June 26, 2015

Exemption No. 11923 Regulatory Docket No. FAA

– 20 15

– 1283

Mr. Paul Seiden 85 North Buesching Road Apartment 421 Lake Zurich , IL 60047

Dear Mr. Seiden :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter posted to the public docket on April 28 , 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption . The petitioner requested to operate an unmanned
ai rcraft system (UAS) to conduct aerial videography, photography , and inspection

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and
the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition
in the Federal R egister because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA
finds that relief from 14 CFR part 21

, C ertification procedures for products and parts,2

Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you pre sent; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Paul Seiden is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Paul Seiden is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by
instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this gran t of exemption are limited to the DJI Phantom 2 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude mus t be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued a irman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transf er his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions a nd limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists betwe en the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its o perating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The4

o perator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then
th e operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or altera tions that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conduct ed by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepa ncies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and
aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rate d on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emerge ncy maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with
14 CFR § 61.51(b). Flights for the purposes of training the operato r’s PICs and VOs5

(traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. Ho wever, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate th e UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the cen ter of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the a irport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may 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 mil es from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies

.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended CO A if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative.
P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) wi th jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator f or the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involve d in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation

.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on June 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

Enclosures

## U.S.	Department	of	Transportation,	Docket	Operations	West Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the Federal	Aviation	Regulations	from	14	C.F.R.	61.113(a)&(b); 91.7(a);	91.9(b)	(2);	91.109;119.121;	91.151(a);	91.405(a); 91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)
Dear	Sir	or	Madam: I,	Paul	Seiden,	am	writing	pursuant	to	the	FAA	Modernization	and
Reform	A ct	of	2012	and	the	procedures	contained	within	14	C.F.R. 11,	to	request	that	I,	Paul	Seiden,	an	owner	and	operator	of	small unmanned	aircraft,	be	exempted	from	the	Federal	Aviation Regulations	(“FARs”)	listed	below	so	that	I,	Paul	Seiden,	may
operate	a	sma ll	ultra	light	weight	unmanned	aircraft	system (“UAS”)	commercially	in	airspace	regulated	by	the	Federal Aviation	Administration	(“FAA”)	located	in Illinois (specifically	in Chicago	and	surrounding	suburbs	as	well	as Cook,Lake,Ka ne,Dupage	and	McHennry	Counties )	in	accordance with	FAA	UAS	Regulation s	&	Policies. This	exemption	request	is	made	based	on	information	outlined	in this	petition,	as	well	as	the	accompanying	DJI	Phantom2
Operators	Manual 1 

## and	Personal	Protocols	and	Controls 2 .	The	DJI Phantom2	UAS	was	selected	because	it	has	a	proven	capabili ty	for	controlled	flight	as well	as	a	gyro	stabilized	flight	mode,	GPS	aided	navigation,	a	compass,	blinking	LED’s	on the	bottom,	a	failsafe	mode	for	returning	home,	and	prop	guards.	These	devices	are offered	for	general	sale	around	the	world	and	have	ofte n	been	used	as	Model	Aircraft	in the	USA.	In	addition,	I,	Paul	Seiden,	have	flown	UAS’s	in	a	recreational	capacity	since 1978	and	have	adopted	safety	protocols	and	controls	to	avoid	and	prevent	public hazard,	as	well	as	manned	aircraft	hazards/catastrophe. This	will	act	to	further	safety protocols	exclusive	to	lightweight	UAS's	specific	to	video	and	photography	usage	as	I, Paul	Seiden,	record	flight	data	and	other	information	gained	through	permitted	flight operations	to	share	with	the	FAA	through	any	requi red	FAA	reports	to	assist	with	future protocol	and	safety	regulation.	I	am	also	a member	of	the Academy of Model Aeronautics
member number 417838

## I.	Contact	Information
Paul	Seiden 85	N	Buesching	Road	apt	421 Lake	Zurich,IL	60047
Mobile	(630)417

- 3891 emai l pcseiden1@gmail.com 

## II.	Information	regarding	the	Phantom	2 UAS Specifically,	the	UAS	is: An	ultra	lightweight	battery	operated	4

- motor	rotorcraft	in	the form	of	a	quadcopter	that	takes	off	and	lands	ver tically, manufactured	by	DJI,	Model	Phantom	2,	with	the	following equipment:

