C. §44704; 14 CFR §91.203 (a) (1).

Luis E. Martinez’s UAS(s) are small rotorcraft aircr aft, the DJI Phantom 3 Pro, weighing less than 3 lbs. including camera payload. He operates his rotorc raft, under normal conditions at a speed of no more than 20 knots, usually 3-5 knots, and have th e capability to hover, and move in the vertical and horizontal plane simultaneously. He will manually operate only in Visual Line of Sight and will operate only within the operating paramete rs as described in the Operating Manual

attached as Attachment 1.

Adherence to the Operating Manual will insure that the UA S will "not create a hazard to the national airspace system or the public."

Given the small size and weight of the UAS involved and the restricted sterile environment within which they will operate, the applicant falls squar ely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immed iately. Also due to the size of the UAS and the areas in which the relevant UAS will operate, approval of the application presents no national security 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 signific ant public benefit, including enhanced safety, reduction in environmental impact, including r educed emissions associated with allowing UAS for educational and marketing operations, (as opposed to full scale aircraft), the granting of the requested exemptions is in the public inter est. Accordingly, the applicant respectfully requests that the FAA grant the requested exe mption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herei n 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 higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe filming operations conducted with conventional aircraft. These limitations and condition to which Luis E. Martinez agrees to be bound when conducting co mmercial operations under an FAA issued exemption include:

The UAS will weigh less than 3 lbs.Page 4 of 12

Flights will be operated manually within visual line of si ght (VLOS) of the Pilot and aircrew (Visual Observer).

Maximum total flight time for each operational flight w ill be 20 minutes. Flights will be terminated at 25% battery power reserve should that occu r prior to the 20 minute limit.

Flights will be operated at an altitude of no more than 400 feet AGL, though most operations will be conducted within 50 feet of the ground.

Minimum two (2) person crew for each UAS operation wil l consist of the Pilot and Visual

Observer.

The UAS Pilot will be an FAA licensed airman with at least a commercial pilot's certificate and

valid driver's license.

The UAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder, other than the UAS Pilot, possesses the necessary PIC qualifications and is also present, that person can also be designated as PIC.

The UAS will only operate within an area of Pinal, Mari copa, and Pima County in the State of

Arizona.

Additionally, the UAS will only operate below 400ft AGL.

The UAS will never enter any MOA or Restricted Airspac e, nor shall it violate any TFR as outlined by the FAA.

A pre-flight briefing will be conducted in regard to the pla nned UAS operation prior to each day's flying and recording activities. It will be mandatory th at all personnel who will be performing duties as "flight crew" be present for this br iefing. Briefing will include review of

NOTAMs and Weather.

Pilot and Observer will have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as requ ired.

Observer and Pilot will at all times be able to communicat e by voice or radio.

Written and/or oral permission from each relevant prope rty holders will be obtained.

If the UAS loses communications or loses its GPS signa l, the UAS has the capability to return to a pre-determined location and land.

The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.Page 5 of 12

PIC will abide by all Arizona Revised Statutes Chapter 28 A rticle 3 (Aircraft Operations).

The UAS Pilot in Command (PIC) shall possess at a mini mum, a commercial pilot certificate

and current driver’s license.

The PIC shall be trained in the operation of the specif ic make and model of the UAS being piloted and successfully completed all training required.

The PIC shall have accumulated and logged, in a manner con sistent with 14 CFR §61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least five hours logged as a UAS pilot with a similar UAS type (multirotor or helicopter). 10 of the 25 hours may be accumulated in a simulator. Prior documen ted flight experience that was obtained in compliance with applicable regulations may satisfy thi s requirement.

The PIC shall have accumulated and logged, in a manner con sistent with 14 CFR §61.51 (b), a minimum of five hours as UAS pilot operating the make an d model of UAS to be utilized for operations under the exemption and three take-offs and t hree landings in the preceding 90 days.

Training, proficiency, and experience-building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time.

During training, proficiency, and experience-building flight s, all persons not essential for flight operations are considered non-participants, and the PIC m ust operate the UAS with appropriate distance from non- participants in accordance with 14 CF R §91.119.

The UAS Safety Observer (SO) shall meet all training re quirements and be responsible for all of his/her duties as set forth by the attached UAS Operating Manual.

The PIC and SO will be designated before each flight.

Minimum crew for each flight operation will consist o f the UAS PIC and SO.

The PIC and SO shall always be within visual line of sigh t (VLOS) of each other and in direct

verbal communication at all times.

Safety Briefings shall be conducted before each day's acti vities to include, but not limited to:

a) Location/operating area b) Embarkation/arrival time c) Operation objective(s) d) Operating system (UAS) e) Operating conditions f) Roles and responsibilities g) Communication procedures h) Discussion on hazards/perceived risk i) Emergency proceduresPage 6 of 12

j) Crew health k ) Weather l) Safety equipment (the PIC and Observer shall wear hard hats and day-glo vests clearly identifying them as PILOT and OBSERVER to assist the public and bystanders)

Liability Insurance

General Liability Insurance shall be maintained in the amount of

500,000/100,000.

