Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 C.F. R. Part 11, Destinations Unknown Productiosn, seeks an 

exemption from Federal Aviation Regulations ("FARs") detailed below for the following 

described Unmanned Aerial System called in this application the ME System, which 

includes an Unmanned Aircraft (UA) and ground station-based equipment and crew: 

THE UNMANNED AIRCRAFT (UA): 

[~]A lightweight (20 lb gross weight with all on-board equipment), manufactured by DJI, 

Phantom 3 that includes the following equipment in flight;

[¥] An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/controller; 

[~]An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video;

[~ An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site; 

~ A 2.4GHz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above; 

THE GROUD STATION -BASED PART OF THE SYSTEM: 

t~] A Pilot in Command (PIC) in operational control of a flight operation from beginning 

to end and who controls the UA while in the air;

[~A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in 

flight; ["?J A radio receiver receiving live video and flight data from the on-board 

camera and computer projects it all together onto a screen for the PIC to view during 

flight; 

t?.J A Visual Observer (VO) is a person who provides a second pair of eyes to visually 

track the UA while in flight 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above described ME System to support Production of 

promotional materials (video and/or still images) for Real Estate sales Production of 

promotional

materials, (video and/or still images) for Travel and Tourism industriesProduction of 
promotional materials, (video and/or still images) for commercial businesses, 

Photography and videography of social events, such as weddings never operating over 

persons not directly involved with the ME system. Also, for Network Television and 

Feature Films.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and 

diminish the likelihood of death or serious bodily injury. With a small payload and 

maximum flight time of only 18 minutes, this is offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than 

ground- based imagery for displaying the characteristics of large, complex properties 

with several buildings and large trees. The alternative could be to charter a full-sized 

helicopter for this purpose, which has proven more costly than many potential clients 

are able to afford. The benefits of reduced cost and improved quality of presentation 

from the UA will be valuable to and benefit many buyers and sellers of real property 

and marine property. 

Additionally, we request that we be allowed to use our system to benefit first 

responders nearby who might require assistance, including fire fighters, the police, the 

sheriff, et al., while remaining subject to all limitations cited in this application as we do 

so. 

The ME System will be operated in the field with both a PIC and aVO in accordance 

with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with 

the following Restrictions: 

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an

airspeed of no more than 50 knots and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the 

property owner; e) The PIC must have accumulated and logged, in a manner consistent 

with 14 CFR § 61.51

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot 

and at least ten hours logged as a UA pilot with a similar UA type;

f) All required permits will be obtained from state and local government prior to 

operation;

g) The ME System will not be operated over densely populated areas;
h) The ME System will not be operated at air shows;

i) The ME System will not be operated over any open-air assembly of people;

j) The ME System will not be operated over heavily trafficked roads;

k) The ME System will not be operated within 5 NM of an airport or heliport;

I) Operations will be restricted to day only and weather conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the operation and risk before the 

first flight at each new location;

n) No flight may be made without a Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight (see Appendix A). 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 

16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on 

the system and will complete a course of maintenance instruction as part of their initial 

training. 

We submit that the combination of the UA's light weight, flight performance and ability, 

fully qualified flight crew and strict operation under the guidelines established in 

8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can 

have full confidence that the operation will have an equivalent or greater level of safety 

than manned aircraft performing the same mission. 

The name and contact information of the applicant are: 

Destinations Unknown Productions LLC : Maurice Sessoms Ph# (201)-838-8157 

Email: MauriceSessoms@me.com

The regulations from which the exemption is requested are listed below. Beside each 

regulation number is the page of the attached Addendum upon which each may be 

found together with our proposed equivalent level of safety for each regulation: 

- 14 CFR Part 21 .................................Addendum Page 1 - 14 CFR 

91.203.................................Addendum Page 1 - 14 CFR 45.23, 

45.29..........................Addendum Page 2 - 14 CFR 

91.9....................................Addendum Page 2 

- 14 CFR 61.113, 61.133.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 .............. Addendum Page 3

- 14 CFR 91.151 .................................Addendum Page 3

- 14 CFR Subpart E (91.401 - 91.417) ......Addendum Page 3

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) ...Addendum 1 
We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional 

information or clarification. We look forward to working with your office. 

Sincerely, Maurice Sessoms

Cl23J ~------- 

Maurice Sessoms Destinations Unknown Productions LLC

Addendum containing Exemption Requests and Equivalent Level of Safety Appendix A 

- Flight Manual's

Appendix B - Owner's Manual for UA

ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Destinations Unknown Productions requests an exemption from the following 

regulations as well as any additional regulations that may technically apply to the 

operation of the ME System: 

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for Unmanned 

Aerial Systems, we request an experimental certificate be issued for the ME System 

under either or both of the following provisions: 21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new uses 

for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations 

to show compliance with the airworthiness regulations including flights to show 

compliance for issuance of type and supplemental type certificates, flights to 

substantiate major design changes, and flights to show compliance with the function 

and reliability requirements of the regulations. Since the experimental certificate can be 

used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit 

our commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements. Combined with the UA's light weight, being 

constructed primarily of carbon fiber and plastic, we propose that the UA will be at 
least as safe, if not safer, than a conventionally certificated aircraft performing the same 

mission. 

If an experimental airworthiness certificate is not appropriate for this application, then 

we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an 

airworthiness certificate in general, citing the equivalent level of safety outlined in the 

previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew."

