David Lucero

18710 Meridian Ave. E.

Suite 115, PMB x017

Puyallup, WA 98375

Email: visualartbydavelucero@gmail.com

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 11.81, David Lucero, hereby applies for an exemption from the

listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small,

unmanned aircraft for photogrammetry, photography/cinematography, industrial

inspections, search & rescue, and analyses. All operations shall be conducted within and

under the conditions and limitations outlined previously by the FAA as required by

Section 333 and conducted in compliance with the attached operator’s manuals.

1. Sections from which exemptions are sought: Application is hereby made for

exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought:

a. David Lucero wishes to operate small Unmanned Aircraft Systems (sUAS) for

commercial purposes to include (but not be limited to) photogrammetry,

photography/cinematography, industrial inspections, search & rescue, and

analyses. This relief is sought because commercial use of sUAS is currently

prohibited by law unless performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh

less than 55 pounds including payload and energy sources:

i. DJI Phantom 3 Professional (4­propeller frame, plastic):
1. Total weight with maximum allowable payload: 1280 grams, or

2.821 lbs.

2. Dimensions: Greatest width: 590mm (23.228in), Height (with

landing gear): 203mm (7.992 inches)

3. Maximum speed: 16 m/s

4. Intelligent Flight Battery system (1x 4­cell, 15.2 volt, 4480 maH

lithiumpolymer) provides twenty three (23) minutes of flight time.

5. Intelligent Flight Controller (with GPS and compass) is installed

on this sUAS, and is the most advanced system currently

available, with latest firmware release.

ii. Flight Controller and Fail­Safe systems:

1. The existing flight control technology that David Lucero utilizes

is the DJI Intelligent Flight Controller, which provides these safety

features:

a. GPS Attitude Control: Prior to flight operation, the GPS

records latitude and longitude, and that position becomes

the origin of flight. Once airborne, the GPS holds the sUAS

in this position, and does not deviate from it, unless the

operator changes the mode. This level of safety

safeguards the sUAS, preventing it from drifting away, and

posing a potential risk of injury or damage to property.

b. Attitude Control: The flight controller disables the GPS,

and allows operator to control the sUAS in a manner

consistent with manual flight. The onboard stability

systems keep sUAS horizontally stabilized, to prevent

erratic flight performance.

c. Return­to­Home (“RTH”): If the operator, under any

circumstances, deems the operation of the sUAS to

become a risk to persons, property, or the sUAS itself, the

RTH command may be invoked, safely returning the sUAS

to the origin of flight, subsequently landing and powering

down autonomously. This feature is a design protocol that

allows the operator to dismiss operation in the event of his

or her inability to control the sUAS, as in with an

emergency situation.

iv. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of sUAS technology to obtain imagery, information and data currently

obtained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents

(e.g., infrastructure inspections) and due to other dangerous activities that
can be avoided (e.g., scaffolding/rigging failures during stack or bridge

inspections).

ii. Reduces the cost of obtaining such information, which benefits

consumers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and

Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the

manufacturer. All repair and maintenance work will be conducted or approved by

qualified personnel such as those authorized by DJI (or equivalent), and will

require a test flight after such work. Records of all maintenance and repair work

will be kept in a maintenance log for each aircraft.

c. All operations will be conducted in accordance with valid Certificates of

Authorization.

d. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

ii. Flight Operations and Procedures Manual (FOPM) and Aircraft Flight

Manuals (AFM), which include lost communication and other emergency

and safety procedures.

iii. Conducted in VMC conditions during daylight hours.

iv. PIC will maintain VLOS at all times.

v. Pre­flight inspections (including ground control station, if any) and

safety risk assessments will be conducted prior to each flight.

vi. Flight altitudes will remain below 400 feet above ground level.

vii. Flight ground speeds will not exceed 50 knots.

viii. Not intrude into Class B, C or D airspace, or published approach, SID

or STAR, or take place within 5 nautical miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over

persons on the ground without their prior permission.

x. Each flight will be logged in both the PIC’s logbook and the aircraft

logbook.

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30

minutes, whichever occurs first.

xii. Any incidents will be reported within 24 hours of occurrence.

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of

aircraft.

e. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft

with well­defined and tested lost link procedures. Please advise of any additional

information or changes that may be required.
Sincerely, David Lucero