DJI PHANTOM 3 PRO

Model: DJI PHANTOM 3 PRO Weight (Battery Included): 2.8 LBS. Hovering Accuracy: Vertical : +/- 4” ( Vision Positioning active) or + /- 19” (with GPS active)

Horizontal : +/- 59” Max Ascent Speed 16.5 FPS Max Decent Speed 10.5 FPS Max Speed : 36 MPH/54 FPS Max Flight Time: 23 MINUTES Operating Temperature Range : 32 0 F – 104 0 F

Dimensions: (including propellers) 23.2” X 23.2”

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

Subpart H, entitled Airworthiness Certificates, establis hes the procedural requirements for the issuance of airworthiness certificates as required by F AR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Appli cant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safe ty under Part 11 and Section 333 of the

Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of t he Reform Act both authorize the FAA to exempt aircraft from the requirement capabili ty, 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 s afer, than a conventional aircraft (fixed-wing or rotorcraft) operating with an airworthiness certifica te without the restrictions and conditions proposed.Page 7 of 12

The UAS to be operated hereunder is less than 3 lbs. fu lly loaded, carries neither a pilot nor passenger, carries no explosive materials nor flammabl e liquid fuels, and operates exclusively

within a limited radius area as set out in the preflight briefing I VLOS operations. Unlike other civil aircraft, operations under this exemption will be tightly controll ed and monitored by both the Operator, pursuant to safety requirements, and under the requirement s and in compliance with local public safety requirements, to provide security for the area o f operation as is now done with conventional aircraft. These safety enhancements, whi ch already apply to civil aircraft operated in connection with video production, provide a greater degre e 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 substant ial external load.

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

When marks include only the Roman capital letter "N" an d the registration number is displayed on limited, restricted or light-sport category aircra ft or experimental or provisionally certificated aircraft, the operator must also display on that aircr aft 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 "provis ional," as applicable.

Even though the UAS will have no airworthiness certifi cate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilo t station on which the word "Experimental" can be placed. Given the size of the sU AV, two inch lettering will be impossible. The word "Experimental" will be placed on the fusela ge in compliance with §45.29 (f) along with the “N” number in the largest possible size.

The equivalent level of safety will be provided by having th e sUAV marked on its fuselage as required by §45.29 (f) where the Pilot, Observer and others working with the sUAV will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b):

Private Pilot Privileges and Limitations - Pilot in Com mand (PIC) Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because t he UAS will not carry a pilot or passengers, the proposed operations can achieve the equival ent level of safety of current operations by requiring the PIC operating the aircraft t o have a private pilot's license rather than a commercial pilot's license to operate this small UAS . Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlle d with no living thing on board. The area of operation is controlled and restricted, and all flight s are planned and coordinated in advance as set forth in the Operating Manual. The level of safety provided by the requirements included inPage 8 of 12

the Operating Manual meets that 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 operati ons of the UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

14 CFR §91.7 (a): Civil Aircraft Airworthiness

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

condition. As there will be no airworthiness certif icate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exis t for determining airworthiness. Given the size of the aircraft and the requirements c ontained in the Operating Manual for maintenance and use of safety checks prior to each fligh t, as set forth in the Operating Manual, an equivalent level of safety will be provided.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Ai rcraft

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 appro ved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any com bination 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 bo ard, 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 ke eping the Operating Manual at the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exempti on Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A 10602, 32827, and 10700

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take c ertain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight man uals will not be provided for the aircraft an exemption will be needed. An equivalent level of safet y will be provided as set forth in the Operating Manual. The PIC will take all actions including re viewing weather, NOTAMs, flight battery requirements, landing and takeoff distances and a ircraft performance data before initiation of flight.

14 CFR §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil airc raft (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 dualPage 9 of 12

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 flig ht 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 certified commercial pi lot who has previously trained in remote flight areas before attempting flight within filming dist ance of structures.

14 CPR § 91.119: Minimum Safe Altitudes

Section 91. 119 establishes safe altitudes for operation of c ivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums pre scribed, provided the person operating the helicopter complies with any route or altitudes presc ribed for helicopters by the FAA. As this exemption is for a UAS, Luis. E. Martinez requests aut hority to operate at altitudes below 400 ft. AGL; an exemption may be needed to allow such operat ions. As set forth herein, the UAS will never operate at or higher than 400 ft. AGL. It wil l however be operated in a controlled area where buildings and people will not be exposed to operati ons without their pre-obtained consent.

The equivalent level 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 ow ner and participants in the photographic activity, all affected individuals will be aware of th e planned flight operations as set forth in the Operating Manual. Compared to flight operations with airc raft or rotorcraft weighing far more than the maximum 3 lbs. proposed herein and the lack of f lammable 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 UAS will ensure separation between these small UAS operations an d the operations of conventional aircraft that must comply with Section 91.119.

