SEESP AN, Inc. Mark A. Ryan 

Founder, President and CEO 

May 1, 2015 

Mr. James Williams 

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

U.S. Department of Transportation 

Docket Management System 

l200New Jersey Avenue, SE 

Washington, DC 20590 

Dear Mr. Williams: 

SEESPAN, Inc. 

31794 Cameros Avenue 

Lewes, Delaware 19958 

302-360-8847 tel 

·-, ·, rMark@SEESPAN.com 

SEESPAN, Inc. (SEESPAN) submits the enclosed request for exemption from multiple regulatory 

provisions ofthe Federal Aviation Administration (FAA) to allow the use ofsmall unmanned aerial 

systems (sUASs) on land and marine spaces controlled by SEESPAN to conduct safe aerial 

photography of public events, such as sports events, entertainment and news gathering for 

direct public consumption and purchase by sports, entertainment and media organizations. 

This version of SEESPAN's request does not contain certain appendices, which contain trade secre~ 

and commercial proprietary information that SEESPAN has not and will not share with others 

except under appropriate confidentiality agreements. The material contains operating conditions 

and procedures that are not available to the public and are protected from release under the 

Freedom of Information Act. See 5 U .S.C. 552 et seq. A complete copy of SEESPAN's request, 

including the appendices for which SEESPAN is seeking confidential treatment, bas been sent to 

Mark Bury, Assistant Chief Counsel for International Law, Legislation and Regulations, to allow 

you and others within the agency who need to review all portions of this exemption request 

complete, yet controlled, access to the documents. 

Your time and cooperation is much appreciated. 

Sincerely, 
May 1, 2015 

Mr. James Williams 

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office Federal Aviation Administration 

800 Independence Avenue, SW Washington, DC 20591 

U.S. Department of Transportation Docket Management System 

1200 New Jersey Avenue, SE Washington, DC 20590 

Re: Request for exemption from multiple regulatory provisions to allow the use of small 

unmanned aerial systems (sUASs) controlled by standard remote controls (RCs) and backed up 

by the SEESPAN Tethered sUAS Flight Control System ("Patent Pending") that can instantly 

restrict the sUAS'sflight path (speed, altitude and trajectory) and efficiently retrieve the sUAS 

back to the base upon command by the Pilot in Command (PIC). 

Dear Mr. Williams: 

SEESPAN, Inc. (SEESPAN) respectfully requests an exemption from several provisions 

of Title 14 of the Code of Federal Regulations (C.P.R.) to permit the establishment of a new 

state-of-the-art technology for safe aerial photography and public communications. Accordingly, 

the grant of an exemption is consistent with Congress' intent, reflected in Section 333 of the 

FAA Modernization and Reform Act of 2012 (Modernization Act), 1 that safe systems be 

permitted in the national airspace prior to the issuance of final regulations governing general use 

of these systems.2 A summary of this request suitable for publication in the Federal Register is 

provided as Appendix A should the FAA determine that publication is required. 

Background Information 

SEESPAN is a media company created to safely acquire public images and offer them 

directly for public consumption or for publishing purposes by SEESP AN and/or other media 

companies. Unlike other sUAS aerial photography companies or traditional above-ground 

photography methods, SEESPAN's laboratory-tested system3 protects the public from loss of 

positive control. The SEESPAN system maintains positive control over sUAS/photographic 

equipment via physical tether. Upon command by the PIC, the SEESPAN tether system controls 

and restricts the sUAS' flight (speed, altitude and trajectory) and retrieves in-flight the 

sUAS/camera. The SEESPAN Tethered sUAS Flight Control System will stop an sUAS within 

40 feet while under worst-case scenario conditions (flying out of control at 68 mph), and then 

1 P.L.II2-95, 126Stat !!,February 14,2012. 2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a 

type of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, 

and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to 

national security. 3 SEESPAN's Tethered Flight Control System has been proven capable and effective in laboratory testing. See 

Appendix B for test protocol and test results. 
retrieve the sUAS back to the ground-based system while constantly under those worst-case 

conditions. Significantly less distance is needed to halt the sUAS under normal conditions. (A 

summary of laboratory testing of the SEESPAN Tethered sUAS Flight Control System base is 

provided as Attachment B.) SEESPAN also applies unique methods for acquiring and 

communicating images; in particular, SEESPAN uses methods connecting the public to online 

information sources via SEESPAN digital media properties (all SEESPAN media products are 

"Patent Pending"). 

