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MicroCopter Pro 

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August 1, 2014 

US Department of Transportation and 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear US DOT and FAA Officials: 

The name and address of the applicant is: 

P. (787) 644-2917 

F. (787) 293-1008 

• PMB 163 Suite 101 

220 Western Auto Plaza 

Trujillo Alto, PR 00976 

info@MicroCopterPro.com 

Re: Waiver, Authorization and/or Exemption 

Request by the US Congress PL 11 2-95, 

2012, Section 333 -FAA Reform Act- for 

limited, safe and responsible commercial use 

of Small Unmanned Aircraft (SUA). 

MicroCopter Professional Services Inc. (MicroCopter Pro): 

President: 

Phone: 

Email: 

Address: 

Sergio Montanez 

(787) 644-2917 

sergio@MicroCopterPro.com 

PMB 163 Suite1 01 

220 Western Auto Plaza 

Trujillo Alto, Puerto Rico 00976 

This application is being submitted on our own behalf, since we do not have sufficient economic 

resources to retain legal council or consulting services. 

The contents of this application, however, are drawn on decades of the cumulative knowledge, 

skills, and advanced techniques learned through experience of our associates on the operation 

and maintenance of Small Unmanned Aircraft (SUAs), as defined by the US Congress in 

Section 331, PL 11 2-95, 2014: ... "6) SMALL UNMANNED AIRCRAFT. -The term "small 

unmanned aircraft" means an unmanned aircraft weighing less than 55 pounds." ... 

With this definition, the US Congress established an important distinction for this type of 

"unmanned aircraft", differentiating them from other unmmaned aircraft which could pose 

greater hazards and require a more rigorous evaluation on the part of the FAA. In recognition of 

the preceding, the US Congress also established an expedited and short-term process, 

conducted under special rules and by way of exception, so that the US DOT-FAA could 
Application 

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authorize the integration of some of these SUAs into the NAS prior to concluding the studies 

ordered under Section 332 of that same law. 

In summary, we have before us the following matters: 

(a) Recognition by the US Congress that some of these SUAs must be integrated into 

the NAS in a short-term basis, taking into account their physical, operational and security 

features. 

(b) The discretion which the US Congress granted the US DOT-FAA to direct special 

rules for this short-term authorization. 

(c) Requests for exemption and authorization such as ours. 

(d) The allegations that these devices will be dangerous in the sky when, in reality, we 

are not seeking to operate them in the airspace of any commercial or manned aircraft. 

(e) The illogical assertion that, in order to operate an SUA commercially at less than 400 

feet above ground, far away from any airport and within the visual scope of vision of the 

operator, a pilot's license would be necessary. The preceding ignores the fact that the 

most experienced pilot of a Boeing 777 would crash an SUA as easily as an SUA 

operator would crash a Boeing. This also ignores the fact that, for a number of decades 

now, even chi ldren and young people have been freely operating these devices as 

Model Aircraft and no catastrophes or mayor accidents as foreseen detractors have 

occurred. 

As pointed out in this application, all the SUAs which our company would use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of 

sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles 

from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, 

unless the air traffic control authorities (ATC) have been notified and have authorized each flight 

within a radius of this distance. 

All our SUAs have proven capability for controlled flight. They are devices offered for general 

sale on the market around the world and have often been used as Model Aircraft in the USA. 

We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 

112-95, 2014, have already provided you with the assurances on the airworthiness of SUAs 

such as ours. 

In the specifications provided, you will see that the flight characteristics, with the addition to the 

skills of our operators and the security rules and procedures we operate by, comply with the 

concept of "Sense and Avoid Capability". 

The submission of this application and its contents is the best demonstration that indeed it is 

possible to pursue the authorization process so that some SUAs may be used for legitimate 

commercial activities and under reasonably safe conditions. 
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No person or company which exposes itself to an evaluation by the US DOT-FAA, with the 

submission of applications of this type, would do so intending to use SUAs in an irresponsible or 

dangerous manner, having been previously identified, registered and subject to supervision by 

our Government. 

The US DOT-FAA does not wish our National Airspace System (NAS) to be used irresponsibly. 

Nor would any person or company which is submitting an application such as this wish to use 

the NAS in an irresponsible way. Even less are we interested in exposing ourselves to the 

consequences of civil, criminal or even financial liability of such irresponsible behavior. In fact, a 

company such as ours dreads to damage our own equipment by misuse, since such devices 

and their components are our tools and source of income. 