At a maximum gross weight of 6.5 pounds, the UA is too small to carry documentation, 

does not have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the 

crew at the ground control station and available for inspection upon request. In order to 

identify the aircraft, we propose that the information found on airworthiness and 

registration certificates be permanently affixed to the aircraft via placard containing the 

following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 

CFR 45.23, which follows immediately after the proposed placard description below: 

Appendix A

EXPERIMENT AL

Manufacturer: DJI Innovations, Inc. 950 E Baseline Ave. Ste. 210 Apache Junction AZ 

85119 Models: Phantom 3

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display N'' and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must 

display the word 

EXPERIMENTAL in letters at least 2 inches high near the entrance to the cabin, cockpit, 

or pilot station. The UA does not have an entrance in which the word EXPERIMENTAL 

can be placed, and may not have a registration number assigned to it by the FAA. 

We propose to achieve an equivalent level of safety by including the word 
in the placard on the top of the aircraft, as shown above, where the PIC, VO and others 

in the 

vicinity of the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, we feel that the permanent placard discussed in the previous paragraph 

will 

provide the aircraft's registration information at the ground station. Finally, we will 

display at the 

ground station a high contrast flag or banner that contains the words ~~unmanned 

Aircraft 

Ground Station in letters 3 inches high or greater. Since the aircraft will operate within 

3/4 NM of the ground station, the banner should be visible to anyone that observes the 

aircraft and chooses to investigate its point of origin. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. We assume that the intent of this requirement 

is to ensure that flight manual information is available to the aircrew while operating the 

aircraft. We request an exemption to this requirement since the aircraft is not only too 

small to carry documentation, the documentation would not be available to the crew 

during flight operations. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a 

current, approved UA Flight Manual (Appendix A) must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command 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. 

Our proposed operations require that the PIC must either 

1. have logged 25 hours of flight experience in this type of UA, or 
EXPERIMENTAL 

Private Pilot written examination.~~ Since there are currently no means available for 

the pilot of a UAS to gain the experience in an equivalent category and class in order to 

apply for a commercial pilot's license, we propose to generate an equivalent level of 

safety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground 

instruction and pass the FAA Commercial Pilot written examination in addition 

Appendix A

to completing the private pilot requirements. Since the aircraft cannot carry passengers 

or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the 

intent of this application is to conduct a business. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." 

The ME System ground-based control station consists of a small hand-held radio 

transmitter 

and while it does not offer a second set of Controls , both the student and instructor 

can, and 

will, operate the single set of controls simultaneously. With both student and instructor 

having 

hands-On the controls during flight, we feel that this technique meets the intent 91.109 

and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the 

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this 

requirement. 

In order to provide an equivalent level of safety we will only fly over private property 

with a size of at least two acres with the permission of the owner of the property flown 

over. The aircraft will not be operated over congested areas or over any open air 
assembly of persons. The property owner will be briefed on the expected route of flight 

and the associated risks to persons and property on the ground. The aircraft will be 

operated at a low altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. 

Therefore we maintain that due to the small size of the UA, the hazard to persons, 

vehicles and structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. 

The UA will always fly below 400 feet AGL and will not need to maintain cruising 

altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the UA onboard computer to the display screen held by the PIC, providing a constantly updated 

AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an 

energy reserve as a safety buffer for delays to landing. The UA is battery operated and 

the maximum duration of flight from a single battery charge is 18 minutes with a 20°/o 

reserve. Since the aircraft will never fly more than 314 NM from the point of intended 

landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for 

an equivalent interpretation with the word "energy". 

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, 

Alterations

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. 

Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance and inspection. 

It is our intention that the PIC perform maintenance and inspection of the aircraft and 

"be authorized to approve the aircraft for return to service." As provided in the Pre-
Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every 

two hours of flight. Maintenance performed by the PIC is limited to repairing small 

cracks, replacing a propeller, checking electrical connections and updating software 

and firmware for the on-board computer. All other maintenance will be performed by 

the manufacturer or their designated repair facility. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second-class 

medical certificate issued under part 67 in order to perform as a pilot or observer. The 

UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic 

and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. 

Given the unlikely event that both the PIC and VO become medically incapacitated 

while the aircraft is in flight, the UA will return autonomously to the site of launching 

and land without crew intervention. 

Therefore, requiring the PIC and VO to meet the same medical requirements as a 

commercial pilot carrying passengers in a large aircraft is an unnecessary burden. 

We propose that the minimum medical requirements for the PIC and VO be vision 

corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision 

requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed 

driver is medically qualified to operate a much larger vehicle. 

APPENDIX A - FLIGHT MANUAL 

FLIGHT RESTRICTIONS

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an 

airspeed of no more than 50 knots and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate verbally at all times during a flight operation;

d) Operations will be restricted to flights over property with the permission of the 

property owner; e) The PIC must have accumulated and logged, in a manner consistent 

with 14 CFR § 61.51

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot 

and at least ten hours logged as a UA pilot with a similar UA type; 
f) All required permits will be obtained from state and local government prior to 

operation; g) The ME System will not be operated over densely populated areas;

h) The ME System will not be operated at air shows;

i) The ME System will not be operated over any open-air assembly of people; 

j) The ME System will not be operated over heavily trafficked roads;

k) The ME System will not be operated within 5 NM of an airport or heliport;

I) Operations will be restricted to day only and weather conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the operation and risk before the 

first flight at each new location;

n) No flight may be made without a successful Pre-Flight Inspection by the PIC before 

each operation to ascertain that the UA is in a condition safe for flight. 

PREFLIGHT CHECKLIST

1. Remote controller, aircraft battery, and mobile device are fully charged.

2. Propellers are mounted correctly and firmly.

3. Micro-SO card has been inserted if necessary.

4. Gimbal is functioning as normal.

5. Motors can start and are functioning as normal.

6. DJI Pilot app connected to the aircraft.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT

If radio contact is lost and not restored within 3 seconds, an automatic Return to Home 

feature is activated and will bring the UAV back to the PIC.