July 14, 2015

Exemption No. 12034

Regulatory Docket No. FAA–2015–1304

Mr. David A. Senechal

P.O. Box 21396

Louisville, KY 40221

Dear Mr. Senechal:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 14, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct general still and video photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI S900.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 
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Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. David A. Senechal is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

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

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. David A. Senechal is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S900 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

David A. Senechal 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI S900 AIRCRAFT SYSTEMS 

PURSUASNT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on April 14, 2015 

David A. Senechal 

P.O. Box 21396 

Louisville KY 40221 

Tel: (812) 786-6100 

 
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TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...............................................................3 

SUMMARY.............................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER.......................................4 

BACKGROUND.......................................................................................4 

BASIS FOR PETITION...............................................................................5 

A. NAME AND ADDRESS OF PETITIONER...........................................7

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DAVID A. 

SENECHAL SEEKS EXEMPTION....................................................7 

C. THE EXTENT OF RELIEF DAVID A. SENECHAL SEEKS AND THE 

REASON DAVID A. SENECHAL SEEKS THE RELIEF........................11 

D. THE REASONS WHY GRANTING DAVID A. SENECHAL’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST.........................................14 

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY.....................................................17 

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL 

REGISTER...............................................................................31 

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT DAVID A. SENECHAL’S REQUEST...........31 

CONCLUSION........................................................................................32 

APPENDICES.........................................................................................33

 
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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer 

SOP Standard Operating Procedures

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing

 
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SUMMARY

David A. Senechal seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

David A. Senechal to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting general still and video photography, real estate photography, news 

and special events, film sets, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

David A. Senechal will provide his clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and effectiveness. 

David A. Senechal will also provide its clients with the high quality digital content for use 

in their commercial, personal, and non-profit multimedia projects. David A. Senechal has 

over 40 years of experience in still and motion picture/video photography. Additionally, 

he has over four (4) years of recreational/hobby experience in Remote Control Helicopter 

and UAS operations. David A. Senechal is also a private pilot and holds an FAA Control 

Tower Operator’s (CTO) license. The objective of David A. Senechal’s aerial video and 

photography operation is to provide high quality imaging for a variety of commercial, 

public, and residential uses, specifically targeting: 

• General Videography and Photography 

• Motion Picture and News Filming 

• Real Estate Photography 

• Increase public knowledge of UAS and promote safe UAS operations. 

BACKGROUND 

Unmanned Aircraft Systems: DJI S900 

David A. Senechal seeks an exemption to operate a DJI S900 UAS for 

compensation or hire within the NAS. The DJI S900 UAS is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft System (UAS) with a Ground Control Station (GCS) utilizing 

a Spektrum DX18 18-channel 2.4 GHz transmitter. The GPS-based autopilot system is a
5

WooKong M (multi-rotor), which utilizes a main controller, an Inertial Measurement Unit 

(IMU), a GPS/compass module, and a power management unit; and transmits pertinent 

position and operational data to the operator via an on-screen-display (iOSD). The 

airborne navigational information and air/ground telemetry are transmitted to the GCS via 

a 5.8 GHz transmitter. The DJI S900 UA has a maximum gross weight of approximately 

14 pounds, a length of 39 inches, a height of 18 inches (landing gear extended), and a 

maximum speed of 40 knots. The DJI S900 UA is equipped with six main rotors driven by 

Lithium Polymer battery powered electric motors; and utilizes GPS with air/ground 

telemetry for positional determination and to provide the operator with pertinent flight data 

while the UA is airborne.

The DJI S900 UAS that will be operated by David A. Senechal will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, 

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. 

BASIS FOR PETITION 

Petitioner, David A. Senechal, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI S900 UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, David A. Senechal’s operation of the DJI 

S900 UAS meets the conditions of FMRA Section 333, and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, David A. Senechal requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 
6

David A. Senechal submits that the requested relief is proper since an equivalent 

level of safety will be ensured. David A. Senechal will personally, or otherwise authorize 

only experienced personnel or technicians to, perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents [i.e., DJI S900 User Manual, WooKong M (multirotor) User Manual, DX18 User Manual, pre-flight checklist, and monthly maintenance 

log]. Furthermore, David A. Senechal will document and maintain all maintenance records 

for the DJI S900 UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by David A. Senechal to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, who meets FAA approved medical standards, and who has demonstrated, by 

meeting minimum flight- hour and currency requirements, that the PIC is able to safely 

operate the DJI S900 UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

David A. Senechal seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI S900 UA does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, David A. Senechal submits that 

the PIC will ensure that the DJI S900 UAS is in an airworthy condition, prior to every 

flight, by determining that the UAS is in compliance with the operating documents [i.e., 

DJI S900 User Manual, WooKong M (multi-rotor) User Manual, Spektrum DX18 User 

Manual, pre-flight checklist, and monthly maintenance log], and that the aircraft is in a 

condition for safe flight. 