Therefore, what is needed is what has been occurring: that the US DOT-FAA would direct an 

opening under Section 333 so that responsible, productive citizens, sponsoring the innovation 

which strengthens our national life, could be given the opportunity to undergo evaluation by the 

authorities, to be identified in their activities, and to commit to acting in a constructive and 

responsible way or confront the consequences of behaving otherwise. 

MicroCopter Pro is a small company that has recently registered on the Registry of Corporations 

of the State Department in San Juan, Puerto Rico, under No. 339370 and Employer 

Identification Number: 66-.XX-2686. Its commercial purpose is to consolidate activities of Hobby 

Shop and offer Professional Services with the use of small and light-weight microcopters: 

(1) Hobby Shop - the sale of these small and light-weight devices, primarily multi-rotor 

(microcopters), for recreational purposes; and 

(2) Commercial and Professional Services - with our own operators and specialized 

devices for conducting aerial filming and inspections under contract with industries, 

private and public sectors, including air filming services for commercial and television 

purposes. 

As is known, the activities described under Point (1) do not form part of this application, since 

they fall under the scope of Hobby Shop. We only point them out for information purposes, so 

that the US DOT-FAA will have the fullest understanding possible of our commercial intentions. 

The present application, however, focuses on the activity described in a general sense under 

Point (2). Despite the fact that we have the best equipment in Puerto Rico with professional 

features and extremely skilled operators, as of the present, we have not yet offered these 

services whi le waiting for a mechanism granted by US DOT-FAA, which would allow us to 

engage in these activities in a legal, safe, registered and organized way. 

We understand that such mechanism is already available, when it was made public that the US 

DOT-FAA is accepting these applications through Section 333. 

We recognize the enormous investment of money, time and resources which our government 

has made in order to achieve the future integration of Unmanned Airspace Systems (UAS) into 
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Application to FAA 

Section 333, PL 112-95, 2014 

August 1, 2014 

Page:4 MlcroCopter ~ Pro ~ 

the National Airspace System This is the public policy in our country: safe and organized 

integration. 

All these efforts require a great deal of time. In addition to establishing all the time frames by 

which the FAA will achieve the greatest possible integration for UAS, our Congress, in its 

wisdom, has made an expedited and temporary mechanism available, when it made it feasible, 

through Section 333, to integrate some of these devices in the short term, provided that it can 

be demonstrated that their specifications and operating conditions are safe. This reasonable 

and practical public policy harmoniously combines in a preventive way with the main concerns 

that arise in regard to this subject until such time as permanent regulations can be reached after 

completion of the studies. 

The key concept in this matter is Reasonableness. 

As responsible citizens, we share the same concerns as the US DOT-FAA: 

1. The safe and organized use of traffic in the NAS. 

2. Prevent groups or individuals from using the NAS for conducting illegal, terrorist, 

dangerous activities or activities that are contrary to the protection of civil rights. 

3. Prevent groups or individuals from using the NAS to adversely affect the operation of 

government institutions, including those of law and order. 

4. To protect the safety of persons and property in the NAS and surface. 

All human activities in the operation of equipment entail risks. But this does not mean that all 

devices which entail risks must be prohibited or regulated to the extreme degree of imposing a 

prohibition in practical terms. Under this premise, nearly everything would have to be prohibited: 

planes, helicopters, spacecraft, cars, bicycles, and even kitchen knives. Similar kinds of 

prohibitions would never occur to anyone, despite the fact that the equipments described above 

entail more risks and have produced more accidents, injuries and deaths than those which have 

been produced or which could be produced by Small Unmanned Aircraft (SUAs), which will form 

part of our commercial activities. 

We all know that what makes a particular piece of equipment hazardous or dangerous is not 

whether money is charged for using it. In the final analysis, it would be irrelevant, from a 

preventive or investigative perspective or with the intention of serving the ends of justice, 

whether or not some person, criminal or terrorist had used an SUA irresponsibly in exchange for 

money. His crime would be to have caused hazards or damages. And, in order to commit a 

crime, he could have to use an aircraft-- whether manned or not-- that is regulated by the FAA, 

a car, a bicycle, and even his own hands. 

