Southeastern	Jet	Corporation

d/b/a:	Daedalus	Aerial	Productions

P.O.	Box	256

Lake	Arrowhead,	CA	92352

Owner/Operator

(561)	213-7151

DaedalusAerialProductions@gmail.com

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Petitioner	request for	FAA	Exemption	333 to	deploy small-UAS/s for	aerial	

photographic	data	collection	and	closed	set	motion	picture	and television filming.

Dear	Inspector:

Pursuant	to	the	statutory	criteria provided	in	Section	333	of	Public	Law	112−95	in

reference	to	49	U.S.C.	§ 44704,	and 14	CFR Part	11 General	Rule	Making	Procedures,	Peter	

C.	Loncteaux, owner	and	operator	of	Southeastern	Jet	Corporation d/b/a	Daedalus Aerial

Productions,	does	hereby	apply	for	an	exemption	from	the	Federal	Aviation Regulations	

(FAR) identified	below,	to	allow	commercial	use	of	small	unmanned aerial	systems	(sUAS)	

for	the	purpose	of	aerial	photographic	data	collection and	filmmaking	under certain	

conditions as set	forth	in	the Daedalus	Aerial	Productions Motion	Picture	and	Television	

Operations	Manual.

sUAS	equipment:	DJI	S1000+;	Phantom	3;	SenseFly	eBee;	SenseFly	eXom.

Petitioner	has	reserved	registration	numbers:	N618DA;	N619DA;	N618SJ;	and	N619SJ.

Petitioner	statement:	The	FAA	has	issued	grants	of	exemption	in	circumstances	similar	in	

all	material respects	to	those	presented	in	this petition.	In	Grants	of	Exemption	Nos.	11062	

to	Astraeus Aerial	(see	Docket	No.	FAA−2014−0352),	11109	to	Clayco,	Inc.	(see	Docket	No.

FAA−2014−0507),	11112	to	VDOS	Global,	LLC	(see	Docket	No.	FAA−2014−0382),	and

11213	to	Aeryon	Labs,	Inc.	(see	Docket	No.	FAA–2014–0642),	the	FAA has found	that	the

enhanced	safety	achieved	using	an	unmanned	aircraft	(UA)	with	the	specifications	

described by	this petitioner, and	carrying	no	passengers	or	crew;	rather	than	a	manned	

aircraft	of significantly	greater	proportions,	carrying	crew	in	addition	to	flammable	fuel,	

gives	the	Petitioner	good	cause	to	find	that	the	sUAS	operation	enabled	by	this	exemption	

is	in	the best public	interest.
Petitioner	Statement:	Relief	from	14	CFR	part	21,	Certification	procedures	for	products and	

parts,	Subpart	H—Airworthiness	Certificates.	In	accordance	with	the	statutory	criteria

provided	in	Section	333	of	Public	Law	112−95	in	reference	to	49	U.S.C.	§	44704,	and	in

consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the

aircraft	and	its	operation gives	the	Petitioner	good	cause	to	find	that	the	sUAS/s operation	

enabled	by	this	exemption	is	in	the best public	interest.

Petitioner	request:	Relief from	14	CFR	§§	Part	21	Subpart	H,	61.23	(a)	(1) and	(2),	61.113	

(a),	91.103	(b)	(2),	91.105,	91.109,	91.119	(a)	(b)	and	(c),	91.121	(a),	91.151	(a)	(1),	91.405	

(a),	91.407	(a)	(1)	and	(2),	91.409	(a)	(1)	and	(2),	91.417	(a)	and	(b)	to	the	extent	

necessary	to	allow	the	petitioner	to	operate	 sUAS/s to	perform aerial photographic data	

collection and	filmmaking; providing the	Petitioner	good	cause	to	find	that	the	sUAS/s

operation	enabled	by	this	exemption	is	in	the best public	interest.