Conventional media organizations rely upon professionals who typically travel to 

destinations, contact sources on location and acquire images and audio for their public audiences. 

This conventional media model is declining rapidly in the marketplace however for a variety of 

reasons. For example, gathering photographic images and audio content is expensive, and 

constrained by human resources both in terms of cost and ability. Conventional media systems 

also typically are limited to acquiring photographic images and audio via ground-level vantage 

points. 

Some conventional systems acquire photographic images via cranes, scaffolding, manned 

aircraft, unmanned aircraft (sUAS/UAS) and satellite. Cranes, scaffolding, blimps and manned 

aircraft are known to be dangerous and carry substantial risk for the crews operating them and for 

the public below. Satellite acquisition is limited to historical still images without audio. The 

historical images are not Jive, oblique, or close enough for interaction. Further, acquisition of 

some areas may be limited because views of the areas may be obstructed, prompting 

photographers to pursue modality options that carry substantially more risk. Some conventional 

systems use fixed cameras installed on structures (e.g., highways and byways). These fixed 

cameras are, however, limited to views from one, low-altitude, low field of view (FOV) fixed 

point (e.g., the toll booth) and also typically provide low-quality clarity of image. Conventional 

media systems also include handling and transporting these larger system components to locations 

of the events. The cost of transporting and operating these system components is expensive and 

carries greater risk to personnel assembling, handling and dismantling them. Further, conventional 

systems are limited in their range and they lack agility, thus requiring multiple photographic 

stations to capture coverage of outdoor action or subject matter. Also, the number of events that 

can be covered is limited to the number of these expensive system components that are available, 

and the number of professionals required to operate them, and the media organization's ability to 

afford the cost to conduct such operations. 

Regulatory Basis for Exemption Request 

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA 

may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption 

is in the public interest. The FAA has imposed a separate requirement in its procedural 

regulations, providing that the petitioner shall explain why granting the exemption would not 

adversely affect safety or how the exemption would provide at least an equivalent level of safety 

as compliance with the underlying regulation.4 In this case, approval of this exemption would 

advance the public interest by significantly enhancing the safety and efficiency of providing 

public access to see activities as they occur in their communities, and for sports, entertainment 

and news gathering organizations to provide public access to their events, and by providing the 

4 14 C.F.R. §ll.8l(e). 
FAA with valuable user experience on sUASs in a context with appreciable economic and 

societal benefits. As described more fully below, the requested exemption would permit the 

operation of a sUAS under tightly-controlled conditions, thus ensuring that operations will not 

have an adverse impact on safety. To the contrary, as explained below, SEESPAN anticipates 

that use of sUASs and the SEESPAN Tethered sUAS Flight Control System will enhance the 

safety of how above-ground photographic images are captured for public consumption. 

Granting an Exemption is in the Public Interest 

The safety and efficiency of aerial or above-ground photography is heavily dependent 

upon radio-controlled/or computer-controlled systems to control the performance of the aerial 

equipment. There are a wide variety of factors that can affect the intended flight of a sUAS 

device, including unexpected wind/weather, lost link with the RC, pilot error, "computer 

hacking," unexpected intrusion upon the restricted area of operations, and other conditions that 

cause the need to halt and retrieve the sUAS back to base. Vigilance and a physical means to 

restrict and retrieve the sUAS are the best defense against these hazards. 

