U.S.	Department	of	Transportation,	Docket	Operations	West Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the Federal	Aviation	Regulations	from	14	C.F.R.	61.113(a)&(b); 91.7(a);	91.9(b)	(2);	91.109;119.121;	91.151(a);	91.405(a); 91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)
Dear	Sir	or	Madam: I,	Paul	Seiden,	am	writing	pursuant	to	the	FAA	Modernization	and
Reform	A ct	of	2012	and	the	procedures	contained	within	14	C.F.R. 11,	to	request	that	I,	Paul	Seiden,	an	owner	and	operator	of	small unmanned	aircraft,	be	exempted	from	the	Federal	Aviation Regulations	(“FARs”)	listed	below	so	that	I,	Paul	Seiden,	may
operate	a	sma ll	ultra	light	weight	unmanned	aircraft	system (“UAS”)	commercially	in	airspace	regulated	by	the	Federal Aviation	Administration	(“FAA”)	located	in Illinois (specifically	in Chicago	and	surrounding	suburbs	as	well	as Cook,Lake,Ka ne,Dupage	and	McHennry	Counties )	in	accordance with	FAA	UAS	Regulation s	&	Policies. This	exemption	request	is	made	based	on	information	outlined	in this	petition,	as	well	as	the	accompanying	DJI	Phantom2 Operators	Manual 1 and	Personal	Protocols	and	Controls 2 .	The	DJI Phantom2	UAS	was	selected	because	it	has	a	proven	capabili ty	for	controlled	flight	as well	as	a	gyro	stabilized	flight	mode,	GPS	aided	navigation,	a	compass,	blinking	LED’s	on the	bottom,	a	failsafe	mode	for	returning	home,	and	prop	guards.	These	devices	are offered	for	general	sale	around	the	world	and	have	ofte n	been	used	as	Model	Aircraft	in the	USA.	In	addition,	I,	Paul	Seiden,	have	flown	UAS’s	in	a	recreational	capacity	since 1978	and	have	adopted	safety	protocols	and	controls	to	avoid	and	prevent	public hazard,	as	well	as	manned	aircraft	hazards/catastrophe. This	will	act	to	further	safety protocols	exclusive	to	lightweight	UAS's	specific	to	video	and	photography	usage	as	I, Paul	Seiden,	record	flight	data	and	other	information	gained	through	permitted	flight operations	to	share	with	the	FAA	through	any	requi red	FAA	reports	to	assist	with	future protocol	and	safety	regulation.	I	am	also	a member	of	the Academy of Model Aeronautics
member number 417838I.	Contact	Information
Paul	Seiden 85	N	Buesching	Road	apt	421 Lake	Zurich,IL	60047
Mobile	(630)417

- 3891 emai l pcseiden1@gmail.com II.	Information	regarding	the	Phantom	2 UAS Specifically,	the	UAS	is: An	ultra	lightweight	battery	operated	4

- motor	rotorcraft	in	the form	of	a	quadcopter	that	takes	off	and	lands	ver tically, manufactured	by	DJI,	Model	Phantom	2,	with	the	following equipment:

• An	on

- board	flight	computer	with	GPS	navigation	and	location ability	that	receives	signals	for	flight	controls	from	a	ground

based	transmitter/controller;

• An	integrated	on

- board	camera	capable	of	capturing	imagery	in the	form	of	full	color,	high	definition	still	photos	and	video;

• An	on

- board	telemetry	system	that	delivers	flight	data	from	the

on

- board	flight	computer	to	the	on

- board	radio	transmitter including	altitude	A GL,	horizontal	and	vertical	speed, compass	direction	of	flight	and	direction	back	to	its	launch site;

• A	600mW,	5.8GHz	on

- board	radio	transmitter	that	transmits	live
video	from	the	on

- board	camera	plus	all	the	flight	data	from the	telemetry	system	descr ibed	above; The	Ground	Station
Includes:

• A	Pilot	in	Command	(PIC)	in	operational	control	of	a	flight operation	from	beginning	to	end	and	who	controls	the	UAS while	in	the	air;