Exemption	Request	Listing: Brackets	represent Petitioner	comments/responses	

1. § 11.81	What	information	must	I	include	in	my	petition	for	an	exemption?	 (1)	The	rule	

from	which	you	seek	the	exemption;	and	(2)	A	brief	description	of	the	nature	of	the	exemption	

you	seek; [See	beginning	with	number	2.]	(h)	If	you	want	to	exercise	the	privileges	of	your	

exemption	outside	the	United	States: [Petitioner	does	not	intend	to	exercise	exemption	

approval	outside	the	United	States.]

2. 49	U.S.C.	§	44704	- 14	CFR	part	21,	Subpart	H.	Certification	procedures	for	products	

and	parts,	Airworthiness	Certificates: [Petitioner	requests	relief	based	on	statutory	criteria	

provided	in	Section	333	of	Public	Law	112−95	in	reference	to	49	U.S.C.	§	44704	– 14	CFR	

part	21,	Subpart	H:	“that	in	consideration	of	the	size,	weight,	speed,	and	limited	operating	

area	associated	with	the	aircraft	and	its	operation,	and	any	associated	noise	certification	

and	testing	requirements	of	part	36,	is	not	necessary.”	This	determination	has	been	

established	by	the	FAA	in	previous	Exemption	333	petitions	and	approvals.]

3. § 61.23 (a) (1)	and	(2):	Operations	requiring	a	medical	certificate:	Except	as	provided	

in	paragraphs	(b)	and (c)	of	this	section,	a	person—(1)	Must	hold	a	first-class	medical	

certificate:	(2)	Must	hold	at	least	a	second class	medical	certificate: [Petitioner	requests	

relief	from	§ 61.23	(1)	and	(2).	It	is	implicit	that	First	and	Second class	medical	

authorizations	revert	to	third	class	medical	certification	when	exercising	the	privileges	of	a	

private	pilot	certificate.	Prior	FAA	Exemption	333	approvals	have	set	the	minimum	sUAS	
pilot	standard	as	either	a	Third	Class	Medical	Certificate	or	State	Driver’s	License.	The	

Petitioner	has	set	the	minimum	standard	at	Third	Class	Medical	Certification	as	stated	in	

the	company	Flight	Operations	Manual.]

4. § 61.113(a)	Private	pilot	privileges	and	limitations:	Pilot	in	command:	(a)	Except	as	

provided	in	paragraphs	(b)	through	(h)	of	this	section,	no	person	who	holds	a	private	pilot	

certificate	may	act	as	pilot	in	command	of	an	aircraft	that	is	carrying	passengers	or	property	

for	compensation	or	hire;	nor	may	that	person,	for	compensation	or	hire,	act	as	pilot	in	

command	of	an	aircraft. [Petitioner	requests	relief from	§	61.113(a)	based on	the	fact	that	

commercial	activities	involved	with	sUAS	operations	do	not	include	the	carriage	of	

passengers	or	property,	and	is	of	such	light	weight,	small	size,	and low	speed	that	the	

activity	poses	minimal	safety	hazards.	Additionally,	the	use	of	sUAS/s in	the	photographic	

and	cinemagraphic	context provides	public	services	otherwise	unobtainable	due	to	the	

very	hazardous nature	of flight	activities	involved	with	maneuvering	manned	aircraft.]				

5. § 91.103	(b)	(2)	Preflight	Action:	Each	pilot	in	command	shall,	before	beginning	a	

flight,	become	familiar	with	all	available	information	concerning	that	flight.	This	information	

must	include:	(b)	For	any	flight,	runway	lengths	at	airports	of	intended	use,	and	the	following	

takeoff	and	landing	distance	information:	(2)	For civil	aircraft	other	than	those	specified	in	

paragraph	(b)	(1)	of	this	section,	other	reliable	information	appropriate	to	the	aircraft,	

relating	to	aircraft	performance	under	expected	values	of	airport	elevation	and	runway	slope,	

aircraft	gross	weight,	and	wind	and	temperature. [Petitioner	requests	relief from	§	91.103	

(b)	(2) based	on	sUAS	aircraft	are	not	designed,	developed,	tested	or	certificated	by	the	

FAA,	as	such;	no	FAA	established/approved	performance	data	exists.	Available	sUAS	

performance	data	consists	of	manufacturer	published	maximum	altitude	limits,	wind	

limitations,	speed	limitations,	and	distance	from	base	station.	The	Petitioner	shall	always	

operate	the	company	sUAS	aircraft	within	the	manufacturer	published	limitations.	