As a result, pursuant to FAA regulations and company policy, SEESPAN personnel will 

follow its ground and flight maintenance manual to ensure the systems are in excellent working 

order. (See Appendix D for the SEESPAN Tethered Flight Manual.) At present, aerial, or aboveground photography, is done primarily by personnel through a labor-intensive and arduous 

series of tasks. Aerial photography companies make use of cranes, scaffolding, blimps, manned 

helicopters, manned fixed-wing aircraft, and satellites to capture images for their clients in various 

industries. Their employees put themselves at risk by assembling and operating this often-times 

heavy equipment and put the participating or non-participating public at risk as well. 

Aerial photography by traditional aircraft is impractical because the required altitudes for 

safe flight reduce visibility below meaningful levels - it is simply not possible to capture 

meaningful or useful images from such distances and/or heights. Thus, the use of sUAS has the 

potential to improve efficiency, resulting in faster and safer delivery of photographic images and 

related information vital to the U.S. public and the American economy. 

Granting an Exemption will not Adversely Affect Safety 

SEESP AN notes that there is no applicable standard for an equivalency determination. 

Some have argued that the appropriate standard is that for model aircraft, noting that their 

operations, if conducted for recreational purposes, would fall completely within the allowable 

operations for model aircraft. We believe it is difficult to argue that there is sufficient correlation 

between model operations controlled by the Academy of Model Aeronautics and the ones 

contemplated by SEESPAN. At the same time, it is clear that equivalency cannot be established 

for traditional, manned civil aircraft because the design and use profiles between traditional 

aircraft and sUAS are simply too different. As such, we believe it makes more sense to focus on 

why the contemplated operations would not adversely affect safety, which is all that §11.8l(e) 

requires. 
That said, SEESP AN believes that granting an exemption will improve public safety over 

current practices involving aerial photography and other above-ground-level photography 

practices. SEESPAN contemplates conducting sUAS operations from a restricted operational 

space, during daylight hours, at altitudes and speeds well below that which would pose a risk to 

other aircraft. The nature of operations anticipated by SEESPAN requires that the sUAS be. 

flown at relatively low altitudes and relatively low speeds. SEESPAN expects that in most 

instances, the sUAS will be flown less than 200 feet in altitude and within its zone of operation, 

which it will prohibit the public from entering. Accordingly, the risk of interference with another 

aircraft or a member of the uninvolved public is minimal and the ability to prevent an accident is 

great. SEESPAN also plans to conduct sUAS operations at least five miles from any public 

airpmts (including heliports). In the event an operation needs to be conducted closer to an 

airport, SEESP AN will inform the airport operator and airport air traffic control tower of the 

contemplated operation and will comply with any directions issued by air traffic control at that 

airport. (Appendix C contains examples of the types of areas where SEES PAN initially intends 

to use the sUAS.) 

SEESPAN intends to use a dedicated staff for sUAS operations. All operations will be 

within visual line-of-sight (i.e., no more than approximately 0.5 miles from the manipulator of 

the controls, or pilot in command (PIC)). The PIC will have at least a recreational or sport pilot 

license and whatever medical documentation is required currently by the FAA to correspond to 

the type of pilot certificate exercised Each PIC will conduct at least three take-offs and landings 

with the sUAS on which he or she is trained every 90 days. Depending on the type of operation, 

additional ground-based visual observers may be employed as well. These observers will be 

within constant visual line of sight and in constant contact with the PIC. The visual observers 

will assist the PIC in avoiding objects near the sUAS. 

SEESPAN intends to use the 3D Robotics X8+ (a description of which is attached in 

Appendix D) with an attached tether. No physical modifications have been made to the aircraft. 

Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C.F.R. § 11.81, SEESPAN provides 

the following information: 

Contact Information 

Mark A. Ryan 

President and CEO 

SEESPAN, Inc., 

31794 Cameros A venue 

Lewes, DE 19958 

302-360-8847 

Mark@SEESPAN.COM 
Regulatory Provisions from which SEESP AN seeks an Exemption 

SEESPAN believes it may need an exemption from the following provisions to conduct 

the contemplated operations. In some instances, relief is needed because relief from another 

provision renders compliance with the regulation at hand infeasible. 