• A	100mW,	2.4GHz	radio	transmitter/controller	operated	by	the PIC	to	control	the	UAS	while	in	flight;

• A	radio	receiver	receiving	live	video	and	flight	data	from	the	on

board	camera	and	computer	projects	it	all	together	onto	a
screen	for	the	PIC	to	view during	flight;• A	Visual	Observer	(VO)	is	a	person	who	provides	a	second	pair	of eyes	to	visually	track	the	UAS	while	in	flight. III.	Proposed Operations I,	Paul	Seiden,	intend	to	use	UASs	in	two	areas. First,	I	seek	an	exemption	to	perform	video	film ing	and photographing	by	air	for	public	and	private	use.	Second,	I will	employ	UAS’s	to	inspect	land,	residential	commercial and	industrial	structures	and	property. Specifically,	I	will	use	UASs	which	are	equipped	with	cameras	and sensors,	in	order	to	eng age	in	the	following	commercial	activities in	Chicago	and	surrounding	suburbs	as	well	as Cook,Lake,Kane,Dupage	and	McHennry	Counties: (a)	Video	filming	by	air	and	photographing	for	public	and	private purposes,	including:	television,	cinematography,	adverti sing	or promotions.	Filming	and	Photography	will	only	be	conducted	with permission	and	under	contract	with	registered	owners	or	with	any local	government	authority	and	only	when	safe	to	do	so. (b)	Video	filming	by	air	and	photographing	to	support	professio nal operations	in	engineering,	land	surveying	and	development, architecture,	real	estate	and	other	related	professional	activities. Filming	and	Photography	will	only	be	conducted	with	permission and	under	contract	with	registered	owners	or	with	any	local

g overnment	authority	and	only	when	safe	to	do	so. (c) Inspection	by	air	of	infrastructure	such	as	bridges,	highways, photovoltaic	power	stations,	and	pipelines.	These	inspections	will only	be	done	under	contract	and	permission	with	any	registered owners	or	with	any	local	government	authority	and	only	when
saf e	to	do	so. (d)	Inspection	by	air	of	land	and	residential,	commercial	and industrial	structures,	only	under	contract	and	permission	with	any registered	owners	or	with	any	local	government	authority	and only	when	safe	to	do	so. (e)	Support	provided	to	searc h	and	rescue	operations	and reconnaissance	in	cases	of	need,	emergency	or	natural	disastersonly	when	government	authorities	have	requested	it	by	contract or	donation	and	only	when	safe	to	do	so. IV.	Relevant	Statutory	Authority This	Petition	for	Exemption is	submitted	pursuant	to	Section 333(a)	through	(c)	of	the	FAA	Modernization	and	Reform	Act	of 2012	("Reform	Act").	Congress	has	directed	the	FAA	"to	safely accelerate	the	integration	of	civil	unmanned	aircraft	systems	into the	national	airspace	system." Pursuant	to	Section	333	of	the Reform	Act,	the	FAA	Administrator	is	to	permit	unmanned	aircraft systems	to	operate	in	the	National	Air	Space	("NAS")	where	it	is safe	to	do	so	based	on	the	following	considerations:

• The	UAS’s	size,	weight,	speed	and	opera tional	capability;

• Operation	of	the	UAS	in	close	proximity	to	airports	and populated	areas;	and

• Operation	of	the	UAS	within	the	visual	line	of	sight	of	the
operator. Additionally,	the	FAA	Administrator	has	general authority	to	grant	exemptions	fro m	the	agency's	safety regulations	and	minimum	standards	when	the	Administrator decides	a	requested	exemption	is	in	the	public	interest.	See 49	U.S.C.	§	106(f)	(defining	the authority	of	the Administrator);	49	U.S.C.	§	44701(f)	(permitting	exemptions from§§ 44701(a),	(b)	and§§	44702