• An	on

- board	flight	computer	with	GPS	navigation	and	location ability	that	receives	signals	for	flight	controls	from	a	ground

based	transmitter/controller;

• An	integrated	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	A GL,	horizontal	and	vertical	speed, compass	direction	of	flight	and	direction	back	to	its	launch site;

• A	600mW,	5.8GHz	on

- board	radio	transmitter	that	transmits	live
video	from	the	on

- board	camera	plus	all	the	flight	data	from the	telemetry	system	descr ibed	above; The	Ground	Station
Includes:

• A	Pilot	in	Command	(PIC)	in	operational	control	of	a	flight operation	from	beginning	to	end	and	who	controls	the	UAS while	in	the	air;

• A	100mW,	2.4GHz	radio	transmitter/controller	operated	by	the PIC	to	control	the	UAS	while	in	flight;

• 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;

## • A	Visual	Observer	(VO)	is	a	person	who	provides	a	second	pair	of eyes	to	visually	track	the	UAS	while	in	flight. III.	Proposed Operations I,	Paul	Seiden,	intend	to	use	UASs	in	two	areas. First,	I	seek	an	exemption	to	perform	video	film ing	and photographing	by	air	for	public	and	private	use.	Second,	I will	employ	UAS’s	to	inspect	land,	residential	commercial and	industrial	structures	and	property. Specifically,	I	will	use	UASs	which	are	equipped	with	cameras	and sensors,	in	order	to	eng age	in	the	following	commercial	activities in	Chicago	and	surrounding	suburbs	as	well	as Cook,Lake,Kane,Dupage	and	McHennry	Counties: (a)	Video	filming	by	air	and	photographing	for	public	and	private purposes,	including:	television,	cinematography,	adverti sing	or promotions.	Filming	and	Photography	will	only	be	conducted	with permission	and	under	contract	with	registered	owners	or	with	any local	government	authority	and	only	when	safe	to	do	so. (b)	Video	filming	by	air	and	photographing	to	support	professio nal operations	in	engineering,	land	surveying	and	development, architecture,	real	estate	and	other	related	professional	activities. Filming	and	Photography	will	only	be	conducted	with	permission and	under	contract	with	registered	owners	or	with	any	local

g overnment	authority	and	only	when	safe	to	do	so. (c) Inspection	by	air	of	infrastructure	such	as	bridges,	highways, photovoltaic	power	stations,	and	pipelines.	These	inspections	will only	be	done	under	contract	and	permission	with	any	registered owners	or	with	any	local	government	authority	and	only	when
saf e	to	do	so. (d)	Inspection	by	air	of	land	and	residential,	commercial	and industrial	structures,	only	under	contract	and	permission	with	any registered	owners	or	with	any	local	government	authority	and only	when	safe	to	do	so. (e)	Support	provided	to	searc h	and	rescue	operations	and reconnaissance	in	cases	of	need,	emergency	or	natural	disasters

## only	when	government	authorities	have	requested	it	by	contract or	donation	and	only	when	safe	to	do	so. IV.	Relevant	Statutory	Authority This	Petition	for	Exemption is	submitted	pursuant	to	Section 333(a)	through	(c)	of	the	FAA	Modernization	and	Reform	Act	of 2012	("Reform	Act").	Congress	has	directed	the	FAA	"to	safely accelerate	the	integration	of	civil	unmanned	aircraft	systems	into the	national	airspace	system." Pursuant	to	Section	333	of	the Reform	Act,	the	FAA	Administrator	is	to	permit	unmanned	aircraft systems	to	operate	in	the	National	Air	Space	("NAS")	where	it	is safe	to	do	so	based	on	the	following	considerations:

• The	UAS’s	size,	weight,	speed	and	opera tional	capability;

• Operation	of	the	UAS	in	close	proximity	to	airports	and populated	areas;	and

• Operation	of	the	UAS	within	the	visual	line	of	sight	of	the
operator. Additionally,	the	FAA	Administrator	has	general authority	to	grant	exemptions	fro m	the	agency's	safety regulations	and	minimum	standards	when	the	Administrator decides	a	requested	exemption	is	in	the	public	interest.	See 49	U.S.C.	§	106(f)	(defining	the authority	of	the Administrator);	49	U.S.C.	§	44701(f)	(permitting	exemptions from§§ 44701(a),	(b)	and§§	44702

