March 

### 27, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington. DC 20590. Re: ExemptionRequest Pursuant to Section 333 of

### the FAA Reform Act andPart 11 ofthe Federal Aviation Regulations from 14 C.F.R. 

### 61.113(a) & (b); 9l.Il9(c); 91.15l(a); 91.405(a); 91.407(a) 

### (1); 91.409(a) (2) ;91.417 (a) & (b). Dear Sir or Madam: I Rolando Chavez petition the Federal Aviation Administrationto conduct sUAS flights over thefollowing tasks: l. Land Surveying 2. Engineering Developments 

### 3. Pipeline Inspections 4. Realty As an experience Radio Control Pilot/Operator and member ofThe Academy ofModel Aeronautics member# 945273. allows for me the experience to reviewthe most efficient flight plan. This knowledge base has come through years ofpiloting, maintaining. and repairing sUAS andRadio Controlled Planes. The pilot/operator and observer are both certified in first aid and CPRthroughtraining provided by the Red Cross.

Pursuantto Section 33 3 ofthe FAA Modernization and Reform Act of2012 (the "Reform Ad') and 14 C.F.R. Part 11, I, Rolando Chavez petitions the FAAto allow safe flight operation ofits sUAS for the commercial purpose ofgathering aerial data ofthe aforementioned tasks. I, Rolando Chavez hereby applies for an exemption fl'om the listed Federal Aviation Regulations (FARs) to allow commercial operation 

### ofits sUAS. so long as 

### such operations are conducted within and under the conditions outlinedherein or as may be established by the FAA in an exemption granted under either Section 333 

### or Section 49 U.S.C. §4470l(f). Furthermore, I,Rolando Chavez have set forth conditions that are consistent withthe equivalentlevel ofsafety setforth in Exemption 11062 andthe related exemptions issuedto sUAS companies for scripted closed set filming for the motion picture and television Industry. As described more fully below. the requested exemption would pennitthe operation ofsmall, tuunanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited, 2) predetermined> 3) controlled 

### as to access, and 4) would provide safety enhancements to the already safe operations in the fields in which it will operate, presently using manned aircraft or ground personneL Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "establish requirements for the safe operation ofsuch aircraft systems inthe national airspace system (NAS)." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is:

Rolando Chavez 716 Amber Ave. Laredo, Texas 78045

. FAA sUAS Registration#



### A/Te!Jtl..3~ Regulations from whichthe exemption is requested:

### 14 C.P.R. 61.113(a) 

### & (b) 14 

### C.F.R. 91.119(c) 14 C.P.R. 91.15l(a) 14 C.F.R. 91.405(a) 14 C.P.R. 407(a) (1) 14 C.P.R. 409(a) (2) 14 C.P.R. 417(a) & (b)

This exemption application is expressly submittedto fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportationto consider whether certain unmarmed aircraft systems may operate safely inthe national airspace system (NAS) before completion oftherulemaking required LUider Section 333 oftheReform Act. In making this detenuination, the Secretary is required to determine whichtypes of UASs do not create a hazard to users ofthe NAS orthe public or pose athreat to national security in light ofthe following: The UAS's size, weight, speed, and operational capability; operation ofthe UAS in close proximity to airports and populated areas; and operation ofthe UAS within visual line ofsight ofthe operator. Lastly, ifthe Secretary deten11ines that such vehicles "may operate safely inthe national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace

**system.~'** Id at § 333(c) The Federal Aviation Act, in addition to the authority granted by Section 333 ofRefonn Act, expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under Section40101 ofthe Act, which includes sUAS, frmn the requirementthat all civil aircraft must have a current ainvorthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofSection 333 or any Sections 4470244716 of the TransportationAct ifthe Administrator finds the exemption in the public interest. 49U.S.C. § 44701(£). 

### See also 49 U.S.C. §447ll(a), 49 U.S.C. 

### §44704; 14 C.P.R.§ 91.203(a) (1). This authority to grant exemptions reaches such issues

as authorization ofcommercial operation ofaircraft without apilot's license. Based uponthe spirit ofSection 333, and the continuing integration ofsmall UAS 1sinto the NAS, I Rolando Chavez submits this petition for review and approval. Finally, I Rolando Chavez; in orderto provide the total safety and protection ofthe general public and manned aircraft will be operating a DJI Phantom 2 Vision (quadcopter). Maximum manufacturer;s safe flight speed is less than 15 m/s. This sUAS will not exceed 10 m/s during sUAS operation. The sUAS will not exceed 200ft (AGL) and will only be operated within line ofsight ofthe PIC and VO and as providedbythe "UAS safe flight operations manual" as 

### it pertains to accident scenes as Exhibit A. I, Rolando Chavez submitthe "UAS manufacturer flight and operational manual" as Exhibit B. Operational compliance ofExhibit A and B shall insure safe flight operations within the boundaries ofthe work site. Compliance outlined in ExhibitA and B shall also insure safe flight sUAS operations withinthe 

### NAS. Furthem1ore, this petitioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the li111itations listed herein. These limitations provide for an equivalent or even higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the operations normally conducted with meumed aircraft. These limitations and conditions to which I, Rolando Chavez agrees to bebound when conducting commercial operations under an FAA 333 issued exemption include: 