- 44716,et	seq.).	A	party requesting	an	exemption	must	explain	the	reasons	why	the exemption:	(1)	would	benefit	the	public	as	a	whole,	and	(2) would	not	adversely	affect	safety	(or	how	it	would	provide	a level	of	safety	at	least	eq ual	to	the	existing	rules).	See	14 C.F.R.	§	11.81	(petitions	for	exemption). V.	These	Proposed	UAS	Operations	Meet	the	Requirements	of
Section	333	of	the	Reform	Act The	proposed	operations	in	this	Petition	for	Exemption	qualify	for expedited	approval	pursu ant	to	Section	333	of	the	Reform	Act	as each	of	the	statutory	criteria	and	relevant	factors	are	satisfied. VI.	Approval	is	Warranted	Based	on	the	UAS	Size,	Weight,	Speed,and	Operational	Capability I,	Paul	Seiden,	will	employ	the	DJI	Phantom	2	quadcopter	f or	the operations	specified	in	this	Petition	for	exemption.

• The	Phantom	2 UASs	have	a	maximum	take

- off	weight	of	less than	5	pounds

• Flight	speed	will	not	exceed	25	miles	per	hour,	and	it	will	not	be flown	in	controlled	airspace	or	at	an	altitude	th at	exceeds
400	feet	AGL.

• All	flights	will	be	flown	in	such	a	manner	that	they	can	be	safely terminated	with	a	reserve	battery	power	of	no	less	than	20% of	the	battery's	maximum	charge.

• The	DJI	Phantom	2	UAS	does	not	carry	any	flammable	propellant

o r	fuel.

• The	Phantom	2	UAS	has	an	integrated	GPS	system	that
calculates	the UAS’s	position	and	height	and	relays	that
information	via	a	secure	connection	to the	operator.

• The	Phantom	2 UAS	contain	a	failsafe	mode	if	its	connection	to
the remote	control	is	lost,	and	this	system	permits	the	UAS

to	return	to	a predetermined	location	and	land	without injury	or	damage.

• For	additional	safety,	the	Phantom	2 will	be	retrofitted	with prop	guards. VII.	Approval	is	Warranted	Based	on	the Opera tional	Restrictions	Set	Forth	in	the	Operations

Manual. DJI's	operators	manual 3 and	the	Personal	Protocols

and	Controls 4 contain	all	of	the	procedures	and	limitations necessary	to	successfully	perform	the	operations	specified	in this	Petition	for	Exemptio n.

VIII.	Public	Interest The	public	interest	will	be	served	by	granting	Paul	Seiden	a Petition	for	Exemption	in	Chicago,	suburbs
and Cook,Lake,Kane,Dupage	and	McHennry Counties.	Congresshas	established	a	national	policy	that	favors	early	integration of UASs	into	the	NAS	in	controlled,	safe	working	environments	such as	those	proposed	in	this	Petition.	In	addition,	the	public	also	has an	interest	in	reducing	the	hazards	associated	with	alternate methods	of	conducting	similar	operations.	Currently	operat ions are	conducted	using	teams	that	physically	climb	onto	structures using	ladders,	using	low	flying	helicopters	or	aircraft,	are extremely	cost	prohibitive	or	are	simply	not	available	by traditional	means.	By	using	UAS,	exposure	to	physical	hazards	will
b e	reduced	by	conducting	the	operation	while	remaining	safely	on the	ground. Additionally,	the	intended	uses	of	the	Phantom	2 UAS	as	outlined in	this	document	have	identifiable	safety	benefits	that	include reducing	the	danger	and	emissions	associated	with full	size helicopters.	UAS	have	no	fuel	to	ignite	or	explode,	no	crew,	add	a greater	degree	of	flexibility,	supplement	the	current	capabilities offered	by	manned	aircraft,	and	public	interest	for	a	ground impact	of	a	small	lightweight	UAS	is	further	minimi zed	from	an ecological	and	safety	standpoint. IX.	A	Summary	The	FAA	May	Publish	in	the	Federal	Register: A.	14	C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	The	Like.

14	C.F .R.	91.7(a)	I,	Paul	Seiden,	will	ensure	the	UAS	is	in	airworthy condition	based	on	compliance	with	the	Phantom	2	operating documents	prior	to	each	flight. 14	C.F.R.	§	91.121	Relief	is	requested	considering	the	limited altitude	of	proposed	operations.

