July 25th, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Petition for Exemption under Section 333 of the FAA Modernization and Reform Act

Of 2012 

Dear Sir or Madam,

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

and 14 C.F.R. Part 11, Martin S Olivarez, the operator and owner of small Unmanned Aircraft Systems 

("sUAS"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed below in section II 

of this document.

Section I. 

Petitioner Contact Information

Martin Olivarez

11121 CR 528 

Mansfield, Texas 76063

Cell: (214) 566-2917

Email: martin.olivarez@gmail.com

Section II. 

The specific Sections of Title 14 CFR that Martin Olivarez wishes to seek exemption:

14 C.F.R Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417

Section III. 

Extent of relief and reasons Martin Olivarez is requesting relief from existing regulations.

I, Martin Olivarez, am requesting relief from the aforementioned Title 14 CFR regulations so it may 

engage commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by 
Section 333. This exemption would permit the operation of sUASs under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, I Martin 

Olivarez would conduct commercial operations of sUASs meeting or exceeding all operational and safety 

requirements per Section 333.

Section IV

How this Exemption Request will benefit the Public as a whole.

1. Project and construction management, inspections and monitoring. The use of sUASs on construction 

sites may improve the safety of workers, local residents and general public by assessing potential 

dangerous situations. Falls and injuries may be reduced or eliminated through a more thorough review of 

the construction sites. In some cases, sUASs may reduce the reliance of helicopters or small aircraft to 

monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy 

usage; 

2. Environmental Review projects. The use of sUASs during the process of reviewing projects as required 

by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental Review of the project site 

as well as surrounding areas. Reliance of helicopters or small aircraft may be eliminated; 

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas may eliminate 

the use of helicopters or aircraft. This could provide a more cost effective, safer and more energy efficient 

product;

4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with surveying 

agricultural projects as well as wildlife and forestry projects by providing information when problems 

occur, vermin infestation, fire hazards, etc.; 

5. Remote Sensing projects. The use of sUASs could provide views and information for remote and 

inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and 

aircraft; U. S. Department of Transportation Docket Management System April 20, 2015 Page Three 

6. Educational and Research projects. The use of sUASs could provide information for said projects in a 

more cost effective and efficient manner than other available options; 7. Aerial filmmaking, photography 

and real estate purposes. The use of sUASs may provide a point of view previously unavailable through

other means. They would be more cost effective, efficient and more safely than helicopters and aircraft; 

and 

8. Search and rescue. The use of sUASs may provide assistance to local law organizations during search 

and rescue missions. SUASs may reach areas unattainable or viewable with helicopters and aircraft. 

SUASs may be implemented quicker as time is of the essence during search and rescue operations.

Section V

Reasons why an exemption will not adversely affect safety, or how the

exemption would provide a level of safety at least equal to the existing rule.

Proposed operations using sUASs provide increased safety enhancement especially when compared with 

helicopters and aircraft for the following reasons: 

1. The sUASs will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the pilot; 

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight times may be 

less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return to the 

ground station with at least 20% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL; 

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer;

6. A briefing will be conducted daily by all personnel working with said sUAS; 

7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consent 

will be required of all persons within 100 feet of flight operation;
8. Written and/or oral permission from relative property owners will be obtained prior to operating the 

sUAS; 

9. All permits, permissions, etc. will be obtained from local government offices as required; 

10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and 

horizontally; 

12. The sUAS will have the capability to return and land at the pre-determined location with the Security 

Perimeter should the sUAS lose communication or GPS signal during any operations;0

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

14. Operations will not be conducted over densely populated areas or heavily traffic highways; and

Section VI 

3DR Solo Specifications

The 3DR Solo is a battery powered quadcopter with a gross takeoff weight of 3.75 pounds. The airframe, 

including rotors, has a span of 26.2 inches. The UAS uses a command and control link for telemetry and 

video operating on 2.4 Ghz with 11 channel hopping to ensure reliability. The vehicle has maximum 

ground airspeed of 30 knots, with a cruising ground speed of 5 knots. In addition, the vehicle includes a 

number of enhanced safety features, including: 

 A choice between automatic and manual take-off and landing. 

 A sophisticated system of computer assisted navigation and flight management.

 Altitude is determined based on a combination of barometers and inertial navigation.

 The ability to both return to home or return to a predetermined point that has been preselected as 

free from obstructions or hazards.

 The ability to set custom battery charge warning levels and to set either an automatic return to 

home or return to a preset location in the event of a low battery.

 Tactile feedback in the controller when warnings are given to alert the pilot to certain conditions 

such as low battery.

 Programmable geo-fencing capabilities allowing the creation of a virtual “safety fence.”

 Up to 26 minutes of flight time (20 with camera and Solo Gimbal),

 HD video streaming to mobile

 Top speed: 55 mph

 Max Altitude: 400ft, per FAA rules

 Weight: 1600 g; 1760 g with Solo Gimbal and GoPro

 Wifi range: up to a half a mile, depending on environment

 Controller with color screen and live flight data

 Pixhawk 2 flight controller software

 Customizable color LEDs for orientation

 Solo Battery: 14.8 V LiPo (5200mAh)

 Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery available)

 10x4.5 self tightening props

 880 kV motors

 Plug and play with 3-axis Solo Gimbal from 3DR
Section VII.

Additional Information, Views, or Arguments.

Personal Statement

I recently obtained my Graduate Certificate in Geospatial Intelligence from Penn State University 

which is a program certified by the United States Geospatial Intelligence Foundation. During my studies I 

learned the positive impact sUAS can have in various arenas and the potential to increase safety and 

efficiency. I am seeking to provide services providing aerial imagery for purposes mapping, surveying, 

and inspection. The system I plan to utilize is the 3DR Solo powered by the Pixhawk 2 flight controller. 

This system does not exceed the weight of 55 pounds. Further information regarding this system is 

located within this document.

Section VIII.

Exemption outside the United States.

I have no intention to operate a sUAS outside the United States.

To the Director and Administration of the Federal Aviation Administration, I hereby submit this

Petition for Exemption, dated July 25, 2015

Respectfully,

Martin Olivarez