Aaron V. Serafinowicz Section 333 UAS Exemption Request

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October 14, 2015

Aaron V. Serafinowicz

603 Fulton Rd Apt. D-37

Tallahassee, FL 32312

931-216-7615

U.S. Department of 

Transportation Docket

Management System

1200 New Jersey Ave., SE

Washington, DC 205930

Petition for Exemption Filed under Section 333 of the 2012 FAA Modernization and Reform

Act Filed via www.regulations.gov

Dear FAA UAS Exemption Review Team,

Aaron V. Serafinowicz (PIC) is respectfully writing to request exemptions that would lead to

safe and legal entry into the NAS under Section 333 of the FAA Modernization and

Reform Act of 2012. A granted exemption would allow A a r o n V . S e r a f i n o w i c z

to obtain a COA, if required, to conduct commercial operations and training described in

this letter. Furthermore, it would enhance airspace safety and efficiency in our community

by offering affordable aerial imagery, video, and surveying to the general public that

would deter and mitigate unsafe and illegal entrance into the NAS by untrained and

unlicensed UAS users.

Annex A outlines requested exemptions and applicable reasoning. Annex B briefly describes

PIC training program and qualifications. Annex C outlines operations, safety

considerations, and limitations. The remainder of this letter is outlined in accordance with

(“IAW”) the Section 333 Guidance document available at FAA’s Petitioning for Exemption

under Section 333.

Aaron V. Serafinowicz UAS Platforms

1. Operations will be conducted with 3D Robotics’ X8+, Quad Kit, Iris+ and Aero M

UAS(s). Design and operational characteristics are defined within attached manuals.

Recently, exemptions for the X8+ were granted to Build Imagery, and BNSF 

Railway Company, amongst others, on the 11th and 12th of March. In addition,

airworthiness of both types of platforms has been demonstrated in different projects

within the United States. All UAS(s) are using proven technologies from 3D 

Robotics Flight controller.

2. PIC will be trained on and operate by strict conditions defined by the Safety Program

of the Academy of Model Aeronautics, attached flight manuals. Inspections will be 
Aaron V. Serafinowicz Section 333 UAS Exemption Request

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conducted before each flight IAW platform’s respective checklist and Annex C. 

Maintenance and repairs will be performed IAW 3DR user manual, at minimum, 

quarterly or upon failed pre- or post-flight inspections.

3. All equipment, frequencies, and payloads comply with FCC requirements and can

be furnished upon request.

Operation of UAS

4. Aaron V. Serafinowicz conducts operations to provide affordable aerial 

photography, video, and surveying to the general public. Refer to Annex C

for a list of operations, safety considerations, and limitations.

5. The 3D Robotics rotary UAS(s) max operating speed will not exceed 22MPH and

the Aero M will not exceed 45MPH. No platform will exceed an altitude of 400 feet

above ground level. All platforms will not operate at night or in weather conditions 

that produce precipitation, visibility less than three miles from the launch point, 

ceilings less than 1000 feet, sustained winds greater than 25 knots, or gust spreads

greater than 10 knots. PIC is equipped with Kestrels to measure current site wind 

speed. This will prevent unnecessary risk to people and property.

6. Areas of intended operations are defined by property owners, responsible agents, 

or government agencies consent and boundaries obtained by government GIS

sources. Refer to Annex C for further information.

7. PIC will not conduct operations within five nautical miles of airports without

approved consent from base operations or air traffic control authorities. PIC will

notify these agencies at least 72 hours prior if operation site is within five nautical

miles of an airport.

8. PIC will maintain unaided VLOS with UAS. In complex duties or terrain, VO(s) will

be used to maintain VLOS with UAS and PIC, and relay flight information.

9. PIC will verify flight limiting factors upon arrival to the operation

site by using government sources and Kestrel for weather data,

surveying and documenting site hazards, and conducting pre-flight

inspections prior to operations.

10. PIC, when applicable to operations, will submit FAA Form 7711-1 or

equivalent form with Flight Standards District Office at least 72 hours

prior operations.

11. Will obtain COA, if required, from FAA Air Traffic Organization if granted

exemption.

We hope that you grant us an exemption to the current regulations. We are
Aaron V. Serafinowicz Section 333 UAS Exemption Request

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looking forward to leading the way and setting a safe and efficient standard for

future companies and UAS operators. Thank you for your consideration.

Very respectfully,

 

 Aaron V. Serafinowicz

ANNEX A: Requested Exemptions

- Part 61 Certification

o 61.113 (a, b)

 Operators should not be required to hold a commercial or private pilot

licenses given safety features of 3D Robotics’ X8+, Quad Kit, iris+ and

Aero M, and safety measures described in Annex C.

- Part 91 General Operating and Flight Rules

o 91.105

o 91.109

 Flight instruction will be accomplished using a thorough and safe

training program outlined in Annex B.

o 91.119 (c)

 Cannot operate above 400 feet AGL and therefore cannot comply with 

this regulation.

o 91.121

 Onboard systems of the 3D Robotics’ X8+, Quad Kit, iris+ and Aero M

provide a similar level of safety by using GPS and other orientation

sensors.

o 91.151 (a)

 3D Robotics’ X8+, Quad Kit, iris+ and Aero M do not use fuel.