### 1. The sUAS must weigh less than 25 lbs. including battery and camera. Operations 

### will be limited to the aircraft described in Exhibit B.2. The sUAS may not be flown faster than recommended by the manufacturer. 3. sUAS operations will be conducted below 200ft above ground level (AGL). The height ofthe sUAS will not exceed 200ft (AGL). 4. sUAS operations will only be conducted in class D airspace, unless otherwise approved by the 

### FAA. 5. The UAS will be operated within visual line ofsight (VLOS) ofthe PIC and VO at all times. This requires the PIC to be able to use hmnan vision unaided by any device otherthan corrective lenses, as specified on the PICs 

### FAA issued third class medical certificate. 6. All operations mustutilize a visual observer (VO). The YO may be used to satisfythe VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 7. The operator will be boundby and follow Exhibits A & B. Any additional requirements identified in the final conditions for this exemptionwill be addedto Exhibits A &

### B. Exhibits A & B will be maintained and made available to the Administrator uponrequest. lfa discrepancy exists between the conditions and limitations inthe final exemption and the procedures outlined in Exhibits A & B, the conditions and limitations ofthe exception will take precedence and will be followed. Otherwise, the operator 'Will follow the procedures as outlined in Exhibits A & B. 8. The operator will update or revise its Exhibits A & B. Itwill be the operatorjs responsibility to track suchrevisions and presentupdated and revised documents to the Administrator upon request. The operator will also presentupdated and revised documents ifitpetitions for extension or amendment. Ifthe operator determines that any update orrevision would affectthe basis fbr which the FAA grantedthis exemption, thenthe operator will petition for amendment to their exemption. The operator will contactthe FAA's UAS Integration Office (AFS80) 'With questions that may arise regarding updates orrevisions to Exhibits A & B. 9. Prior to eachflight 

### the PIC 

### will inspect the sUAS to ensure itis in safe flight condition. The procedures for preflight inspection and functional viability ofall sUAS components are outlined in Exhibit A &B. 10. All sUAS flights will 

### only be conducted during daylight hours. No night flights ofsUAS will be conducted. 11. The operator will comply withthe manu.factu:rds recommendations pertainingto maintenance, inspection and replacement ofUAS components. The maintenance manual, submitted as Exhibit C, outlines these components. 12. Priorto operations conducted for the purpose ofgathering aerial data, the PIC will have accumulated and loggedj in a manner consistent with 14 C.P.R.§ 61.5l(b), aminimum of300 flight cycles and 30 hours oftotal time as a UAS multirotor aircraft pilot and at least 20 hours logged as a UAS pilotwith a similarUAS type. Prior documented flight experience that was obtained in compliance with applicable regulations will be used to satisfy this requirement. Training, proficiency, and experience building flights may also be conducted underthis grant ofexemptionto accomplishthe required flight cycles and flight time. During training, proficiency. and experiencebuilding flights, allpersons not essential tor flight operations will be considered nonparticipants, and the PIC will operate the sUAS with appropriate distance from nonparticipants in accordance with 

### 14 C.P.R. §91.119.

Sincerely,



# ~hEXHIBIT A. Preflight Procedures specific to sUAS operations for the purpose ofthe specified commercial use: 1. Ifavailable, bolUldaries ofthe s UAS operation will be clearly marked that aUAS operation will be in effect. The clearly marked identifiers will specify that non-authorized individuals must remain 500ftfrom the UAS operation. Authorized individuals will sign



### aconsent to enterthe UAS operational theater. 

### 2. Individuals 

### working within the area ofUAS operation 

### will be llOtified thataUAS operation \:vill be in effect. 3. The area ofUAS inspectionwill be observed for obstaclesthat may interfere with safe operation. 

### Ifobstacles exist that would affectUAS operations the VAS operation 

### will



### cease. 4. All operation flights ofthe sUAS 

### will be conducted llllder 200ft. AGL. 5. 

### No sUAS 

### flights will 

### be conducted inrain, snow or winds exceeding 12mph. 6. All sUAS flights 

### will be conducted with the Pilot and Visual Observer. In situations where either one is unable to attend the flight mission, the flight mission will NOT be conducted. 7_ All batteriesboth from the transmitter and sUAS vvill be fully charged and verified before take off. 8. Perso!ll1el atthe Air Control Tower (ACT) From Laredo. Texas International Airportwill be notified 30 minutes before flight and will be advised the exact location and duration of 

### the sUAS flight. 9. All software and firmware will be updatedand the sUAS tested before

## any flight mission_ 10. All maintenance checks will be conducted priorto each sUAS flight. 11. No sUAS flights will be conducted within 5 1niles ofan airport. 12. All sUAS flights will be conducted within Visual Line ofSight (VLOS). 13. No sUAS flights will be conducted unless 8or more GPS satellites are acquired for safety. Ifno more than 8 GPS satellites are acquired, no flights 

### will be allowed.

### ExhibitB Phantom 2Vision Manual Vl.

### 8 Please download Exhibit Bfor review @ download.djiinnovations.com