ATTN: U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E. West Building Ground Floor, RoomW12-140

Washington, DC 20590

Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal

Aviation Regulations

December 29, 2015

Petitioner:

Sean M. Cook

6305 SW Well Rd.

Bentonville, AR 72712

P: (479) 531-7221

E: s83cook@gmail.com

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Sean Cook, operator of an Unmanned 

Aircraft System (UAS), hereby apply for an exemption from the listed Federal Aviation Regulations (“FARs”) to 

allow commercial operation of my UAS, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.

I currently hold a certificate for commercial operations for rotorcraft with instrument rating as well as private SEL 

for airplane. I have a combined total flight time of just over 1,200 hours and am intimately familiar with Federal 

Aviation Regulations (“FARs”) as well as safe practices and operation of aircraft. I have also registered under the 

new registration requirements for recreational purposes until my request for exemption is granted. Aircraft is 

currently properly marked with new registration number. 

1. Sections from which exemptions are sought: 

a. 14 CFR Part 21 (Subpart H)

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFR Part 91:

i. 91.7 (a)

ii. 91.9 (b) (2)

iii. 91.103(b)(2)

iv. 91.105

v. 91.109

vi. 91.119

vii. 91.1

viii. 91.151

ix. 91.203 (a) &

(b) x. 91.205 (b)

xi. 91.215

xii. 91.401-417
I believe an exemption is only needed from the above-listed regulatory provisions. To the extent thatthe FAA

believes that additional relief is required for me to conduct the operations described within, I request an

exemption from any such regulatory provisions aswell.

2. Relief sought:

a. I wish to operate small Unmanned Aircraft Systems (UAS) for commercial purposes to include:

i. Aerial Land Surveying & Mapping

ii. Construction Monitoring

iii. Agricultural Surveying

iv. Real Estate Photography

v. Forest and Land Management

vi. Product Demonstrations

b. This exemption will cover use of the following airframe, which will weigh less than 55 pounds

including payload and energy sources:

i. DJI Phantom 3 Professional (see www.dji.com/product/phantom-3)

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by use of

manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure

inspections) and due to other dangerous activities that can be avoided (e.g.,

scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of time obtaining such information, which benefits consumers and

the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from

manned aircraft.

4. Operations:

a. Operations will be limited to the following aircraft described in the operating documents, which is a 

quad-­­rotor aircraft weighing approximately 3 pounds: Phantom 3 Professional Unmanned Aircraft 

System.

b. The UA will not be flown at an indicated airspeed exceeding 50 knots.

c. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL)

d. The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times.

e. When needed I will utilize a visual observer (VO). The UA will be operated within the visual line of 

sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The 

PIC will be designated before the flight and will not transfer his or her designation for the duration of the 

flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

f. The operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. Any revisions to the operating documents will be presented to the 

Administrator upon request.

g. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated 

until the necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The Ground Control Station will be included in the preflight inspection. 

h. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics,

e.g. replacement of a flight critical component, will undergo a functional test flight.

i. I will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

j. The UAS operated will comply with all manufacturer Safety Bulletins.

k. The UA will not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-­­published aeronautical chart without first contacting the control tower or approach.

l. The UA will 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.
m. If a UA loses communications or loses its GPS signal, it will return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating documents.

n. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents.

o. The PIC will not begin 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 UA with 15% 

battery power remaining.

p. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

q. Required registration will be available at all times by PIC and will be presented whenever requested 

by an Administrator or local law enforcement officer. 

r. The UA will remain clear and yield the right of way to all manned aviation operations and activities 

at all times.

s. The UAS will not be operated by the PIC from any moving device or vehicle.

t. The UA will not be operated over congested or densely populated areas.

u. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless:

i. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. We will 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 and/or;

ii. 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

iii. made a safety assessment of the risk of operating closer to those objects and determined 

that it does not present an undue hazard, and;

iv. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

v. All operations will 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.

w. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office 

(AFS-­­80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) 

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

Thank you for your time and consideration.

Respectfully,

Sean M. Cook