David A. Senechal also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI S900 UAS will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI S90 UA will be provided to 

the PIC via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the

flight path. This altitude information, combined with David A. Senechal’s operation of the 
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DJI S900 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, David A. Senechal seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. David A. 

Senechal submits that safety will not be affected by operation of the DJI S900 UAS during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), 

with enough battery power to fly for a total duration of approximately 14 minutes to the

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 5 minutes. 

In accordance with 14 C.F.R. § 11.81, David A. Senechal provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

David A. Senechal 

P.O. Box 21396 

Louisville KY 40221 

Tel: (812) 786-6100 

Email: dsenechal57@gmail.com

B. The Specific Sections Of 14 C.F.R. from Which David A. Senechal Seeks 

Exemption. 

1. David A. Senechal Seeks Exemption From The Requirements Of Section

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if— 

(1) The flight is only incidental to that business or employment; and 
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(2) The aircraft does not carry passengers or property for compensation or hire. 

2. David A. Senechal Seeks Exemption From The Requirements Of Section

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. David A. Senechal Seeks Exemption From The Requirements Of Section

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) 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-- 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) 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. 

4. David A. Senechal Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following: 

(b) 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. 

5. David A. Senechal Seeks Exemption From The Requirement Of Section 

91.405(a).
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Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft— 

(a) Shall have that 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[.] 

6. David A. Senechal Seeks Exemption From The Requirements Of Section

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. David A. Senechal Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. David A. Senechal Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 
10

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include-- 

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 
11

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief David A. Senechal Seeks And The Reason David A. Senechal 

Seeks The Relief. 

1. Extent Of Relief David A. Senechal Seeks And The Reason David A. Senechal

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a private pilot or higher level certificate, who meets FAA approved 

medical standards, and who has met certain flight-hour and currency requirements, 

to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to 

that business or employment; and (2) The aircraft does not carry passengers or

property for compensation or hire. 

As set forth more fully below, David A. Senechal submits that an equivalent level 

of safety will be maintained because no PIC will be allowed to operate the DJI 

S900 UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate the DJI S900 UAS in a manner 

consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate

distances from people, vessels, vehicles and structures. 

Further, David A. Senechal submits that all flights of the DJI S900 UA, conducted 

by the PIC pursuant to the grant of this Petition: (1) will be incidental to David A. 
12

Senechal’s business; and (2) will not carry passengers or property for compensation 

or hire. 

2. Extent Of David A. Senechal Seeks And The Reason David A. Senechal Seeks 

Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow David A. Senechal to determine that the DJI S900 UAS is 

in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents [i.e., DJI S900 User Manual, WooKong 

M (multi-rotor) User Manual, Spektrum DX18 User Manual, pre-flight checklist, 

and monthly maintenance log]. 

David A. Senechal seeks the requested relief because the DJI S900 UA does not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. Therefore, David A. Senechal will ensure that the DJI S900 UA is in airworthy 

condition based upon its compliance with the operating documents [i.e., DJI S900 

User Manual, WooKong M (multi-rotor) User Manual, Spektrum DX18 User 

Manual, pre-flight checklist, and monthly maintenance log] prior to every flight, 

and further, determine that the aircraft is in condition for safe flight, as stated in the 

conditions and limitations below. 

3. Extent Of Relief David A. Senechal Seeks And The Reason David A. Senechal

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI S900 UAS, which utilize a barometric pressure sensor, 

GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UAS to the PIC at the ground control station (GCS). 

Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), David A. 

Senechal seeks the requested relief because the DJI S900 UAS’s altimeter may be 

set on the ground to zero feet AGL, rather than the local barometric pressure or 

field altitude, before each flight. 
13

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions 

and limitations stated below. As more fully set forth herein, an equivalent level of 

safety will be maintained since the DJI S900 UAS is equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground 

level pressure setting will be established prior to each flight, and provides the PIC

with altitude information of the UAS on the heads-up display of the GCS. 

4. Extent Of Relief David A. Senechal Seeks And The Reason David A. Senechal

Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery 

powered DJI S900 UAS during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 14 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 5 minutes. David A. Senechal seeks the requested relief because 

without an exemption from Section 91.151(b), the flight time duration of the 

battery powered DJI S900 UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that David A. Senechal proposes to conduct 

pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI S900 UAS, 

the DJI S900 operating documents, and David A. Senechal’s proposed operating 

limitations, ensure that the PIC will safely operate the battery powered DJI S900 

UAS during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 14 

minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 5 minutes. 