Additionally,	per	the	company	Flight	Operations	Manual,	“each	pilot	in	command	shall,	

before	beginning	a	flight,	become	familiar	with	all	available	information	concerning	that	

flight	assuring	that	the	sUAS	aircraft	is	in	a	safe,	airworthy	condition.]		

6. § 91.105	Flight	Crewmembers	at	Stations:	(a)	During	takeoff	and	landing,	and	while	

en	route,	each	required	flight	crewmember	shall...(1)	Be	at	the	crewmember	station	unless	

the	absence	is	necessary	to	perform	duties...(2)	Keep	the	safety	belt	fastened	while	at	the	

crewmember	station...(b)	Each	required	flight	crewmember	of	a	U.S.-registered	civil	aircraft	

shall,	during	takeoff	and	landing,	keep	his	or	her	shoulder	harness	fastened...This	paragraph	
does	not	apply	if—(1)	The	seat	at	the	crewmember's	station	is	not	equipped	with	a	shoulder	

harness: [Petitioner	requests	relief from	§	91.105 based	on	sUAS	unmanned	operations	do	

not	permit	or	necessitate	the	use	of	safety	belts.	Additionally,	per	the	company	Flight	

Operations	Manual,	the	assigned	PIC	will	not	abandon	nor	change	pilot	duty	

responsibilities	during	any	portion	of	a	sUAS	flight.]	

7. § 91.109	Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests:	(a)	No

person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	being	used	for flight	

instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	However,	instrument	flight	

instruction	may	be	given	in	an	airplane	that	is	equipped	with a	single,	functioning	throwover	

control	wheel	that	controls	the	elevator	and	ailerons,	in	place	of	fixed,	dual	controls:

[Petitioner	requests	relief from	§	91.109 based	on	the	shift	in	flight	technologies	from	

manned	flight	to	drone.	Flight instruction	for	company	sUAS	aircraft	shall	occur	in	closed,	

secure	areas	with	only	essential	trainer/trainee	personnel	present.	Should	

nonparticipating	vehicles	or	pedestrians	enter	the	secure	area,	flight	training	shall	be	

immediately	suspended	until	corrected.]	

8. § 91.119	(a)	(b)	and	(c)	Minimum	safe	altitudes:	General:	(a)	Anywhere.	An	altitude	

allowing,	if	a	power	unit	fails,	an	emergency	landing	without	undue	hazard	to	persons	or	

property	on	the	surface.	(b)	Over	congested	areas.	Over	any	congested	area	of	a	city,	town,	or	

settlement,	or	over	any	open	air	assembly	of	persons,	an	altitude	of	1,000	feet	above	the	

highest	obstacle	within	a	horizontal	radius	of	2,000	feet	of	the	aircraft.	(c)	Over	other	than	

congested	areas.	An	altitude	of	500	feet	above	the	surface,	except	over	open	water	or	sparsely	

populated	areas.	In	those	cases,	the	aircraft	may	not	be	operated	closer	than	500	feet	to	any	

person,	vessel,	vehicle,	or	structure. [Petitioner	requests	relief	from	§ 91.119	(a)	due	to	the	

ability	to	preprogram	company	sUAS aircraft to	safely	auto-land	when	conditions	of	low	

battery	or	loss	of	GPS/radio	communications	occur, avoiding	undue	safety	concerns.														

