Sean Lucas

132 E. Alcove Dr. 

Grand Junction CO 81507

970-245-8662

email: ep.videopro@gmail.com

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

Dear Recipient,

 In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, I Sean Lucas, 

referred to as the petitioner, kindly request exemption from the following sections of 

Title 14, Code of Federal Regulations §§ 

14 C.F.R. 61.113(a)

14 C.F.R. 61.113(b)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409 (a)(1) 

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a) & (b)

I the Petitioner seek relief from the listed regulations in order to operate small 

unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) for the purposes of aerial photography, 

cinematography, videography and other aerial operations that can be performed safely 

and more cost effectively with the use of small UAS at low altitude within the U.S. 

national airspace system as compared to a manned aircraft. Safe UAS operations 

conducted within FAA guidelines will support local business and create positive 

awareness in the community by providing UAS alternatives to previous methods of 

larger, more dangerous aircrafts. Compensated tasks will be conducted only at the 
request of and with authorization and permission of clients or their authorized agents 

in compliance with privacy Laws and FAA Regulations. In addition, only the 

authorized individual/Operator, Sean Lucas will conduct UAS flights within and 

under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.

The FARs 

I, The petitioner seek exemption from the above mentioned FARs for the following 

reasons; 

61.113(a) & (b)

The petitioner requests relief in order to facilitate the utilization of an experienced 

UAS operator with the addition of a trained observer. All pre-flight inspection, 

maintenance and flight logs will be saved and made available to the FAA and 

Secretary of Transportation (SoT) for review; with the purpose of safely integrating 

civil UAS operation in the National Airspace System. The petitioner will conduct 

flights as the authorized UAS Operator. The UA controlled by the Operator will 

perform at altitudes well below the permissible limits for other civil aircrafts, 

eliminating the risk to other aircrafts.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted 

closer than 500 feet to the ground may require that the UAS be operated closer than 

500 feet to essential persons, or objects that would not be possible without additional 

relief. The petitioner requests modification, waiver or exemption and clarification 

concerning the terms “congested areas” and “densely populated”. The petitioner 

requests waiver for this condition to allow reasonable and responsible operations in 

areas of subdivisions and neighborhoods if required. The petitioner will primarily 

operate the UAS between ground level and 200 feet. The UAS will be operated over 

designated properties with the consent of the local municipality or their designated 

agent and while maintaining a safe distance from persons. The petitioner will compile 

flight data from the logs. This data may assist the FAA in development of regulations 

for commercial operations in low-risk, controlled environments.

91.121 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric 

sensor for altitude information. Altitude information is generated by the UA on board 

computing system, its then received and displayed at the operators ground station. 

91.151(a) 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar 

UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for 
daytime, VFR conditions. The UAS provides battery power remaining in percent to 

the PIC. The UA batteries provide approximately 25 minutes of powered flight. 

Information provided in the operating documents discusses procedures regarding 

remaining battery power management. Those documents contain a condition in which 

the PIC will initiate a landing procedure when battery remaining reaches a specified 

level. Given the limitations on proposed operations and the location of those proposed 

operations, The FAA found that a reduced minimum power reserve for flight in 

daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes 

to inspect and ensure that the UAS is in a condition for safe flight in accordance with 

the operating documents. The FAA found that adherence to the petitioner’s operating 

documents and the conditions and limitations specified, describing the requirements 

for maintenance, inspection, and record-keeping, were sufficient to ensure that safety 

would not be adversely affected. 

Areas of interests for UAS commercial use

Aerial video and or photography for real estate, architecture, agriculture, land 

surveying, engineering, television, cinematography, and news media. Aerial 

inspections and or photography of residential or commercial structures, utility 

infrastructures including but not limited to electrical power lines, wind turbines and 

cell towers. In addition, live streaming aerial video in efforts assist in search and 

rescue operations ONLY at the legal authorization of local authorities or government. 

The UAS

The petitioner seeks exemption to operate UA Multifunctional Quad-rotor Systems by 

DJI (DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1) for compensation or hire 

within the National Airspace System. The DJI Phantom 2, 3, and Inspire 1 are highly 

successful consumer grade small rotor crafts in the quadcopter configuration. They are 

vertical takeoff and landing (VTOL) UAS with a Ground Control Station (GCS) 

utilizing an electronic tablet. All 3 systems contain internal measuring units (IMU) 

with integrated barometric sensors augmented with global positioning systems (GPS) 

to maintain their geospatial orientation and position. Real time video control station 

allows the operator and/or PIC to monitor battery level, GPS signal strength, altitude, 

distance from PIC, camera imagery, and control camera angle. Integrated failsafe 

mode Return to Home aid and assist operations for either loss of RC or GPS signal. 

The onboard flight controllers will warn the pilot via telemetry and external lighting 

cues before reaching a low battery state. The 3 UASs have the capability to abort a 

flights and return to home safely in case of any unpredicted obstacles or emergencies. 

DJI Phantom 2 
Dimensions: 210x335x335 mm 

Weight: 1000g / 2.20lb

Intelligent Flight Battery: 5200mAh 25min Flight Time

Max Flight Speed:15m/s or 33.5mph

Operating Frequency: 2.4GHz ISM

Key Features:

Live real-time flight data

Intelligent Orientation Control (IOC), GPS, and Return to home failsafe

Self-tightening locking Propellers

Dynamic home point orientation

Intergraded No Fly Zones prevents inadvertently entering protected air space

Intelligent Flight Battery includes capacity data, over charge/discharge protection, 

maintenance data.