14 C.F.R. §61.23(a) and (c) 

14 C.F.R. §61 l01(e)(4) and (5) 

14 C.F.R. §61.113(a) 

14 C.F.R. §61.315(a) 

14 C.F.R. §91.7(a) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151(a)(l) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a)(1) 

14 C.F.R. §91.409(a) 

14 C.F.R. §91.417(a) and (b) 

SEESPAN believes an exemption is only needed from the above-listed regulatory 

provisions. To the extent that the FAA believes that additional relief is required for SEESPAN to 

conduct the operations described here, we request an exemption from any such regulatory 

provisions as well. 

The Extent of Requested Relief and the Reasons Relief is Needed 

14 C.F.R.§ §61.23(a) and (c), 6J.JOI(e)(4) and (5), 61.113(a), and 61.315(c) 

§61.23 Medical certificates: Requirement and duration. 

(a) Operations requiring a medical certificate. Except as provided in 

paragraphs (b) and (c) of this section, a person-

(1) Must hold a first-class medical certificate: 

(i) When exercising the pilot-in-command privileges of an airline transport 

pilot certificate; 

(ii) When exercising the second-in-command privileges of an airline 

transport pilot certificate in a flag or supplemental operation in part 121 of 

this chapter that requires three or more pilots; or 

(iii) When serving as a required pilot flightcrew member in an operation 

conducted under part 121 of this chapter if the pilot has reached his or her 

60th birthday. 

(2) Must hold at least a second class medical certificate when exercising: 

(i) Second-in-command privileges of an airline transport pilot certificate in 

part 121 of this chapter (other than operations specified in paragraph 

(a)(l )(ii) of this section); or 

(ii) Privileges of a commercial pilot certificate; or 
(3) Must hold at least a third-class medical certificate-

(i) When exercising the privileges of a private pilot certificate; 

(ii) When exercising the privileges of a recreational pilot certificate; 

(iii) When exercising the privileges of a student pilot certificate; 

(iv) When exercising the privileges of a flight instructor certificate and 

acting as the pilot in command; 

(v) When exercising the privileges of a flight instructor certificate and 

serving as a required pilot flight crewmember; 

(vi) When taking a practical test in an aircraft for a recreational pilot, 

private pilot, commercial pilot, or airline transpmt pilot certificate, or for a 

flight instructor certificate; or 

(vii) When performing the duties as an Examiner in an aircraft when 

administering a practical test or proficiency check for an airman 

certificate, rating, or authorization. 

*** 

(c) Operations requiring either a medical certificate or U.S. driver's 

license. (1) A person must hold and possess either a medical certificate 

issued under part 67 of this chapter or a U.S. driver's license when-

(i) Exercising the privileges of a student pilot certificate while seeking sport 

pilot privileges in a light-sport aircraft other than a glider or balloon; 

(ii) Exercising the privileges of a sport pilot certificate in a light-sport 

aircraft other than a glider or balloon; 

(iii) Exercising the privileges of a flight instructor certificate with a sport 

pilot rating while acting as pilot in command or serving as a required 

flight crewmember of a light-sport aircraft other than a glider or balloon; 

or 

(iv) Serving as an Examiner and administering a practical test for the 

issuance of a sport pilot certificate in a light-sport aircraft other than a 

glider or balloon. 

(2) A person using a U.S. driver's license to meet the requirements of this 

paragraph must-

(i) Comply with each restriction and limitation imposed by that person's U.S. 

driver's license and any judicial or administrative order applying to the 

operation of a motor vehicle; 

(ii) Have been found eligible for the issuance of at least a third-class airman 

medical certificate at the time of his or her most recent application (if the 

person has applied for a medical certificate); 

(iii) Not have had his or her most recently issued medical certificate (if the 

person has held a medical certificate) suspended or revoked or most recent 

Authorization for a Special Issuance of a Medical Certificate withdrawn; 

and 

(iv) Not know or have reason to know of any medical condition that would 

make that person unable to operate a light-sport aircraft in a safe manner. 

