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 therequest 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 fordaytime, 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