In reality, what defines whether a piece of equipment is feasibly and reasonably safe are its 

specifications, its operating features and the safety controls which are applied during its use. It 

is for this reason that we support the wisdom of the US Congress in adopting Section 333 and 

the US DOT-FAA, when it put this opening into place. We trust that the present application will 

be evaluated in light of that same open, practical and reasonable vision. 
Application to FAA 

Section 333, PL 112-95, 2014 

August 1, 2014 

Page: 5 MicroCopter ~ Pro ~ 

As you will conclude when evaluating our application, all our equipment and operating 

procedures propose less risks to the NAS and to the safety of persons and property on the 

ground than those which the FAA requires in order to grant exemptions, for instance, with Order 

8900.1 CHG 0, Volume 3, Chapter 8 - Issue a Certificate of Waiver for Motion Picture and 

Television Filming and waivers related to FAA, Form 7711-1. 

Therefore, this mechanism to open the process and conduct evaluations which is being offered 

by the FAA through Section 333 also merits our acknowledgment. The fact that one owns an 

SUA should not confer an automatic right to its unlimited or commercial use, without first 

submitting to a process which would permit the evaluation and approval by the FAA. 

Taking the foregoing into consideration and the reasonable and practical special rules set by the 

US Congress when it approved Section 333, Public Law 11 2-95, 2012, that a waiver be granted 

to us from the requirements set forth in: 14 CFR 21, subpart H; 14 CFR 45.23 (b); 14 CFR 

61. 11 3 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91. 109; 91.11 9; 91.121; 91.1 51 (a); 

91.203 (a) and (b); 91.405 (a); 91.407 (a)(1 ); 91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) and 

(b), inasmuch as it deals with conditions that clearly do not apply to the commercial use of 

SUAs, as described in this application. 

We commit ourselves to this process and to be safe participants in our NAS in a limited way, 

within the operating and safety parameters set forth in this application. 

Cordially, 

Note to US DOT-FAA: 

For obvious reasons, we ask the US DOT-FAA to keep CONFIDENTIAL the information 

presented on this application owned by our company including: our Manual: Security and 

Operational Rules, our Equipments Physical and Technical Specifications, our working Forms 

and the personal data of our team. (Appendix A-B-C-D and E) 
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Application to the US DOT-FAA 

MicroCopter Professional Services Inc. 

(MicroCopter Pro) 

August 1, 2014 

Re: Waiver, Authorization and/or Exemption 

Request by the US Congress PL 11 2-95, 

2012, Section 333 -FAA Reform Act- for 

limited, safe and responsible commercial use 

of Small Unmanned Aircraft (SUA). 

MicroCopter Professional Services Inc. (MicroCopter Pro) is submitting this application, through 

the mechanism of the special rules provided under Section 333, Public Law 11 2-95, 201 2, as 

follows: 

(1) That, taking into consideration: 

(a) the types of Small Unmanned Aircraft (SUAs) that are small, light-weight, low-speed, 

multi-rotor and with other features described in the section on specifications in this 

application; 

(b) the operating flight and safety controls which we are describing here and with which 

we are obligated to comply; 

(c) the certifications of liability and compliance, which we attach hereto; 

(d) the operating skills and experience of our staff, which we described herein; 

(e) the lawful nature of the commercial activities in which we are seeking to engage with 

the use of the specified SUAs; and 

(f) the need in the industry for the professional and commercial services which we are 

able to offer in a safer, more cost-effective and accessible way than other 

conventional methods which are used for these services; 

the US DOT-FAA grant us authorization to offer these professional services and use the 

SUAs specified herein or their equivalents commercially in a limited manner, subject to 

what is set in this application and any other conditions which the US DOT-FAA 

understands must be amended or included. 

(2) Also taking the foregoing into consideration and the reasonable and practical special 

rules set by the US Congress when it approved Section 333, Public Law 11 2-95, 201 2, 

that a waiver be granted to us from the requirements set forth in: 14 CFR 21, subpart H; 

14 CFR 45.23 (b); 14 CFR 61.11 3 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 
Application 

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91.109; 91.119; 91.121; 91 .1 51 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 

(a)(2); 91.409 (a)(2) and 91.417 (a) and (b), inasmuch as it deals with conditions that 

clearly do not apply to the commercial use of SUAs, as described in this application. 

(3) Commercial Activities: That, within the conditions described in this application and 

others which the US DOT-FAA understands must be amended or included, authorization 

be granted us to use Small Unmanned Aircraft (SUAs), as described herein, which are 

equipped with cameras and sensors, in order to engage in the following commercial 

activities: 

(a) Video filming by air and photographing for public and private purposes, including: 

television, cinematography, advertising, promotions, public or news mass events. 

(b) Video filming by air and photographing to support professional operations in 

engineering, land surveying, architecture, real estate and other related professional 

activities. 