***** 
§61.101 Recreational pilot privileges and limitations 

*** 

(e) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircraft-

*** 

***** 

(4) For compensation or hire; 

(5) In furtherance of a business; 

§61.113 Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no 

person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as pilot in command of an aircraft. 

***** 

§61.315 What are the privileges and limits of my sport pilot certificate? 

(a) If you hold a sport pilot certificate you may act as pilot in command of 

a light-sport aircraft, except as specified in paragraph (c) of this section. 

***** 

SEESPAN anticipates initially using specially trained staff to conduct the sUAS 

operations. Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC operating the 

aircraft to have at least a recreational or sport pilot license to operate this sUAS. The FAA has 

already approved the use of these pilots in other exemptions, recognizing the extensive 

requirements for private or commercial pilot certificates are not required to safely operate the 

sUAS. Unlike conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. 

The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the SEESPAN Field Testing Procedures, Logs, Guidelines 

Manual (See Appendix E). The sUAS will fly at altitudes well below the permissible 

limits for other civil aircraft, eliminating the risk to other aircraft, and within a 

geographical envelope under the sole control of SEESPAN. In addition, the tether 

system enables immediate stoppage and recovery of the unmanned aircraft in a safe, 

efficient and controlled manner should other aircraft or unauthorized individuals 

enter the area of operation. Accordingly, the risk would be limited to SEESPAN 

personnel, who will be appropriately outfitted in safety gear, and SEESPAN property 

on the ground. 

14 C.F.R. 91.7(a) 

§91. 7 Civil aircraft airworthiness. 

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

condition. 
(b) The pilot in command of a civil aircraft is responsible for determining 

whether that aircraft is in condition for safe flight. The pilot in command shall 

discontinue the flight when unairworthy mechanical, electrical, or structural 

conditions occur. 

There is no clear definition of "airworthy," and the term has been defined in various ways 

depending on the circumstances. In all instances, it appears that the concept includes a 

requirement that the airplane 1) conforms to the aircraft's type design or its type certificate, as 

modified by supplemental type certificates and airworthiness directives, and 2) be in condition 

for safe operations. The sUAS will not have a type design or type certificate, as the FAA has not 

developed standards applicable to sUAS. As discussed later in this document, the types of 

operations contemplated by SEESPAN will not qualify the sUAS for an experimental 

airworthiness certificate. Accordingly, relief from §91.7(a) is required. Should the FAA 

include airworthiness requirements as a condition of exercising the exemption, SEESPAN will 

assure the continued airworthiness of the sUAS. Regardless, SEESPAN believes that it can 

meet the requirements of §91.7(b) and is not requesting an exemption from that provision. 

14 C.F.R. 91.119 

§91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

*** 

(b) Over congested area Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, at an altitude of 1,000 feet 

above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

***** 

SEESP AN submits that the only relief it requires from §91.119 is from the minimum 

altitudes and minimum distances to people, vessels, vehicles and structures 

listed in paragraphs (b) and (c). Relief is required from paragraph (c) because asset evaluation 

conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at 

this altitude also pose a heightened risk of collision with another aircraft, safety can only be 

assured through the grant of an exemption. 

Relief is requested from paragraph (b) for the same reasons, as well as because the tether 

allows for the safe operation near people, and can accordingly be used in congested areas, even 

though it will not technically be flown directly over anyone other than SEESPAN personnel 

directly involved in the operation. SEESPAN suggests that given its tether design, which has 

been tested both in the laboratory and in the field to validate the strength and capabilities of the 

tether in worst-case scenario conditions, relief should be granted as long as the aircraft is no closer 

than 100 feet from members of the uninvolved public when the tether is engaged. SEES PAN 
believes the tether provides the same level of protection as a barrier; which the FAA has routinely 

allowed as a means of operating an unmanned aircraft closer than 500 feet in other exemptions. 

The 100 foot buffer zone provides added protection from any flying debris. 