5. Extent Of Relief David A. Senechal Seeks And The Reason David A. Senechal

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b). 
14

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, David A. Senechal requests 

relief from these Sections because the DJI S900 UAS does not require 

airworthiness certificates. As set forth more fully below, the DJI S900 UAS meets 

the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, David A. Senechal will personally, or otherwise use 

experienced personnel or technicians to, perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the UAS operating documents [i.e., DJI S900 User Manual, 

WooKong M (multi-rotor) User Manual, Spektrum DX18 User Manual, pre-flight 

checklist, and monthly maintenance log]. Furthermore, David A. Senechal will 

document and maintain all maintenance records for the DJI S900 UAS. 

D. The Reasons Why Granting David A. Senechal’s Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing David A. 

Senechal to safely, efficiently, and economically perform general aerial video and 

photography, as well as real estate, special events, film sets, and landscape over certain 

areas of the United States. 

Additionally, use of the DJI S900 UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Finally, the benefits of 

David A. Senechal’s proposed operation of the DJI S900 UAS will be realized without 

introducing any privacy issues. 

 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI S900 UAS is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI S900 UAS would reduce the 
15

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be 

reduced. The DJI S900 UAS does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control 

during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI S900 UAS. 

Conducting aerial acquisitions with the DJI S900 UAS, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI S900 UAS 

produces no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that 

are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI S900 UAS, 

while virtually eliminating the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric 

motors rather than an internal combustion engine. 

By using the DJI S900 UAS to perform aerial acquisitions, the risk to life and 

property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the 

aircraft, the DJI S900 UAS, weighing approximately 14 pounds at its maximum 

gross weight, with a length of 39 inches, and with no fuel on board, has less 

physical potential for collateral damage to life and property on the ground, and in 
16

the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a 

length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI S900 

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI S900 UAS is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI S900 UAS will allow United States based entities, like David 

A. Senechal, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned 

and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI S900 UAS is one such 

technology that not only allows companies greater operational flexibility compared 

to manned aircraft, but provides such flexibility without the high operational cost of 

a traditional manned aircraft. 

By operating the DJI S900 UAS, entities such as David A. Senechal can remain 

competitive and profitable, and therefore, provide greater job stability to employees 

and contractors, which will ultimately contribute to growth of the U.S. economy. 

Improved financial performance of U.S. companies, through commercial use of the 

DJI S900 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States 

and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted 

for decades, David A. Senechal’s proposed operation of the DJI S900 UAS will not 

introduce any privacy issues. Specifically, the DJI S900 UAS will be operated in 
17

accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which David A. Senechal Seeks Exemption. 

1. Reasons Why The DJI S900 UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, David A. Senechal’s operation of the 

DJI S900 UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security. Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 
18

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, David A. Senechal submits that the DJI S900 UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) 

the characteristics of the DJI S900 UAS; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 

a. The Specifications Of The DJI S900 UAS Demonstrate Its Safe 

Characteristics. 

The DJI S900 UAS does not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, 

weight, speed, and operational capability. 

i. Technical Specifications Of The DJI S900 UAS. 

The technical specifications of the DJI S900 UAS are set forth in the DJI 

S900 and the WooKong M (multi-rotor) User Manuals, attached hereto 

as Exhibits A and B, respectively. 

ii. The DJI S900 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area. 

The DJI S900 UAS may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI S900 UAS is provided in the WooKong M 

(multi-rotor) User Manual, attached hereto as Exhibit B. 

iii. The DJI S900 UAS Is Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation. 

When the Control Link is lost, the DJI S900 UA will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI S900 UAS 

does not reacquire control link data from the GCS, the UAS will assume 

that the Control Link is lost and the UA will return to the home position 

(i.e., failsafe mode) via GPS, and will descend to the takeoff position 
19

and shutdown. A complete description of the Failsafe Functions of the 

DJI S900 UAS is provided in the WooKong M (multi-rotor) User 

Manual, attached hereto as Exhibit B. 

iv. The DJI S900 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

S900 flight control software is provided in the WooKong M (multirotor) and Spektrum DX18 User Manuals, attached hereto as Exhibits B 

and C, respectively. 

b. Flight Operations Of DJI S900 UAS Are Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer. 

David A. Senechal will authorize only certificated pilots who meet FAA 

approved medical standards to act as a pilot in command (PIC) of the DJI 

S900 UAS. Additionally, when needed to maintain Visual Line of Sight 

(VLOS), a safety observer will assist the pilot during flight time. 

c. Flights Of DJI S900 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, David A. Senechal proposes to commercially 

operate DJI S900 UAS for the purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following 

specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UAS 

weighing less than 55 pounds maximum gross weight: DJI S900 

Unmanned Aircraft Systems. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting 

operations for the purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 40 knots. 