However, operators will prepare to land when battery falls below

25% and before 20% is reached. PIC(s) will conduct a weather brief 

before each flight and UAS will not be operated below VFR

conditions.

o 91.405 (a), 91.407 (a)(1), 91.409 (a)(1, 2), 91.417 (a, b)

 All maintenance and repairs will be accomplished by utilizing 3DR

documentation and user manual. Furthermore, pre- and post-flight

checks will be conducted with each flight. If deficiencies are found, 

the UAS will not be operated until repairs are conducted. All repairs
Aaron V. Serafinowicz Section 333 UAS Exemption Request

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will be logged.

o 91.7 (a)

 Airworthiness all aircraft has been demonstrated. If required, a waiver

or certificate according to step four on the Petitioning for Exemption

under Section 333 web page will be obtained.

o 91.203 (a, b), 91.9

 An equivalent level of safety will be ensured by requiring PIC(s) to 

carry manuals and standard operating procedure documents while 

operating UAS.

In addition, request exemption from other regulations deemed necessary by reviewer.
Aaron V. Serafinowicz Section 333 UAS Exemption Request

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ANNEX B: Pilot in Command Qualifications

1. PIC/ UAS pilot already holds a FAA Private Pilot Certificate and will maintain a minimum 

of Sport Pilot currency standards.

2. PIC/ UAS pilot will be considered Pilot in Command (PIC), whether flying or

supervising, and will be responsible for safe operation of the flight.

3. PIC/ UAS Pilot will log all flight hours IAW FAA FAR Part 61.51

4. PIC/ UAS pilot has logged approximately 65 hours on multirotor UAS and 40 on fixed wing 

UAS.

5. PIC/ UAS Pilot has logged approximately 15 hours on UAS simulator. 

ANNEX C: Operations, Safety and Limitations

Aaron V. Serafinowicz conducts several types of operations for two primary reasons. First, is

to provide affordable aerial photography, video, and surveying to the general public.

Second, is to provide free education and training to youth, high-school, and undergraduates

in there freshman or sophomore year. By providing affordable services to the general

public and free education, I hope to keep the community safe by deterring and mitigating

untrained and unlicensed UAS users from entering the NAS.

1. Proposed operations are, but not inclusive to, the following:

a. Aerial construction site monitoring with photos and progress mapping 

before, during, and after. 

b. Real-estate photography and video services for property owners, managers, 

or real-estate agents

c. Home inspections with multi-spectral cameras for owners or potential buyers.

d. Outdoor event photography or video (e.g., 5Ks, weddings, golf tournament, 

etc.) for the general public with consent of property owners and or responsible

government authority

e. Agriculture monitoring, imagery, and surveying for owners, farmers,

or agronomist with permission of property owner

f. General imagery, mapping, and surveying for property/land owners

or governments

g. Wildlife monitoring, surveying, and forestry research.

h. Educational demos in support high school and/ or college 

engineering programs.

i. Emergency search and rescue programs in coordination with local 

agencies. 

j. Ongoing research and development within the guidelines of the 

current technologies used for this exemption request.

2. Safety is important, and the guidelines below will be followed in accordance

with (“IAW”) FAA regulations.

a. Pre-flight:
Aaron V. Serafinowicz Section 333 UAS Exemption Request

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i. PIC(s) will define operational borders using government GIS sources

ii. PIC(s) will account for all persons on property.

iii. PIC(s) will seek consent for persons within 100 feet of flight operations

iv. PIC(s) will survey and document site flight hazards

v. PIC(s) will review weather data from Kestrel and government sources

vi. PIC(s) will verify payload limits are not exceeded

vii. PIC(s) will conduct specific platform pre-flight checklist

viii. PIC(s) will document all tasks

ix. PIC(s) will conduct briefings for all PIC(s), VO(s), owners or

responsible agent, and persons within 100 feet of operations. Brief will 

highlight the concept of operation, potential hazards, weather

conditions, and abbreviated guidelines of the Academy of Model

Aeronautics Safety Code

b. Flight Operations and Limitations:

i. PIC(s) will operate according to FAA regulations, manuals, and

standard operating procedures

ii. PIC(s) will end operations before sunset.

iii. PIC(s) will not start operations before sunrise.

iv. PIC(s) will not operate on any property without consent from owner

or responsible agent

v. PIC(s) will not fly within 5NM of airports without consent from

base operations or air traffic control authorities

vi. PIC(s) will not fly over people

vii. PIC(s) will not fly within 100 feet of non-consenting persons

viii. PIC(s) will not fly in excess of 400 feet above ground level

ix. PIC(s) will not operate UAS, to include payloads, more than 35 pounds

x. PIC(s) will maintain VLOS and or coordination with VO(s)

xi. PIC(s) will prepare for landing when battery level falls below 25%

and land before level reaches 20%

SUMMARY OF FLIGHT MANNUALS, PREFLIGHT CHECK LIST and SAFETY 

EQUIPMENT

3D Robotics X8+ Operation Manual: LINK

3D Robotics X8+ Flight Checklist: LINK

3D Robotics Iris+ Operation Manual: LINK

3D Robotics Iris+ Flight Checklist: LINK

3D Robotics Aero Operation Manual: LINK

3D Robotics Aero Flight Checklist: LINK

3D Robotics Aero Safety Information: LINK

3D Robotics PixHawk Flight Controller Check list: LINK

Safety Equipment

Flight Planning and Weather Software: ForeFlight

Air Traffic Monitoring Device: Yaesu FTA-230 Transceiver