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), and 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 provide 
significant 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 small (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 continuing evolving mission under the FAA Modernization 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 air and noise pollution generated 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 Drone 

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 requested and by permission 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 protocols 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 does 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 Sedona 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 future 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 Arizona specifically Sedona and the Verde Valley Arizona prohibits potential 

home Buyers/Sellers/Owners of property to see boundary lines, monitor property boundaries or 
land 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 controlled 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 not be photographed without their consent nor will 

restricted 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 sUAS flights will not operate 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 flight 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 plotted 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 wit 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 Modernization and Reform act of 2012 which will allow safe 
operation 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