4. The UAS must be operated at an altitude of no more than 500 feet above 

ground level (AGL), as indicated by the procedures specified in the 
20

operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC, 

or safety observer, at all times. This requires the PIC to be able to use 

human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) to 

maintain VLOS is not permitted. 

7. When needed to satisfy the VLOS requirement, all operations will utilize a 

safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The 

PIC and SO must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. 

8. The SO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. The SO must possess a valid state driver’s license to ensure 

that he/she meets the minimum health and visual acuity requirements to 

perform the SO function. 

9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant 

of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must 

also present updated and revised documents if it petitions for extension or 

amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating 
21

until the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. The Ground Control Station must be 

included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the 

UAS operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts 

the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit 

requirements. 

14. The operator must carry out its maintenance, inspections, and record 

keeping requirements, in accordance with the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between 

inspections. 

17. The PIC must possess at least a private pilot certificate, and meet FAA 

approved medical standards. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely

operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of 

training the operator’s PICs are permitted under the terms of the 

exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UAS with 
22

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 

C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of 

operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UAS may not operate within 5 nautical miles of an airport reference 

point as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s ATC Tower or airport management 

is obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. The letter of agreement with the 

airport’s ATC Tower or airport management must be made available to the 

Administrator upon request. 

21. The UAS may not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC. 

22. If the UAS loses communications or loses its GPS signal, it must return to 

a pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the UAS with 25% 

battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airman (NOTAM) not more than 72 hours 

in advance, but not less than 48 hours prior to the operation. All operations 

shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified 

by serial number, registered in accordance with 14 C.F.R. part 47, and 

have identification (N- Number) markings in accordance with 14 C.F.R. 

part 45, Subpart C. Markings must be as large as practicable. 
23

27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UAS must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

29. The UAS must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or 

vehicle. 

31. Flight operations must be conducted at a safe distance from all 

nonparticipating persons (persons other than the PIC, SO, operator trainees 

or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UAS and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are at an unsafe 

distance from the UAS, flight operations must cease immediately 

and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable 

COA must be reported to the FAA's UAS Integration Office (AFS-80) 

within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 
24

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety. 

David A. Senechal submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to 

operate the DJI S900 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

S900 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Considering David A. Senechal’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (See Exemption 

No. 11062); and the airmanship skills necessary to safely operate the DJI S900

UAS, David A. Senechal submits that the additional manned airmanship experience 

of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for David A. Senechal’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

David A. Senechal will not allow any PIC to operate the DJI S900 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI 

S900 UAS training and currency requirements, that the PIC is able to safely operate 

the DJI S900 UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 
25

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption). In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure 

an equivalent level of safety during David A. Senechal’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as 

follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations 

for the purpose of motion picture filming (or similar operations), the PIC must 

have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 

hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as 

a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 

11062, the PIC must also have accumulated and logged a minimum of 5 hours as 

a UAS pilot operating the same make and model of UAS to be used for 

operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours 

make and model time may be included in the 10 hours of multi-rotor time and 

the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In 

addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that 

at a minimum, the flight-hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely 

conduct the petitioner’s proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with applicable 

regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UAS with 

appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 
26

Accordingly, David A. Senechal will ensure safe operations by not allowing any

PIC to operate the DJI S900 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the DJI S900 UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, David A. Senechal will ensure that the DJI S900 UAS 

is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI S900 UAS will be provided to the PIC 

via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with David A. Senechal’s operation of 

the DJI S900 UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information will 

be generated by GPS equipment installed onboard the aircraft. Prior to each flight, 

a zero altitude initiation point is automatically established by the UAS at ground 

level. 
27

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

S900 UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, David A. Senechal will 

ensure that he will safely operate the battery powered DJI S900 UAS during 

daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 14 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI S900 

UAS; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI S900 

UAS iOSD provides visual warnings to the PIC at the GCS when the UAS 

experiences low battery voltage; and the Spektrum DX18 transmitter utilizes a 

count-down timer with an aural alert to warn of an impending low battery level. At 

a critically low battery level, the DJI S900 UAS will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for 

manned aircraft to operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has 

previously granted relief from Section 91.151 specific to UAS, in circumstances 
28

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not 

Adversely Affect Safety. 