B.	14 C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC. Pursuant	to	14	C.F.R.	§	61.113	(a),	The	FAA	has	previously declared	that	additional	manned	airship	experience	of	a commercially	certified	pilot	would	not	correlate	to	the	airmanship
skills	ne cessary	for	similarly	proposed	operations	in	previously issued	exemptions	to	this	regulation	through	Exemption	Nos.
11062	and	11138.Pursuant	to	14	C.F.R.	§	61.113	(b),	The	stick	and	rudder	controls	of the	typical	aircraft	one	would	be	trained	on	to	achiev e	a	private pilots	license	are	completely	different	than	that	of	a	small	UAS. Additionally,	the	FAA	does	not	require	manned	ultralight	vehicle PICs	to	meet	any	aeronautical	knowledge,	age,	or	experience requirements	or	to	have	airman	or	medical	certificate s	(as outlined in	14	C.F.R.	§	103).	Ultralight	vehicles	can	weigh	more	than	500	pounds	than	the Phantom	2,	can	carry	up	to	5	gallons	of	combustible	fuel,	and	fly	at	speeds	close	to double	that	capable	by	the	Phantom	2.	Due	to	these	facts,	I,	Paul	Seiden	re spectfully request	that	an	333 exception	be	granted	and	PIC	license	requirement	be	waived D.	14	C.F.R.	91.119	(c):	Minimum	Safe	Altitudes. 14	C.F.R.	§	91.119	(c)	I,	Paul	Seiden,	will	ensure	that	all	persons and	objects	not	essential	to	flight	operations	mu st	remain	500 feet	away	from	operations.	In	addition	to	visual	monitoring	of	the area,	a	traffic	cone	and	warning	sign 6 alerting	persons	in	the	area will	be	placed	at	the	operation	ground	station.	To	protect	objects and	personnel	essential	to	flight	operat ions	the	Phantom	2	will	be fitted	with	propeller	guards	to	minimize	potential	hazards. E.	14	C.F.R.	91.151	(c):	Fuel	Requirements	for	Flight	in	VFR
Conditions. 14	C.F.R.	91.151	(c),	I,	Paul	Seiden,	will	ensure	that	each	individual flight	will	not	begin	unl ess	there	is	enough	power	to	fly	to	the	first point	of	intended	landing	and	land	the	UA	with	30%	battery power	remaining.	In	addition,	each	individual	flight	will	last	no longer	than	20	minutes,	5	minutes	less	than	the	manufacturer
stated	25	minutes	of	fli ght	time. F.	14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b): Maintenance	Inspections.
The	above

- cited	Regulations	require,	amongst	other	things, aircraft	owners	and	operators	to	“have	[the]	aircraft	i nspected	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.	.	.	.”These	Regulations	only	apply	to	aircr aft	with	an	airworthiness certificate.	They	will	not,	therefore,	apply	to	my,	Paul	Seiden’s, UAS.	However,	as	a	safety	precaution	I	inspect	my	UAS	per operating	documents	before	and	after	each	flight.

X.	Conclusion This	Petition	for	Exemption	satisfies	th e	criteria	articulated	in

Section 333	of	the	Reform	Act	of	2012	including	weight,	speed, operating	capabilities,	proximity	to	airports	and	populated	areas, operation	within	visual	line	of	sight	and	national	security. Additionally,	the	Petition	provides	mor e	than	adequate justification	for	the	grant	of	the	requested	exemptions	to	permit Paul	Seiden	to	operate	a	Phantom	Vision	UAS	in Chicago,	suburbs
and Cook,Lake,Kane,Dupage	and	McHennry Counties for	the operations	specified	herein. Granting	the	exemption	w ill	benefit	the	public	interest	as	a	whole in	several	ways,	including	(1)	significantly	improving	safety	and reducing	risk	by	alleviating	human	exposure	to	danger,	and	(2) improving	the	quality	of	services	and	decreasing	operating	costs compared	with	conve ntional	flight	operations.

Very	Respectfully,

Paul	Seiden