§ 91.119	(b)	Petitioner	shall	not	under	any	circumstance	operate	company	sUAS	aircraft	

“over	any	congested	area	of	a	city,	town,	or	settlement,	or	over	any	open	air	assembly	of	

persons.”		§ 91.119	(c)	Petitioner	shall	not	operate	company	sUAS	at	a	distance	closer	“than	

500	feet	to	any	person,	vessel,	vehicle,	or	structure”	without	written	consent	from	an	

authorized	signatory	and	in	a	secure	area.	With	regard	to	§ 91.119	(a) (b)	and	(c)	in	its	

entirety,	no	company	sUAS	aircraft	shall	be	operated	at	an	altitude	that	exceeds	400	feet	

above	ground	level	(AGL)].	

		
9. § 91.121	(a)	Altimeter	settings:	(a)	Each	person	operating	an	aircraft	shall	maintain	

the	cruising	altitude	or	flight	level	of	that	aircraft,	as	the	case	may	be,	by	reference	to	an	

altimeter	that	is	set...:	[Petitioner	requests	relief from	§	91.121	(a) due	to	sUAS	equipment	

limitations	which	do	not	permit	the	installation	of	an	altimeter.	All	company	sUAS	aircraft	

are	equipped	with	GPS	and	use	above	ground	level	(AGL)	sUAS	controller	readouts	to	

determine	altitude.	Additionally,	FAA	regulation	does	not	apply	to direction	of	flight

altitude for aircraft	below	3,000	ft.	All	sUAS	aircraft	are	restricted	to	an	altitude	of	400	ft.]

10. § 91.151 (a) (1)	Fuel	requirements	for	flight	in	VFR	conditions:	(a)	No	person	may	

begin	a	flight	in	an	airplane	under	VFR	conditions	unless	(considering	wind	and	forecast	

weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed— (1)	During	the	day,	to	fly	after	that	for	at	least	30	minutes:

[Petitioner	requests	relief from	§	91.151 (a)	(1)	 based	on	the	difference	in	fuel	format	

calculations between	petroleum	operated engines	and	battery	electrically operated sUAS	

motors.	Company	sUAS	aircraft	on	average	are	capable	of	sustaining	25	minutes	of	flight.	

The	Company	Flight	Operations	Manual	dictates	that	sUAS	flights	must	be	discontinued	

when	battery	life	reaches	25	percent	of	total	useful	life	or	five	minutes	of	flight	time	

remaining	whichever	is	less.	All	company	sUAS	aircraft	controllers	are	capable	of	

determining	battery	energy	status.	All	company	aircraft	are equipped	to	auto-land	under	

low	battery	conditions	prior	to	complete	shutdown.]		

11. § 91.405(a)	Maintenance	required:	Each	owner	or	operator	of	an	aircraft—

(a)	Shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between

required	inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	

repaired	as	prescribed	in	part	43	of	this	chapter; [Petitioner	requests	relief	from	§	91.405

(a)	based	on	statutory	criteria	provided	in	Section	333	of	Public	Law	112−95	in	reference	

to	49	U.S.C.	§	44704	– 14	CFR	part	21,	Subpart	H:	“that	in	consideration	of	the	size,	weight,	

speed,	and	limited	operating	area	associated	with	the	aircraft	and	its	operation”	sUAS	

aircraft	are	exempted	from	aircraft	Airworthiness	Certification,	and	since	§ 91.405 (a)	

applies	to	Certificated	aircraft,	is	not	relevant.	Petitioner	shall,	as	outlined	in	the	Flight	

Operations	Manual,	conduct	pre-flight	inspections,	preventative	maintenance,	scheduled	

maintenance,	and	repair,	to	ensure	that the	sUAS	is	in	a	condition	for	safe	flight.]