In seeking this exemption, David A. Senechal submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because David A. Senechal will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed in the operating documents [i.e., 

DJI S900 User Manual, WooKong M (multi-rotor) User Manual, Spektrum DX18 

User Manual, pre-flight checklist, and monthly maintenance log]. Furthermore, 

David A. Senechal will document and maintain all maintenance records for the DJI 

S900 UAS. 

Since the DJI S900 UAS will be inspected as prescribed by the operating 

documents, David A. Senechal will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 

operating documents [i.e., DJI S900 User Manual, WooKong M (multi-rotor) User 

Manual, Spektrum DX18 User Manual, pre-flight checklist, and monthly 

maintenance log]are attached hereto as Exhibits A, B, C, D, and E, respectively. 

Likewise, the exemption sought will not adversely affect safety because David A. 

Senechal will use trained technicians to perform maintenance, alterations or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents. 
29

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance 

of the DJI S900 UAS will be performed by trained technicians. Maintenance will 

be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that 

safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. 

In consideration of David A. Senechal’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI S900 UAS, David A. 

Senechal submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, David A. Senechal 

requests that the FAA prescribe special conditions for the intended operation of the 

DJI S900 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special 

conditions will permit safe operation of the UAS for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, 
30

or otherwise pose a threat to national security; and further, provides the authority

for such UAS to operate without airworthiness certification in accordance with any 

requirements that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the DJI S900 UAS, since the airworthiness regulations of 

14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to 

the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft engine, 

or propeller because of a novel or unusual design feature of the aircraft, aircraft 

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for David A. Senechal’s intended operation of the 

DJI S900 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

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

 
31

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which David A. Senechal Seeks Exemption: 

David A. Senechal seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption David A. Senechal 

Seeks: 

This exemption will permit David A. Senechal to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support David 

A. Senechal’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, David A. Senechal’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 

C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without 

airworthiness certification. 

As discussed in detail above, David A. Senechal will operate the DJI S900 UAS safely 

in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise 

pose a threat to national security. 

 
32

CONCLUSION 

As set forth herein, David A. Senechal seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the DJI S900 UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing David A. 

Senechal to safely, efficiently, and economically operate the DJI S900 UAS commercially 

within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, David A. Senechal respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

S900 UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States. 

Dated: April 14, 2015 

 Respectfully submitted, 

 

 _________________________ 

 David A. Senechal 

 P.O. Box 21396 

 Louisville KY 40221 

 Tel: (812) 786-6100 

 

Appendices: 

A – DJI S900 User Manual 

B – WooKong M (multi-rotor) User Manual 

C – Spektrum DX18 User Manual 

D – Preflight Checklist 

E – Monthly Maintenance Log 
33

APPENDIX – A 

DJI S900 User Manual 

Due to the size of the subject user manual, an electronic version is located at: 

http://download.dji-innovations.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf 
34

APPENDIX – B 

WooKong M (multi-rotor) User Manual 

Due to the size of the subject user manual, an electronic version is located at: 

http://download.djiinnovations.com/downloads/wkm/0823/WooKong_M_User_Manual_en.pdf 

 
35

APPENDIX – C 

Spektrum DX18 User Manual 

Due to the size of the subject user manual, an electronic version is located at: 

http://www.horizonhobby.com/pdf/SPM18000-Manual.pdf 

 
36

Appendix D 

DJI S900 UAS Preflight Checklist 

Attach camera to gimbal, ensure secure and properly aligned. 

Deploy and lock frame arms, ensure locked. 

Unfold GPS antenna, ensure locked. 

Visually inspect airframe, motors & props, wiring. 

Install flight battery, connect negative (-) terminal. 

Power on transmitter. Verify correct power setting. Validate aural start-up tones, verify 

DJI S900 configuration, set battery count-down timer to match installed battery, observe 

all switch positions, verify transmitter voltage. 

Power on camera, verify operation. 

Power up DJI S900 by connecting inflight battery positive (+) terminal. 

Validate aural start-up tones. Observe gimbal operation, validate pitch control via 

transmitter control. 

Verify LEDs on each motor arm, verify WooKong M LED status light operating normally. 

Apply power to visual monitor. Verify proper channel reception and adequate receiver 

voltage, verify video and iOSD display normal. 

For GPS operations, confirm reception of at least 6 satellites prior to take-off. 

Start motors in idle briefly, then increase above 0%, validate Home Position recorded in 

autopilot via WooKong M LED status light. Transmitter count-down timer begins when 

throttle increased above 0%. 

Continue to increase throttle until take-off thrust is attained. 

 
37

APPENDIX – E 

month:_________(year:________

UAS$#:$___________ Date(Issue(

Discovered

Date(Issue(

Addressed

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other:

MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted

Maintenance(Performed(By:(((

Print(&(Sign