- 44716,et	seq.).	A	party requesting	an	exemption	must	explain	the	reasons	why	the exemption:	(1)	would	benefit	the	public	as	a	whole,	and	(2) would	not	adversely	affect	safety	(or	how	it	would	provide	a level	of	safety	at	least	eq ual	to	the	existing	rules).	See	14 C.F.R.	§	11.81	(petitions	for	exemption). V.	These	Proposed	UAS	Operations	Meet	the	Requirements	of
Section	333	of	the	Reform	Act The	proposed	operations	in	this	Petition	for	Exemption	qualify	for expedited	approval	pursu ant	to	Section	333	of	the	Reform	Act	as each	of	the	statutory	criteria	and	relevant	factors	are	satisfied. VI.	Approval	is	Warranted	Based	on	the	UAS	Size,	Weight,	Speed,

## and	Operational	Capability I,	Paul	Seiden,	will	employ	the	DJI	Phantom	2	quadcopter	f or	the operations	specified	in	this	Petition	for	exemption.

• The	Phantom	2 UASs	have	a	maximum	take

- off	weight	of	less than	5	pounds

• Flight	speed	will	not	exceed	25	miles	per	hour,	and	it	will	not	be flown	in	controlled	airspace	or	at	an	altitude	th at	exceeds
400	feet	AGL.

• All	flights	will	be	flown	in	such	a	manner	that	they	can	be	safely terminated	with	a	reserve	battery	power	of	no	less	than	20% of	the	battery's	maximum	charge.

• The	DJI	Phantom	2	UAS	does	not	carry	any	flammable	propellant

o r	fuel.

• The	Phantom	2	UAS	has	an	integrated	GPS	system	that

calculates	the UAS’s	position	and	height	and	relays	that
information	via	a	secure	connection	to the	operator.

• The	Phantom	2 UAS	contain	a	failsafe	mode	if	its	connection	to

the remote	control	is	lost,	and	this	system	permits	the	UAS

to	return	to	a predetermined	location	and	land	without injury	or	damage.

• For	additional	safety,	the	Phantom	2 will	be	retrofitted	with prop	guards. VII.	Approval	is	Warranted	Based	on	the Opera tional	Restrictions	Set	Forth	in	the	Operations

Manual. DJI's	operators	manual 3 

## and	the	Personal	Protocols

and	Controls 4 

## contain	all	of	the	procedures	and	limitations necessary	to	successfully	perform	the	operations	specified	in this	Petition	for	Exemptio n.

VIII.	Public	Interest The	public	interest	will	be	served	by	granting	Paul	Seiden	a Petition	for	Exemption	in	Chicago,	suburbs
and Cook,Lake,Kane,Dupage	and	McHennry Counties.	Congress

## has	established	a	national	policy	that	favors	early	integration of UASs	into	the	NAS	in	controlled,	safe	working	environments	such as	those	proposed	in	this	Petition.	In	addition,	the	public	also	has an	interest	in	reducing	the	hazards	associated	with	alternate methods	of	conducting	similar	operations.	Currently	operat ions are	conducted	using	teams	that	physically	climb	onto	structures using	ladders,	using	low	flying	helicopters	or	aircraft,	are extremely	cost	prohibitive	or	are	simply	not	available	by traditional	means.	By	using	UAS,	exposure	to	physical	hazards	will
b e	reduced	by	conducting	the	operation	while	remaining	safely	on the	ground. Additionally,	the	intended	uses	of	the	Phantom	2 UAS	as	outlined in	this	document	have	identifiable	safety	benefits	that	include reducing	the	danger	and	emissions	associated	with full	size helicopters.	UAS	have	no	fuel	to	ignite	or	explode,	no	crew,	add	a greater	degree	of	flexibility,	supplement	the	current	capabilities offered	by	manned	aircraft,	and	public	interest	for	a	ground impact	of	a	small	lightweight	UAS	is	further	minimi zed	from	an ecological	and	safety	standpoint. IX.	A	Summary	The	FAA	May	Publish	in	the	Federal	Register: A.	14	C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	The	Like.