(c) Inspections by air of agricultural areas. 

(d) Inspections by air of infrastructure such as bridges, highways, electrical installations, 

dams, aqueducts, phot6voltaic power stations, wind farms and pipes, only under 

contract with the owners or with any local government authority. 

(e) Inspection by air of land and residential, commercial and industrial structures, only 

under contract with the owners or with any local government authority. 

(f) Inspections by air to detect sources of pollution and gas emissions, under contract 

with the owners in the area or with any local government authority. 

(g) Support provided to search and rescue operations and reconnaissance in cases of 

need, emergency or natural disasters and only when government authorities have 

requested it by contract or donation. 

(h) To offer training to persons, private and public entities which are interested in the use 

of SUAs, for purposes of enhancing the skills and safety controls which make the 

NAS safer and for the protection of persons and property. 

(4) To offer the aforementioned services, MicroCopter Pro possesses: 

(a) SUAs and electronic components which are adjusted to the parameters set by the 

US Congress in Section 333 and as we describe in the section on specifications in 

this application, including their proven controlled flight capacity (airworthiness). 

(b) Skilled and experienced personnel, as we have described in this application. 

(c) the most advanced cameras, sensors and software in the industry, in accordance 

with the specifications set forth in this application. 
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(d) With the moral and legal obligation to comply rigorously with all the conditions and 

safety rules which are defined in this application and those which the US DOT-FAA 

understands must be amended or included. 

(5) Skilled personnel and Certifications: We will demonstrate the legal obligations and 

medical condiction of all those persons at our company who will be directly engaged with 

the commercial operation of the SUAs, including the owner and the partners and, 

primarily, those who will perform functions such as the Pilots-in-Command (PICs), the 

Observers and the repair and maintenance technicians of the SUAs. Documents, 

Affidavits and Certifications are attached. Together with this application to the US DOTFAA, the following is included in Appendix A: 

(a) The description of the experience and skills possessed by the Pilots-in-Command 

(PICs), the Observers and the repair and maintenance technicians of the SUAs, in 

order to guarantee safe flights and the proper operation of their components. 

(b) A Birth Certificate, issued by the state government authority in our jurisdiction. 

(c) A sworn Affidavit of each person mentioned in the preceding paragraph (5), with a 

signature affixed on the original document and identified by name and the employer 

social security number of the company and of each person signing, on which they 

assure that: 

They are familiar with the FAA legal provisions and operating rules contained in: 

I. 49 USC 40103 (b)(2) (authorizing the FAA to prescribe air traffic regulations 

to protect people and property on the ground. 

II. 14 CFR sections: 91.1; 91.13 through 91. 15; 91.113; 91.126 through 91.135; 

91.137 through 91.145 and 14 CFR Part 73. In general, those rules establish 

requirements for operating in the various classes of airspace and near 

airports in non-designated airspace, in order to minimize risk of collision in 

higher traffic airspace. Other rules in 14 CFR, Part 91, or other parts of the 

regulations, may apply to SUA operations, depending on the particular 

circumstances of the operation. The regulations cited above are not intended 

to be an exhaustive list of rules that could apply to SUA operations. The FAA 

anticipates that the cited regulations are the ones that would most commonly 

apply to SUAs in commercial operations. 

Ill. Recognized and agree that the safety rules which may be established by the 

FAA at any time will have priority over any others. 

In these sworn Affidavit we also assure that the authorized SUAs and their 

components will NOT to be used to: 
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I. Perform or support - whether directly or indirectly - an illegal activity under 

federal, state or municipal laws. 

II. Provoke accidents, risks or damage to persons, property or aircraft in the 

National Airspace System due to the non-observance of the safety rules 

outlined by the FAA. 

Ill. Nor obstruct - whether directly or indirectly - the operations of any public 

agency, including those related to public transportation or agencies entrusted 

with law enforcement. 

IV. Violate the rights of others, including their rights to privacy and intimacy. 

V. Never to violate the rights to privacy and intimacy of persons through images 

in which the identity could be distinguished and without having been 

authorized in writing, unless that film or photographic material forms part of a 

public news or mass event; and 

VI. that, in those cases of images of residential structures or private vehicles 

where the identities of same can be distinguished, never to take such images 

· from an SUA for commercial purposes, unless their owners or some 

government agency with due authority has been authorized in writing that 

said images can be taken and used from the air. 