12. § 91.407 (a) (1)	and	(2)	Operation	after	maintenance,	preventive	maintenance,	

rebuilding,	or	alteration:	(a)	No	person	may	operate	any	aircraft	that	has	undergone	
maintenance,	preventive	maintenance,	rebuilding,	or	alteration;	(1)	It	has	been	approved	for	

return	to	service	by	a	person	authorized	under	§43.7	of	this	chapter;	and	(2)	The	maintenance	

record	entry	required	by	§43.9	or	§43.11,	as	applicable,	of	this	chapter	has	been	made:

[Petitioner	requests	relief from	§	91.407 (a) (1)	and	(2)	based	on statutory	criteria	

provided	in	Section	333	of	Public	Law	112−95	in	reference	to	49	U.S.C.	§	44704	– 14	CFR	

part	21,	Subpart	H:	“that	in	consideration	of	the	size,	weight,	speed,	and	limited	operating	

area	associated	with	the	aircraft	and	its	operation”	sUAS	aircraft	are	exempted	from	

aircraft	Airworthiness	Certification,	and	since	§ 91.407 (a) (1)	applies	to	Certificated	

aircraft,	is	not	relevant.	Petitioner	shall,	in	a	timely	manner,	conduct	sUAS	manufacturer	

required/recommended	maintenance,	preventive	maintenance,	rebuilding,	and	alterations.	

When	such	maintenance	procedures	are	completed,	prior	to	sUAS	aircraft	commercial	use,	

preflight	and	flight	testing	shall	be	accomplished	to	ensure	that	the	sUAS	is	in	a	condition	

for	safe	flight.]

13. § 91.409 (a) (1)	and	(2)	Inspections:	(a)	Except	as	provided	in	paragraph	(c)	of	this	

section,	no	person	may	operate	an	aircraft	unless,	within	the	preceding	12	calendar	months,	it	

has	had— (1)	An	annual	inspection	in	accordance	with	part	43	of	this	chapter	and	has	been	

approved	for	return	to	service	by	a	person	authorized	by	§43.7	of	this	chapter;	or	(2)	An	

inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	part	21	of	this	

chapter: [Petitioner	requests	relief from	§	91.409 (a) (1)	and	(2) based	on	statutory	criteria	

provided	in	Section	333	of	Public	Law	112−95	in	reference	to	49	U.S.C.	§	44704	– 14	CFR	

part	21,	Subpart	H:	“that	in	consideration	of	the	size,	weight,	speed, and	limited	operating	

area	associated	with	the	aircraft	and	its	operation”	sUAS	aircraft	are	exempted	from	

aircraft	Airworthiness	Certification,	and	since	§ 91.409 (a) (1)	and	(2)	applies	to	

Certificated	aircraft,	is	not	relevant.	Petitioner	shall,	in	a	timely	manner,	conduct	sUAS	

manufacturer	required/recommended	maintenance,	preventive	maintenance,	rebuilding,	

and	alterations.	When	such	maintenance	procedures	are	completed,	prior	to	sUAS	aircraft	

commercial	use,	preflight	and	flight	testing	shall	be	accomplished	to	ensure	that	the	sUAS	is	

in	a	condition	for	safe	flight.]

14. § 91.417 (a)	and	(b)	Maintenance	records:	(a)	Except	for	work	performed	in	

accordance	with	§§ 91.411	and	91.413,	each	registered	owner	or	operator	shall	keep	the	

following	records	for the	periods	specified	in	paragraph	(b)	of	this	section;	(b)	The	owner	or	

operator	shall	retain	the	following	records	for	the	periods	prescribed: [Petitioner	requests	
relief	based	on	statutory	criteria provided	in	Section	333	of	Public	Law	112−95	in	

reference	to	49	U.S.C.	§	44704	– 14	CFR	part	21,	Subpart	H:	“that	in	consideration	of	the	

size,	weight,	speed,	and	limited	operating	area	associated	with	the	aircraft	and	its	

operation”	sUAS	aircraft	are	exempted	from	aircraft	Airworthiness	Certification,	and	since	

§ 91.417 (a) and	(b)	applies	to	Certificated	aircraft,	is	not	relevant.	[Petitioner requests	

relief	from	§	91.417 (a)	and	(b) and shall,	in	a	timely	manner,	conduct	sUAS	manufacturer	

required/recommended	maintenance,	preventive	maintenance,	rebuilding,	and	alterations.	

