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	Act	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	small	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,Kane,Dupage	and	McHennry	Counties)	in	accordance	

with	FAA	UAS	Regulations	&	Policies.

This	exemption	request	is	made	based	on	information	outlined	in	

this	petition,	as	well	as	the	accompanying	DJI	Phantom2	

Operators	Manual1	and	Personal	Protocols	and	Controls2.	The	DJI	

Phantom2	UAS	was	selected	because	it	has	a	proven	capability	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	often	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	required	FAA	reports	to	assist	with	future	

protocol	and	safety	regulation.	I	am	also	a member	of	the Academy of Model Aeronautics 

member number 417838
I.	Contact	Information

Paul	Seiden 85	N	Buesching	Road	apt	421

Lake	Zurich,IL	60047

Mobile	(630)417-3891	 email	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	vertically,	

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	groundbased	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	AGL,	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	described	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	onboard	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	filming	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	engage	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,	advertising	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	professional	

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	

government	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	

safe	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	search	and	rescue	operations	and	

reconnaissance	in	cases	of	need,	emergency	or	natural	disasters	
only	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	operational	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	from	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	equal	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	pursuant	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	for	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	that	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	

or	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	

Operational	Restrictions	Set	Forth	in	the	Operations	

Manual.	 DJI's	operators	manual3	and	the	Personal	Protocols	

and	Controls4	contain	all	of	the	procedures	and	limitations	

necessary	to	successfully	perform	the	operations	specified	in	

this	Petition	for	Exemption.	 

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.	Congress	
has	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	operations	

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	

be	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	minimized	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	necessary	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	achieve	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	certificates	(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	respectfully	

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	must	remain	500	

feet	away	from	operations.	In	addition	to	visual	monitoring	of	the	

area,	a	traffic	cone	and	warning	sign6	alerting	persons	in	the	area	

will	be	placed	at	the	operation	ground	station.	To	protect	objects	

and	personnel	essential	to	flight	operations	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	unless	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	flight	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	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.	.	.	.”
These	Regulations	only	apply	to	aircraft	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	the	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	more	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	will	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	conventional	flight	operations.

Very	Respectfully,

Paul	Seiden