The SEESPAN Tethered sUAS Flight Control System is proven capable of restraining and 

retrieving the sUAS efficiently, even tmder worst-case scenario conditions, regardless of 

trajectory, altitude or speed (up to 68 mph). The SEESPAN Tethered sUAS Flight Control System 

provides: 

• 3X safety factor with the power to stop a runaway sUAS, even at worst-case scenario speeds of 68 

mph. 

• 3X safety factor with the power to ensure the tether remains attached to the sUAS. 

• Can stop an sUAS within 40 feet under worst-case scenario conditions and safely retrieve the 

sUAS to the SEESPAN base. 

Further, outdoor testing has shown that the SEESPAN system stops the sUAS at its 

maximum flying speed and then retrieves the sUAS in flight (video showing the SEESPAN flight 

tests are available in Appendix G). 

Relief should not be needed from paragraph (a) because an emergency landing of the 

aircraft due to a power failure will not create an undue hazard to persons or property on the 

surface. As noted in the explanation of why an exemption will not adversely affect safety, 

SEESPAN has exclusive control over the geographic space over which it is operating, and public 

access is restricted. We tightly control access to our operational space and have the ability to 

assure that no individuals unassociated with the planned operations enter that space. 

14 C.F.R. 91.121 

§91.121 Altimeter settings. 

(a) Each person operating an aircraft shall maintain the cmising 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) ff there is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the cunent 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 depa1ture airport or an appropriate altimeter setting available before departure; 

or 

(2) At or above 18,000 feet MSL, to 29.92" Hg. 

(b) The lowest usable flight level is determined by the atmospheric 

pressure in the area of operation as shown in the following table: 
Current altimeter setting . Lowest usable night level . ·· '·C ,~" .·:< ,f'f.·•'•'~-'l.to.·.;-(,,;~~~.Y':'Il\~·;;.:,.,;< ·~:;.;"'•~<~:'-~.-~f:·,,~;!i·k~~~,N~ ;.:.·,::(.· ,:\• :.;:.<>.-:·.,\~· ;::7-::,i;'·.:t~i?~'··'il''';"-\l!,,<:,~"''tr;..)• ;':f;'/K<O;i2"):>i·"~~).};,'i~:ri>)l;•:;;~ •• ~.'N'·\: ·:i'-!<!':-;;;,-,i:'".t>\ib·.~'~'~·~·;:;~~~<:~tk~9:w:N.-i ~~(.\-.,>':.~:"'"''·•'~'';"''-" ~J<'H'fi· ·< Y ';..',<•;c;m"'"'';c•:<&<M 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.41 through 28.92 190 

28.91 through 28.42 195 

28.41 tJuough 27.92 200 

27.91 through 27.42 205 

27.41 through 26.92 210 

(c) To convel1 minimum altitude prescribed under~~ 9l.l19 

and 91.177 to the minimum tlight level, the pilot shall take the tl ight level 

equivalent of the minimum altitude in feet and add the appropriate number of feet 

specified below, according to the current reported altimeter setting: 

Current altimeter setting Adjustment factor ~·.~-:Y.~:i·.'?·~~~\~~)'i'"'l-1~"'{•'<~>X;;\'!h,«;:~:'f».1ll•'~;:o""'1~"''<~ ;,~.,;-tA%<'-h'i'!<<~'\C';;;o,.i-;Y.x.~·{;-..;~. "Ol::' .··'..<;-""''"'·'> l'>>'<.,..,l<:!!.'-Jl>:"'"'"'""""'""""'' .~~ >~"<")'~'f>'N'i;i.:i~:.~,:-:<.> ~-·:;•;·.~;..>.t~~·';' ~-....;,>-< c~t-.l·lt-,~~· ~~,;.:, .'k'!'r.<'-•; ~·· <F, _,, .• ,",!:";",:! 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through27.92 2,000 

27.91 through 27.42 2.500 

27.41 through 26.92 3,000 

SEESPAN believes an altimeter is not needed because the very nature of aerial 

journalism, or aerial photographic coverage of sports or entertainment events, requires that the 

sUAS maintain flight relatively low to the ground to effectively capture photographic images at 

the ground level. That is, at or under 200 feet AGL. Here again, the SEESPAN Tethered sUAS 

Flight Control System enables the pilot to safely restrain and retrieve the sUAS should there be a 

significant exceedance of that 200-foot level. In addition, the SEESPAN PIC can access altitude 

readings via computer or smart phone using the on-board telemetry transmitter of the sUAS; 

altitude readings are taken primarily using an on-board barometer (pressure sensor). 

