Docket Management System

800 Independence Ave. SW

Washington DC, 20591

September 21, 2015 & sent again on November 12, 2015

Ref: Docket # FAA

- 2015

- 2571

Dear Sir or Madam,

In response to your letter dated 17, September 2105 I would like to respond to the following information that has been requested.

Petitioner

Dennis D. Pinciaro

Sedona Drone

PO Box 21063

Sedona, AZ. 86341

Phone 928

- 301

- 4360

Email: dpco.dp2@gmail.com

Public Interest

Granting the Section 333 petition for exemption will further the public interest by allowing Sedona Drone to perform safely, efficiently, and economically aerial photography and video of construction sites, real estate (assisting Agents/Sellers in marketing a home), a nd landscape over certain identified areas of the United States. Additionally the sUAS DJI Phantom 2 Vision

current Tail Number N5852P would decrease congestion of NAS, reduce pollution, and providesignificant benefits to the economy

. DJI currently has a Section 333 exception on file will the

FAA.

The integration of sUAS’s into the NAS will not only replace traditionally more expensive options and/or approaches to aerial photography it will enable work to be done in ways simply impossible to do previously

. The commercial deployment of sm all (under 55lbs.) aircraft offers the public a new, highly efficient and inexpensive approach to aerial imagery.

In deploying its sUAS DJI Phantom 2 Vision Sedona Drone uses protocols that are aligned
with the FAA’s contin uing evolving mission under the FAA Moder nization and Reform Act of
2012 to provide safe operating practices for public safety.

Aerial imagery with the DJI Phantom 2 Vision as an alternative to manned aircraft will greatly benefit the public by reducing ai r and noise pollution ge nerated by traditional aircraft including current helicopters. The battery operate ( fuel free) sUAS DJI Phantom 2 Vision has (4) electric

motors that are pollution free and reducing a carbon footprint for aerial imagery. Sedona Dr one Use a DJI Phantom 2 Vision that weighs <3.1 lbs., Max Ascent/descent 20.7 ft. /s, Max flight Velocity 32.8ft/s, and Propeller length @ 9 inches/Diagonal 13.8 inches reducing risk to life and property. Flight logs and a monthly maintenance log will be established and maintained.

The sUAS DJI Phantom 2 Vision will be primarily used for Real Estate Photography. Only by special request will the sUAS be used for special activities request ed and by permissio n of a business owner or private parties by Sedona Drone and evaluated each for its merits and objectives. All would fall/comply with the standards above.

Public Safety

Public safety will be the primary objective and operational requirement for Sedona Drone. Flight plan/s for the specific area /location and photographic objective will be developed and will be very specific to the well

- defined flight mission. Flight prot ocols will be clearly defined to the one and only pilot for Sedona Drone. In seeking the Section 333 Exception Sedona Drone commits to and will operate safely in the NAS as directed by the FAA’s policies for sUAS < 55 lbs. The
sUAS DJI Phantom 2 Vision doe s not create a hazard to its pilot, the NAS, to the public at large, or national security.

The sUAS DJI Phantom 2 Vision has several built in features such as return

- to

- home point
under its fail safe mode via GPS the unit will descent to the takeoff location in the event of loss of control link. Whether inspecting infrastructure, conducting site and land observations, and primarily photographing real estate safety will and is the primary objective of S edona Drone. For whatever reason if the flight environment is unsafe any and all flights will be canceled. Client

or observers on site Safety Briefings will provide high level of safety and oversight for the public to comply with the FAA’s current and futu re guidelines. All flight operations will be conducted in accordance with current and future FAA Aviation Regulations, including minimum altitude requirements of 14 C.F.R. 91.119. All flights will be in the public’s best interest.

Terrain of Northern Arizo na specifically Sedona and the Verde Valley Arizona prohibits potential home Buyers/Sellers/Owners of property to see boundary lines, monitor property boundaries orland misuse by trespassers. Use of sUAS’s can help them evaluate safely as well as identify

their property without high expense of commercial aircraft which disrupt neighborhoods with noise and air pollution, and are cost prohibitive , also cannot access cliff or mountainous areas.

Additional Information

All flights will be private and/or contro ll ed access to the subject property with the owners or controlling authority’s consent prior to the flight. Written consent will be obtained from either the owner or controlling authority. People will no t be photographed without their consent nor will

rest rict ed areas where flight operations are restricted in the NAS.

Limitations and Conditions

The applicant proposes the following limitations and conditions:

1. The sUAS will be < 55 lbs.

2. The sUAS airspeed will not exceed 50 knots

. 3. The s UAS flights will not o perate more than 400 ft. Altitude

. 4. The sUAS will operate within a Visual Line of Sight rules established by the FAA.

5. All operator and User manuals will be updated upon manufacture’s release.
6. Full inspection of the sUAS will be conducted prior to every fli ght by the operator.

7. Sedona Drone will follow the manufacturer’s maintenance requirements.
8. The sUAS will not be operated over person/persons except by previous authorization.
9. If equipment failure is determined at any level the flight will be terminated immediately.
10. The sUAS DJI Phantom 2 Vision will comply with any and all manufactures safety
bulletins.

11. Pre

- flight inspections for all hardware of the sUAS will be required prior to any flight operation.

12. The subject flight path will be surveyed and plotte d prior to any flight.
13. The sUAS will remain clear and yield to any and all manned flight activities including
aircraft but not limited to ultra

- lights vehicles, parachute activities, parasailing, hang gliding, etc.

14. The sUAS will not operate in a class B, C,or D airspace without FAA prior approval.
15. Night flying will not be conducted.
16. The sUAS will not operate above 400 foot ceiling or within 5 miles of a restricted airport.

17. Any accident or incident will be reported to the FAA Integration Office and NTSB w it in 24 hours. Flight operations will not resume until authorized by the fore mentioned agencies.
18. The owner/operator will comply with all applicable parts of 14 CFR.

To be granted this exemption is in the public interest based on the direction of Section 333 of the 2012 FAA Modernization and Reform Act. This Act will ensure safe operation of a sUAS commercially.

As set forth herein, Sedona Drone seeks an exemption pursuant to 14 C.F.R., 11.61 and
Section 333 of the FAA Moderni zation and Reform act of 2012 w hich will allow safeoperation of the sUAS DJI Phantom 2 Vision without an airworthiness certificate, for the

limited purpose of conducting real estate aerial photography over a small and defined operational area of the United States.

Dennis D. Pinciaro

Owner/Operator

Sedona Drone