DJI Phantom 3

Dimensions: 203x330x457 mm 

Weight: 1280g / 2.8lb

Intelligent Flight Battery: 4480mAh 23min Flight time

Max Flight Speed: 16m/s or 35.7mph

Operating Frequency: GHz; 2.400~2.483 GHz

Key Features:

Live real-time flight data

Intelligent Orientation Control (IOC), GPS, and Return to home failsafe

Self-tightening locking Propellers 

DJI Vision Positioning System for improved safety

Dynamic home point orientation

Intergraded No Fly Zones prevents inadvertently entering protected air space 

Intelligent Flight Battery includes capacity data, over charge/discharge protection, 

maintenance data.

DJI Inspire 1

Dimensions: 438x451x301mm 

Weight: 2935g / 6.47lb

Intelligent Flight Battery: 5200mAh 18min Flight time

Max Flight Speed: 22m/s or 49.2mph

Operating Frequency: 5.725~5.825 GHz; 2.400~2.483 GHz

Key Features:

Live real-time flight data

Intelligent Orientation Control (IOC), GPS, and Return to home failsafe

Self-tightening and locking Propellers 

DJI Vision Positioning System for improved safety

Dynamic home point orientation

Intergraded No Fly Zones prevents inadvertently entering protected air space

Intelligent Flight Battery includes capacity data, over charge/discharge protection, 

maintenance data.
Risk Mitigation 

Aerial Safety is of the utmost concern. I the petitioner have reviewed FAA 

exemptions reference’s 1-3 Conditions and Limitations section and believes that the 

procedures specified therein are reasonable and will be utilized in order to manage 

and mitigate risk and ensure public safety. A preflight checklist is being developed 

and employed to ensure that the UA airworthiness and will be verified before each 

launch. Airworthiness will be maintained by performance of routine inspections 

before each flight, maintaining flight and maintenance logs. These documents will be 

made available upon request to assist in future implementation of safety standards and 

regulations. The petitioner will only operate the UAS over designated properties with 

the clients consent. Flight plans will be predetermined to limit the UASs flight time 

and limit safety concerns. The petitioner will take into account distance from persons 

and potential flight obstacles prior to operating the UAS. UAS operations will always 

be within VLOS of the PIC and the observer. The petitioner/Operator will carry 

suitable insurance for the protection of the Operator and the Public thus providing 

positive and responsible UAS operations in the community.

Developing Flight Check List

On hand DJI Phantom2 and DJI Inspire 1 official Manuals and procedures

Reference B4UFLY Smartphone App

Optimal weather conditions have been verified 

Location scouting including landing and takeoff distance

Establish reasonable low altitudes to ensure safety of civil aircrafts

Obtain consent of all persons involved in filming including land and property owners

Visual Inspection of aircraft

Prepare flight logs

Flight battery and transmitter battery at full charge

Propellers are in proper airworthy conditions and are securely locked and mounted. 

Perform sensor and compass calibration

DJI Ground Station activated

Clear uninterrupted communication between UAS and remote

Visually inspect and ensure all motors are running properly and rotate evenly. 

Ascend 10ft for control inspections: Forward, Back, Left, Right, Hover. 

Visually inspect for controlled flight performance along with ground station data.

Flights will be operated within line of sight of a pilot and/or observer.

Maximum flight time for each operational flight will be no more than 30 minutes. 

Flights will be terminated at no less than 25% battery power reserve should that occur 

prior to the 30 minute limit. 

Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet 

above an elevated platform from which filming is planned. 

Upon completion of flight operations perform visual inspection 

Record all flight data into the Flight Logs

Perform regular scheduled maintenance 
Public interest

Choice of UAS over a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned 

aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, the 

use of the UAS in order to facilitate commerce could lead to economic growth. 

Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their 

desired photographic subjects that cannot be displayed through ground level 

videography/photography. Crop surveying applications could lead to decreased use of 

pesticides and fertilizer and conservation of water as well as increased crop yields and 

decreased costs. Aerial surveying and inspections can increase planning efficiency, 

improve resource estimations, and reduce risks to personnel and property. The 

petitioner will provide clients with photographic data for these purposes on a ‘for hire’ 

basis acting as an independent contractor. Flight data including UA flight time, 

Control Unit operation time, incident, accident, and details concerning any deviations 

from normal operations will be available upon request for use in collecting data 

regarding the use of UAS as part of these applications. 

Conclusion 

The petitioner is requesting this exemption for the purposes of aerial photography, 

cinematography, and videography. The petitioner wishes to provide safe and reliable 

services for businesses such as but not limited to, real estate, architecture, agriculture, 

land surveying, engineering, television, cinematography, and news gathering. By 

providing safe deployments and cost effective operations through UAS the petitioner 

offering a much needed and desired service in the community. The petitioner can 

ensure adherence to standards and protocols and can develop and refine generally 

applicable safety guidelines and processes. The primary purpose of seeking this 

exemption is to obtain the capability to offer UAS services while remaining in 

compliance with FAA regulations. The petitioner has 4 years of experience in the 

UAS and radio control model aircraft hobbies and wishes to move forward in this 

ever growing industry. 

Respectfully Submitted,

Sean Lucas