(d) Medical Certificate: Pilots-in-Command (PIC) and Observers current Second Class 

airman medical certificate that has been issued under 14 CFR 67, Medical Standards 

and Certification. 

(6) Insurance: We are managing an insurance with public liability policy with maximum 

coverage of one million dollars (US $1 ,000,000) to compensate for possible damage to 

persons and property during our activities. That policy will take effect within twenty-four 

(24) hours after the FAA has issued authorization in writing and prior to undertaking the 

first authorized commercial flight. 

(7) Security and Operational Rules: We describe all those rules which will be rigorously 

followed when performing our operations, including those rules before, during and after 

each flight. In addition to the safety standards which we describe in this application, the 

safety rules established by the FAA will also be rigorously followed. 

At such time as this application is authorized by the US DOT-FAA, we recognize and 

agree that it will be strictly limited to legitimate commercial activities, the operating 

conditions, the safety rules and the types of equipment or their equivalents which are 

contained in said authorization. We also recognize and agree that any other element that 

is not s·pecifically authorized by the FAA will require a new application for evaluation or 

the submission of another application to amend the authorization previously granted. 
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The "Manual: Security and Operational Rules" which, at a minimum, all SUA operators at 

our company know and observe, primarily the Pilots-in-Command (PIGs) and the 

Observers, are shown on Appendix B. 

Legitimate Commercial Activities: We describe those activities which form part of this 

application, the safe way in which we will perform them, and we explain how the use of 

SUAs represents a more cost-effective, accessible and safe alternative when engaging 

in these commercial activities than other conventional methods. (See Appendix C) 

MicroCopter Pro Operating Forms: We show those which will be used to guarantee 

safety during all flight operations: "SUA Flight Checklist (SFCL)" and "SUA Commercial 

Flight Register" (SCFR) (See Appendix D) 

Equipments Physical and Technical Specifications: We describe those which pertain 

to SUAs and their components or equivalent devices, which would be used by 

MicroCopterPro in its commercial activities authorized by the US DOT-FAA. At a 

minimum, our equipment complies with the following features: 

(a) The part of the SUAs of the largest size shall not exceed 4.5 feet long and, in flight, 

the total weight of the SUA will not exceed 55 pounds, including all its components 

and equipment. In fact, none of our SUAs exceeds 25 pounds at the time of flight, 

including all their components. 

(b) The maximum speed in flight of these SUAs will not exceed 50 knots (57.539 mph). 

(c) When SUA, their equipment and components exceed the 15 pounds of weight at the 

time of the flight, they will use a system of parachute activated by Radio Control for 

the purpose of eliminating or minimizing possible damages during any accident. Our 

system is: Mars Parachute for UA V's. This system is capable to work on aircraft of 

up to 25 pounds utilizing a high energy compression spring and a servo to deploy the 

chute and reduces the falling speed of craft in the event of a malfunction. 

(d) The Pilot-in-Command (PIC) of the SUAs are responsible for a thorough preflight 

inspection of the SUAs. Flight operations will not be undertaken unless the PIC 

verifies that the SUAs is airworthy. 

(e) The Pilot-in-Command (PIC) of the SUA will never fly distances that exceed the 

scope of his natural line of sight. 

(f) Its flight systems are supported electronically by GPS and the "Safe Return" 

mechanism to guarantee that, in the event of the loss of the radio control signal, 

battery charge or fuel, the SUA can return to the point of take-off in an autonomous 

and safe way. The point of take-off and "Safe Return" are always located within a 

safety perimeter. 

(g) The Safety Perimeter is that area selected by the Pilot-in-Command (PIC) prior to the 

flight and where the possibility of contact between SUAs and persons outside their 
Application to FAA 

Section 333, PL 11 2-95, 2014 

August 1, 2014 

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operation, ground or air vehicles, electrical cabling or explosive or dangerous 

material deposits as defined by federal and state law, is minimal or non-existent. 

(h) All our SUAs operate with propellers. Only those manufactured from flexible 

materials, capable of breaking up upon impact with other objects, will be used. 

Propellers manufactured with any type of metal in the blades will never be used. 

(i) Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 20% battery power reserve. 

U) All our SUAs authorized for these commercial activities wi ll have, to firmly adhered to 

the surface of the most resistant part of their structure, a light-weight plate on which 

is engraved - not written in ink - the name of our company, a brief description of the 

type of SUA, our phone number and the code which the FAA will assign on the 

authorization notice to our company. 

(See the technical specifications for each SUA on Appendix E)