U.S. Department of Transportation

Federal Aviation Administration

Washington, DC

June 15, 2015

Petitioner

Jordan Senecal

2960 Ashton Pointe Circle

Dacula, GA 30019

770­365­4949

jordansenecal@me.com

Jordan Senecal will be providing clients with high quality imaging for a variety of

commercial, public, and residential uses. He is a current licensed private pilot

with hours of flying experience and is seeking an exemption from these specific

requirements of Title 14 C.F.R.:

I. 61.113(a) and (b)

II. 91.119(b) and (c)

III. 91.121

IV. 91.151(a)

V. 91.405(a)

VI. 91.407(a)(1)

VII. 91.409(a)(1) and (2)

VIII. 91.417(a) and (b)
Definitions

I. AGL Above Ground Level

II. ATC Air Traffic Control

III. COA Certificate of Authorization

IV. FAA Federal Aviation Administration

V. FAR Federal Aviation Regulation

VI. GPS Global Positioning System

VII. NAS National Airspace System

VIII. PIC Pilot in Command

IX. UA Unmanned Aircraft

X. sUAS Small Unmanned Aerial System

XI. VFR Visual Flight Rules

XII. VLOS Visual Line of Site

Summary

In the instance of granting exemption, Jordan Senecal will be operating the sUAS in

order to fulfill contracted obligations, such as: aerial photography and videography for

real estate agents, appraisers, property managers, general contractors; solar panel

installation technicians; agriculturists; utility inspections (only where safe flight is

attainable); chambers of commerce and associated businesses; wildlife conservation

organizations; public departments; all other institution requiring filmography (safe flight

permitting)
Aircraft

I. DJI Phantom 3

A. Weight (Including Battery and Propellers) 2.82 lbs

B. Diagonal Size (Including Propellers) 23.23 in

C. Max Ascent Speed 11.2 mph

D. Max Descent Speed 6.7 mph

E. Max Flight Time ~ 23 minutes

F. Remote Controller Operating Frequency 2.400 GHz ­ 2.483 GHz

G. Auto­Takeoff Rises to a pre­set height and

will hover in place until directed

where to go

H. Auto­Return Home Remembers the exact spot it

took off from to enable a tap of a

button to return back home

I. Low Battery Failsafe If the flight battery is run running

low or the Phantom 3 loses

connection with the remote it will

automatically return back home
II. DJI Inspire 1

A. Weight (Including Battery and Propellers) 6.47 lbs

B. Diagonal Size (Including Propellers) 22.87 in

C. Max Ascent Speed 11.2 mph

D. Max Descent Speed 9 mph

E. Max Flight Time ~ 18 minutes

F. Remote Controller Operating Frequency 2.400 GHz ­ 2.483 GHz

5.725 GHz ­ 5.825 GHz

G. Auto­Takeoff Rises to a pre­set height and

will hover in place until directed

where to go

H. Auto­Return Home Remembers the exact spot it

took off from to enable a tap of a

button to return back home

I. Low Battery Failsafe If the flight battery is run running

low or the Inspire 1 loses

connection with the remote it will

automatically return back home

Specific Sections of C.F.R From Which Jordan Senecal Seeks

Exemption

I. Section 61.113(a) and (b) ­ Private Pilot Privileges and Limitations

Section 61.113 states that 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. The sUAS will not carry a pilot or passengers. Then the stated operations can

achieve the equivalent level of safety by requiring the PIC operating the aircraft to have

completed FAA Private Pilot Ground school instruction and passed the FAA Private

Pilot written exam to operate these sUAS. These sUAS are not capable of carrying a

pilot or passengers, therefore distinguishing them as remotely controlled vehicles. The
area of operation is controlled and restricted providing a sound level of safety

referenced from the operations manual. The risk associated with the operation of a UAS

are greatly reduced with a private pilot acting as PIC thus exceeding the present level of

safety achieved by section 61.113.

II. Section 91.119 ­ Minimum Safe Altitudes

Section 91.119 states persons may operate a helicopter at less than the minimums

prescribed in paragraph (b) or (c) of this section, provided each person operating the

helicopter complies with any routes or altitudes specifically prescribed for helicopters by

the FAA. The sUAS meets this criteria as a helicopter and requests the ability to operate

at altitudes up to 400’ AGL. Only in accordance with pre­obtained consent will the sUAS

operate while also maintaining an altitude less than 400’ AGL. For comparison with

traditional aircraft and rotorcraft the sUAS weighs less than 10lbs, while also preventing

potential risks associated with flammable fuel. Lastly the 400’ AGL ceiling limits any

ability for the sUAS to interfere with conventional aircraft operating at or above 500’

AGL.

III. Section 91.121 ­ Altimeter Settings

Section 91.121 states 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, when operating below 18,000 feet MSL, to the current reported altimeter

setting of a station along the route and within 100 nautical miles of the aircraft. In the

case of an aircraft not equipped with a radio, the elevation of the departure airport or an

appropriate altimeter setting available before departure. The sUAS will reference its

altitude based on GPS and will be restricted to a 400’ AGL ceiling. The PIC will also

verify GPS elevation from multiple ground based sources prior to takeoff.

IV. Section 91.151 ­ Fuel Requirements for Flight in VFR conditions

Section 91.151 states no person may begin a flight in a rotorcraft 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, to fly after that

for at least 20 minutes. The sUAS battery powered operational flight time is not able to

incorporate a 20 minute reserve window following successful first point of intended

landing due to current battery capacity limitations. In order to provide adequate reserve

power for return landing the sUAS will abide by a 12 minute flight time or 25% of

remaining battery power, whichever happens first.
V. Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b)

These sections only apply to aircraft with an airworthiness certificate, Jordan Senecal

requests exemption from these sections because the DJI Phantom 3 and Inspire 1 do

not require airworthiness certificates. Both sUAS are in accordance with FMRA Section

333 for operation, absent an airworthiness certificate. In order to insure proper

maintenance the operations manual will be cited for necessary corrective measures. In

addition, the PIC is the person most familiar with the aircraft and best suited to maintain

the aircraft in an airworthy condition, and any sUAS conducted maintenance will be

documented for the life of the aircrafts.

Public Interest

● Real estate agents will be able to set their listings apart with a unique perspective

only available from sUAS photographic equipment, therefore increasing the

prospect of meeting or exceeding the asking price.

● Property managers and contractors will have the ability to survey their property

for anomalies while preventing human endangerment due to hazardous

conditions.

● Solar panel technicians can safely inspect potential installation locations without

putting themselves in high elevation and sloping circumstances.

● Agriculturists will have the ability to survey their land in a more timely manner

and better document the condition of their property.

● Marketing firms and other businesses would use unique aerial photography and

panographic video to promote marketing campaigns and increase revenue.

● Search and rescue entities could utilize the sUAS to help quickly aid in finding

the location of person(s) while providing a better vantage point in closer quarters.

Public Safety

● Both sUAS will reduce air and noise pollution do to the aircraft being powered by

a battery and brushless electric motors.

● These small aircraft create less potential for harm, should an emergency

situation occur, thanks to their size and weight.

● Furthermore the lack of combustible fuel also significantly decreases their

chances of producing harm.
Conclusion

Based on the criteria provided under the FMRA Section 333, Jordan Senecal requests

that the FAA grants him exemption from 14 C.F.R Sections 61.113(a) & (b), 91.119(b)

and (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b) in order to conduct contracted commercial sUAS operations using the DJI

Phantom 3 and Inspire 1 for a wide range of industries and applications.

Kind Regards,

Jordan Senecal