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane 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-

(1) During the day, to fly after that for at least 30 minutes. 

*** 

(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. 
Operating the sUAS in a pre-defined area with less than 30 minutes of reserve fuel does 

not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the 

event it has to be flown to an alternate airport or circle the planned airport in the event of 

unanticipated conditions. SEESPAN does not intend to use the sUAS for point-to-point flights 

and will not operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport 

in order to land. Rather, SEESPAN will operate the sUAS using pre-planned flight paths (taking 

into account weather conditions) designed to allow the sUAS to fly to the point of intended 

landing. As such, there is no need for a time-based excess fuel requirement. Rather it should be 

sufficient to require only as much additional excess flight capacity as necessary to safely land the 

sUAS. We believe that a 20% fuel reserve is more than sufficient to meet this objective. 

14 C.F.R. 91.405(a), 91.407(a) (I), 14 C.F.R. 91.409(a), and 14 C.F.R. 91.417(a) and (b)5 

§91.405 Maintenance required. 

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; 

***** 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration. 

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

rebuilding, or alteration unless -

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

§43. 7 of this chapter; 

***** 

§91.409 Inspections. 

(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. 

***** 

91.417 Maintenance records. 

(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 

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)(l) 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. 

(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. 

SEESP AN believes that an exemption from these four maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow an 

operator to meet the part 91 maintenance requirements. In particular, there are no individuals 

authorized by the FAA to approve an sU AS for return to service under §91.407 (a) or to conduct 

the initial airworthiness and annual return to service inspections required by §91.409(a). 

SEESPAN will maintain the aircraft as instructed in the owner's manual of the sUAS and related 

manuals of operation provided by the manufacturer of the electric winch attached to the 

SEESPAN Tethered sUAS Flight Control System base, and will not operate the aircraft or the 

SEESPAN base until it has reasonably determined that any needed repairs have been made. 

However, because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a), 409(a), and 417(a) and (b), we believe an exemption from these provisions is appropriate. 
Please do not hesitate to contact me at the phone number or via the e-mail address 

provided above should you have any questions or concerns. 

Respectfully submitted, 

~~ SEESP~c. 

cc: Encl. 

Appendix A: Summary of Request (confidential treatment has been requested for appendices BG) 
Appendix A 

Summary for Federal Register Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register should the FAA determine that publication is needed. 

Petitioner: SEESPAN, Inc. (SEESPAN) 

Sections of 14 C.F.R. Affected: 

14 C.F.R. §61.23(a) and (c) 

14 C.F.R. §61.101(e)(4) and (5) 

14 C.F.R. §61.113(a) 

14 C.F.R. §61.315(a) 

14 C.F.R. §91.7(a) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.15l(a)(l) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a)(l) 

14 C.F.R. §91.409(a) 

14 C.F.R. §91.417(a) and (b) 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 

§§61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 9l.119(c), 91.121, 

91.151(a)(1),, 91.405(a), 91.407(a)(l), 91.409(a), and 91.417(a) and (b) to conduct sUAS 

operations within a space controlled SEESPAN during daylight hours. In general, sUAS 

operations are intended to be conducted in areas remote from airports and heliports. The nature 

of operations anticipated by SEESPAN requires that the sUAS be flown at relatively low 

altitudes. SEESPAN expects that in most instances, the sUAS will be flown less than .200 feet in 

altitude and in no instances will be flown higher than 400 feet above the ground. Accordingly, 

the risk of interference with other aircraft is minimal. Further, risk to the public is minimal and 

reduced significantly versus current aerial photography methods.