When	such	maintenance	procedures	are	completed,	prior	to	sUAS	aircraft	commercial	use,	

preflight	and	flight	testing shall	be	accomplished	to	ensure	that	the	sUAS	is	in	a	condition	

for	safe	flight.	Additionally,	Petitioner	will	retain	all	maintenance	records	accumulated	over	

the	life	of	each	sUAS	operated	for	as	long	as	the	sUAS	aircraft	is	operated.	Petitioner	shall	

make	all	maintenance	records	kept	by	this	section	available	for	inspection	by	the	

Administrator	or	any	authorized	representative	of	the	National	Transportation	Safety	

Board	(NTSB).]

Petition	Summary:

1. § 11.81	What	information	must	I	include	in	my	petition	for	an	exemption?		

(f)	A	summary	we	can	publish	in	the	Federal	Register,	stating:	

(g)	Any	additional	information,	views	or	arguments	available	to	support	your	request;

Pursuant	to	14	C.F.R.	Part	11 the	following	summary	is	provided	for	publication	in	

the Federal Register.

Southeastern	Jet	Corporation	d/b/a	Daedalus	Aerial	Productions	seeks	an	exemption	from	

the	following	rules:	14	CFR	§§	Part	21, Subpart	H,	61.23	(a)	(1)and	(2),	61.113 (a),	91.103	

(b)	(2),	91.105,	91.109,	91.119	(a) (b)	and	(c),	91.121	(a),	91.151	(a)	(1),	91.405 (a),	91.407

(a) (1)	and	(2),	91.409 (a)	(1)	and	(2),	91.417	(a)	and	(b) to	operate	commercially,	

unmanned	sUAS	aircraft	(55	pounds	or	less)	in	aerial	photographic	data	collection,	and	

motion	picture	and	television	operations.

Petitioner	represents	the	proposed	operation(s)	would	not	adversely	affect	safety,	and	will	

provide	a	level	of	safety	at	least	equivalent	to	that	provided	by	the	rule/s from	which	

exemption	is	sought.

Petitioner	represents	that	its	unmanned	aircraft,	as	a result	of	size,	weight,	speed,	
operational	capability,	proximity	to	airports	and	populated	areas,	and	operation	within	

visual	line	of	sight	does	not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	

public	or	pose	a	threat	to	national	security.

As	established	by	previous	FAA	Exemption	of sUAS	operations sanctioning commercial	use

of	sUAS/s	for aerial	photographic	data	collection and movie/television	filming,	Petitioner	

represents	its	sUAS	operations will	enhance	safety	by	reducing	risk	i.e., pre-drone	film

operations used manned, conventional and turbine powered aircraft,	associated with	

significant levels	of weigh,	speed,	and	fuel, operating at very low	altitudes exposing

personnel	and	structures to considerable hazard/risk.	This	is	contrasted	by dramatically	

reduced	sUAS size,	weight,	speed,	lack	of	combustible	fluids,	and vastly	improved

operational	capability (maneuverability) mitigating	the safety	risk/hazard potential.

Petitioner	represents	photographic	data	will	only	be	collected	from those	who	have

contractually agreed (Privacy).	Petitioner	will	not	enter	any	Restricted,	Special	Use	or	

Temporary	Flight	Restricted	areas	without	appropriate	Agency	approval.

Please	direct	all	questions	to	Pete	Loncteaux:	(561)	213-7151	(best)	or	

DaedalusAerialProductions@gmail.com

Regards,

Pete	Loncteaux

Southeastern	Jet	Corporation

d/b/a/	Daedalus	Aerial	Productions

P.O.	Box	256

Lake	Arrowhead,	CA	92352

(561)	213-7151

DaedalusAerialProductions@gmail.com