14	C.F .R.	91.7(a)	I,	Paul	Seiden,	will	ensure	the	UAS	is	in	airworthy condition	based	on	compliance	with	the	Phantom	2	operating documents	prior	to	each	flight. 14	C.F.R.	§	91.121	Relief	is	requested	considering	the	limited altitude	of	proposed	operations.

B.	14 C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC. Pursuant	to	14	C.F.R.	§	61.113	(a),	The	FAA	has	previously declared	that	additional	manned	airship	experience	of	a commercially	certified	pilot	would	not	correlate	to	the	airmanship
skills	ne cessary	for	similarly	proposed	operations	in	previously issued	exemptions	to	this	regulation	through	Exemption	Nos.
11062	and	11138.

## Pursuant	to	14	C.F.R.	§	61.113	(b),	The	stick	and	rudder	controls	of the	typical	aircraft	one	would	be	trained	on	to	achiev e	a	private pilots	license	are	completely	different	than	that	of	a	small	UAS. Additionally,	the	FAA	does	not	require	manned	ultralight	vehicle PICs	to	meet	any	aeronautical	knowledge,	age,	or	experience requirements	or	to	have	airman	or	medical	certificate s	(as outlined in	14	C.F.R.	§	103).	Ultralight	vehicles	can	weigh	more	than	500	pounds	than	the Phantom	2,	can	carry	up	to	5	gallons	of	combustible	fuel,	and	fly	at	speeds	close	to double	that	capable	by	the	Phantom	2.	Due	to	these	facts,	I,	Paul	Seiden	re spectfully request	that	an	333 exception	be	granted	and	PIC	license	requirement	be	waived 

## D.	14	C.F.R.	91.119	(c):	Minimum	Safe	Altitudes. 14	C.F.R.	§	91.119	(c)	I,	Paul	Seiden,	will	ensure	that	all	persons and	objects	not	essential	to	flight	operations	mu st	remain	500 feet	away	from	operations.	In	addition	to	visual	monitoring	of	the
area,	a	traffic	cone	and	warning	sign 6 

## alerting	persons	in	the	area will	be	placed	at	the	operation	ground	station.	To	protect	objects and	personnel	essential	to	flight	operat ions	the	Phantom	2	will	be fitted	with	propeller	guards	to	minimize	potential	hazards. E.	14	C.F.R.	91.151	(c):	Fuel	Requirements	for	Flight	in	VFR
Conditions. 14	C.F.R.	91.151	(c),	I,	Paul	Seiden,	will	ensure	that	each	individual flight	will	not	begin	unl ess	there	is	enough	power	to	fly	to	the	first point	of	intended	landing	and	land	the	UA	with	30%	battery power	remaining.	In	addition,	each	individual	flight	will	last	no longer	than	20	minutes,	5	minutes	less	than	the	manufacturer
stated	25	minutes	of	fli ght	time. F.	14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b): Maintenance	Inspections.
The	above

- cited	Regulations	require,	amongst	other	things, aircraft	owners	and	operators	to	“have	[the]	aircraft	i nspected	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.	.	.	.”

## These	Regulations	only	apply	to	aircr aft	with	an	airworthiness certificate.	They	will	not,	therefore,	apply	to	my,	Paul	Seiden’s, UAS.	However,	as	a	safety	precaution	I	inspect	my	UAS	per operating	documents	before	and	after	each	flight.

X.	Conclusion This	Petition	for	Exemption	satisfies	th e	criteria	articulated	in

Section 333	of	the	Reform	Act	of	2012	including	weight,	speed, operating	capabilities,	proximity	to	airports	and	populated	areas, operation	within	visual	line	of	sight	and	national	security. Additionally,	the	Petition	provides	mor e	than	adequate justification	for	the	grant	of	the	requested	exemptions	to	permit Paul	Seiden	to	operate	a	Phantom	Vision	UAS	in Chicago,	suburbs
and Cook,Lake,Kane,Dupage	and	McHennry Counties for	the operations	specified	herein. Granting	the	exemption	w ill	benefit	the	public	interest	as	a	whole in	several	ways,	including	(1)	significantly	improving	safety	and reducing	risk	by	alleviating	human	exposure	to	danger,	and	(2) improving	the	quality	of	services	and	decreasing	operating	costs compared	with	conve ntional	flight	operations.

Very	Respectfully,

Paul	Seiden