14 CPR § 91.121 : Altimeter Settings

This regulation requires each person operating an aircraf t 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 UA S 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 G PS altitude indicator before flight.

14 CPR §91.151 (a): Fuel Requirements for Flight in VFR Cond itions

Section 91.151 (a) prohibits an individual from beginning "a flig ht 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 nor mal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At ni ght, to fly after that for at least 45 minutes."Page 10 of 12

The battery powering the UAS provides approximately 23 minute s of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS fligh ts would be impossible. Given the limitations on the UAS's proposed flight area and t he location of its proposed operations within a predetermined area, a longer time frame for fli ght in daylight or night VFR conditions

is reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Cor poration to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representativ es who have signed waivers will be allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size a nd speed of the small UAS. Additionally, limiting UAS 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 17 minutes or 25% of battery power whichever happens first. Thi s restriction would be more than adequate return the UAS to its planned landing zone from anyw here in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 57 45, 1 0673, and 10808.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certificati on 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 airw orthiness certificate required by paragraph (b) of this section or a special flight author ization 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 3 lbs. and is o perated without an onboard Pilot. As such, there is no ability or place to carry certifica tion and registration documents or to display

them on the UAS.

An equivalent level of safety will be achieved by keeping t hese documents at the ground control point where the Pilot flying the UAS will have immediat e access to them, to the extent they are applicable to the UAS, and should they be issued. The FAA has issued numerous exemptions to this regulation. A representative sample of other exce ptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspecti onsPage 11 of 12

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 requ ired inspections, except as provided in paragraph C of this section, have discrepancies repaired a s prescribed in Part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircra ft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance wi ll be accomplished by the operator; pursuant to the Operating manual. An equivalent level of saf ety will be achieved because these small UAS 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 higher than 400 ft. AGL. As pro vided in the Operating Manual, the PIC (operator) will ensure that the UAS is in working orde r prior to initiating flight, and perform required maintenance. Moreover, the operator is the pe rson most familiar with the aircraft and best suited to maintain the aircraft in an airworthy con dition to provide the equivalent level of safety.

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is neede d: Applicant seeks an exemption from the following rules: D 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 c ommercially a small unmanned vehicle (51bs or less) in Educational and Marketing oper ations.

All flights will occur over private or controlled acce ss property with the property owner's prior consent and knowledge, or over remote public land. Image captur e of people will rarely take place, but in the event they are, they will have cons ented prior to being filmed or otherwise have agreed to be in the area where data collection will ta ke place.

Airborne Image Capture

With regard to airborne filming, Luis E. Martinez adhere s to all FAA regulations. Further Luis E. Martinez’s airborne teams operate under the principal s of: Safety First , Quality Assurance, Accountability,

Reporting, and Training. When approved by the FAA it is Luis E. Martinez duty to treat all UAS operations the exact same level of professionalism and seriousness as that of conventional

aircraft.

Approval of exemptions allowing commercial operations of U AS in the real estate industry will enhance safety by reducing risk. Conventional filming operatio ns, using turbine or piston powered aircraft present the risks associated with vehicle s that weigh in the neighborhood of 2,0001bs.+, carrying large amounts of Jet A or aviation fuel. Such aircraft must fly to and from photographing location. In contrast, a UAS weighing fewer than 3 lbs. and powered by batteries eliminates virtually all of the risk given the substantial reduced mass and lack of combustiblePage 12 of 12

fuel carried on board. The UAS is typically transporte d to the location via auto or cargo van in a

medium sized case and is never flown to set. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associate d with manned aircraft.

The operation of small UAS, weighting less than 3 lbs. , conducted in the strict conditions outlined above, will provide an equivalent level of safet y supporting the grant of the exemptions requested herein, including exempting the applicant from the r equirements of Part 21 and allowing commercial operations. These lightweight airc raft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are f ar safer than ground than conventional operations conducted with piston helicopters or fixed wing aircraft operating in relatively close proximity to the ground and people.

The primary market of interest for Luis E. Martinez uti lizing UAS is the photography of real property, commercial and industrial properties, and agricult ural fields.

The airborne image capture process will be accomplished exclusively in day time VFR environments. To capture the highest quality of resolution t he majority of airborne data collections will take place during the 07:00am- 07:00pm (19:00) windo w. And only during daylight conditions.

Summary

Satisfaction of the criteria provided in Section 333 of th e Reform Act of 2012- size, weight, speed, operating capabilities, proximity to airports and populat ed areas and operation within visual line of sight and national security- provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant's UAS in the real estate industry pursuant to the Operating Manual appended hereto. Luis E. Martinez is eagerly standing by to support the FAA and UAS community in its quest to est ablish proper regulations and protocols for the safe introduction of unmanned aircraft i nto the national airspace.

Sincerely,

Luis E. Martinez

515 E. Barrus Place Casa Grande, AZ (520)705-4268 kd7gmk@gmail.com