March 27, 2015 

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 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 Administration to conduct sUAS flights over 

the following tasks: 

l. Land Surveying 

2. Engineering Developments 

3. Pipeline Inspections 

4. Realty 

As an experience Radio Control Pilot/Operator and member of The Academy of Model 

Aeronautics member# 945273. allows for me the experience to review the most efficient flight 

plan. This knowledge base has come through years of piloting, maintaining. and repairing sUAS 

and Radio Controlled Planes. The pilot/operator and observer are both certified in first aid and 

CPR through training provided by the Red Cross. 

Pursuant to Section 3 3 3 of the FAA Modernization and Reform Act of 2012 (the "Reform 

Ad') and 14 C.F .R. Part 11, I, Rolando Chavez petitions the FAA to allow safe flight operation 

of its sUAS for the commercial purpose of gathering aerial data of the aforementioned tasks. I, 

Rolando Chavez hereby applies for an exemption fl'om the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of its sUAS. so long as such operations are conducted 

within and under the conditions outlined herein 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 with the 

equivalent level of safety set forth in Exemption 11062 and the related exemptions issued to 

sUAS companies for scripted closed set filming for the motion picture and television 

Industry. 

As described more fully below. the requested exemption would pennit the operation of small, 

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 of this exemption would thereby enhance safety and 

fulfill 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 

(NAS)." Section 333(c) of the Reform Act. The name and address of the applicant is: 

Rolando Chavez 

716 Amber Ave. 

Laredo, Texas 78045 . 

FAA sUAS Registration# A/Te!Jtl..3~ 

Regulations from which the 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 submitted to fulfill Congress' goal in passing Section 

333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmarmed aircraft systems may operate safely in the national airspace 

system (NAS) before completion ofthe rulemaking required LUider Section 333 ofthe Reform 

Act. In making this detenuination, the Secretary is required to determine which types of 

UASs 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 populated areas; and operation of the 

UAS within visual line of sight of the operator. Lastly, if the Secretary deten11ines that such 

vehicles "may operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such 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 authority to issue exemptions. This statutory authority by its 

terms includes exempting civil aircraft, as the term is defined under Section 40101 of the Act, 

which includes sUAS, frmn the requirement that all civil aircraft must have a current 

ainvorthiness certificate. The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of Section 333 or any Sections 4470244716 of 

the Transportation Act if the Administrator finds the exemption in the public interest. 49 U.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 of commercial operation of aircraft without a pilot's license. Based upon the 

spirit of Section 333, and the continuing integration of small UAS1

s into the NAS, I Rolando 

Chavez submits this petition for review and approval. 

Finally, I Rolando Chavez; in order to provide the total safety and protection of the 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 

of sight of the PIC and VO and as provided by the "UAS safe flight operations manual" as it 

pertains to accident scenes as Exhibit A. I, Rolando Chavez submit the "UAS manufacturer 

flight and operational manual" as Exhibit B. Operational compliance of Exhibit A and B shall 

insure safe flight operations within the boundaries of the work site. Compliance outlined in 

Exhibit A and B shall also insure safe flight sUAS operations within the 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 of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the operations normally 

conducted with meumed aircraft. These limitations and conditions to which I, Rolando Chavez 

agrees to be bound 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 of the 

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 of sight (VLOS) of the PIC and VO at all times. 

This requires the PIC to be able to use hmnan vision unaided by any device other than corrective 

lenses, as specified on the PICs FAA issued third class medical certificate. 

6. All operations must utilize a visual observer (VO). The YO may be used to satisfy the 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 bound by and follow Exhibits A & B. Any additional requirements 

identified in the final conditions for this exemption will be added to Exhibits A & B. Exhibits A 

& B will be maintained and made available to the Administrator upon request. lf a discrepancy 

exists between the conditions and limitations in the final exemption and the procedures outlined 

in Exhibits A & B, the conditions and limitations of the 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. It will be the operatorjs responsibility to 

track such revisions and present updated and revised documents to the Administrator upon 

request. The operator will also present updated and revised documents if it petitions for 

extension or amendment. If the operator determines that any update or revision would affect the 

basis fbr which the FAA granted this exemption, then the operator will petition for amendment to 

their exemption. The operator will contact the FAA's UAS Integration Office (AFS80) 'With 

questions that may arise regarding updates or revisions to Exhibits A & B. 

9. Prior to each flight the PIC will inspect the sUAS to ensure it is 

in safe flight condition. The procedures for preflight inspection and functional viability of all 

sUAS components are outlined in Exhibit A & B. 

10. All sUAS flights will only be conducted during daylight hours. No night flights of sUAS 

will be conducted. 

11. The operator will comply with the manu.factu:rds recommendations pertaining to 

maintenance, inspection and replacement ofUAS components. The maintenance manual, 

submitted as Exhibit C, outlines these components. 

12. Prior to operations conducted for the purpose of gathering aerial data, the PIC will have 

accumulated and loggedj in a manner consistent with 14 C.P.R.§ 61.5l(b), a minimum of300 

flight cycles and 30 hours of total time as a UAS multirotor aircraft pilot and at least 20 hours 

logged as a UAS pilot with a similar UAS 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 under this 

grant of exemption to accomplish the required flight cycles and flight time. During training, 

proficiency. and experience building flights, all persons 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, 

~h 
EXHIBIT A. 

Preflight 

Procedures specific to sUAS operations for the purpose of the specified commercial use: 

1. If available, bolUldaries of the s UAS operation will be clearly marked that a UAS 

operation will be in effect. The clearly marked identifiers will specify that non-authorized 

individuals must remain 500ft from the UAS operation. Authorized individuals will sign 

a consent to enter the UAS operational theater. 

2. Individuals working within the area of UAS operation will be llOtified that a UAS 

operation \:vill be in effect. 

3. The area ofUAS inspection will be observed for obstacles that may interfere with safe 

operation. If obstacles exist that would affect UAS operations the VAS operation will 

cease. 

4. All operation flights of the sUAS will be conducted llllder 200ft. AGL. 

5. No sUAS flights will be conducted in rain, 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 batteries both from the transmitter and sUAS vvill be fully charged and verified before 

take off. 

8. Perso!ll1el at the Air Control Tower (ACT) From Laredo. Texas International Airport will 

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 updated and the sUAS tested before any flight mission_ 

10. All maintenance checks will be conducted prior to each sUAS flight. 

11. No sUAS flights will be conducted within 5 1niles of an airport. 

12. All sUAS flights will be conducted within Visual Line of Sight (VLOS). 

13. No sUAS flights will be conducted unless 8 or more GPS satellites are acquired for 

safety. If no more than 8 GPS satellites are acquired, no flights will be allowed. 
Exhibit B 

Phantom 2 Vision Manual Vl. 8 

Please download Exhibit B for review @ 

download.djiinnovations.com