September 16, 2015

Exemption No. 12882

Regulatory Docket No. FAA−2015−2285

Mr. D. Logan Seale Jr. 

220 Kenoza Avenue

Haverhill, MA 01830

Dear Mr. Seale:

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 June 16, 2015, you petitioned the Federal Aviation 

Administration (FAA) for an exemption. You requested to operate an unmanned aircraft 

system (UAS) to conduct residential and commercial aerial photography and videography.

See Appendix A for the petition submitted to the FAA describing 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 Register 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 3D Robotics Iris+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public 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 the requested relief from 
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14 CFR part 21, Certification procedures for products and parts, 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 collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 Labs, 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 proportions, 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 present; 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. D. Logan Seale Jr. 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. D. Logan Seale Jr. 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 (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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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 grant of exemption are limited to the 3D Robotics Iris+

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 must 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 airman 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer 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 and 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 between 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 operating 

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. The 
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operator 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 

the operator must petition for an amendment to its grant of exemption. The FAA’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 alterations 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 conducted 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 discrepancies, 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 Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated 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 emergency 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 operator’s PICs and VOs 
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(training, 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. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the 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 center of the airport symbol 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 airport 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 miles from the PIC.

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

pre-determined location within the private 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 conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA 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.
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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 and 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, vehicles, 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 protection. 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 trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission 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 FAA'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.
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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) with jurisdiction over the area 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 for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the 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 involved 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.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Docket Operations, M-30

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Room W12-140, West Ground Floor

Washington, DC 20590-0001

Subject: Petition for Exception

I, D. Logan Seale Jr., of 220 Kenoza Ave. in Haverhill, MA 01830 hereby petition the FAA for an 

exemption from various sections of 49 USC of Federal Aviation Regulations. I am associated with 

Logan Seale Photography/Interactive of 220 Kenoza Ave, Haverhill, MA, and will be the Pilot in 

command of any aerial photography, following approval of this request.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95, I

request certain exemptions in order to conduct residential and commercial aerial photography

(henceforth meaning still and/or video) using a small Unmanned Aircraft System- the 3D Robotics 

Iris+

Sincerely,

D. Logan Seale Jr.

220 Kenoza Ave

Haverhill, MA 01830

Logan@LSPhoto.com
Overview:

I D. Logan Seale Jr. 220 Kenoza Ave. in Haverhill, MA hereby petition the FAA for an exemption 

from various sections of 49 USC of Federal Aviation Regulations. I am associated with Logan Seale 

Interactive/Photo, 220 Kenoza Ave. Haverhill, MA, and will be the Pilot in Command of any aerial 

photography, following approval of this request.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95, I

request certain exemptions in order to conduct residential and commercial aerial photography

(henceforth meaning still and/or video) using a small Unmanned Aircraft System, The 3D Robotics 

Iris+. The aircraft consists of four electric motors with rotors, powered by a Lithium battery and

managed by an on board flight control system that is remotely accessed by the Pilot in Command

using a portable control unit.

The remote control unit is a wireless communication device using the 915MHz frequency band.

Real-time viewing of the on board camera is enabled through a video link within the

5.8GHz frequency band. Both frequencies are approved by the FCC for limited-range

communication purposes.

The Iris+ (known as 'Iris+' for this request) has a maximum payload of less

than 2 pounds including the camera (.9 pounds and has a maximum

forward speed of 30 knots (-I would fly from 0-15

knots) and is managed by a sophisticated GPS control system that assures a Return To Land

(RTL) procedure in the event of Loss of Signal (LOS). That same system can set maximum height

and distance so the UA does not exceed preferred parameters. The manufacturer, 3D Robotics, 

regularly updates software and firmware. The Iris+ is equipped with a Geo fence that restricts its 

movements to an altitude of 100 meters and a distance from the operator of 1000 meters

I D. Logan Seale, will use the UAS in daytime only to enhance real estate marketing for Realtors

in the greater New England area and coastal North Carolina area showing views of

properties currently unattainable by still or aviation.

I will operate the quad-copter is a safe manner, using the following pre-flight check list and

operating procedures to determine that the aircraft is physically and electronically ready for

safe flight and that permission from the property owner/representative is received:

Pre-flight Checklist:

• If required, notify the appropriate FAA facility of our launch schedule and location.

• Survey the property for hazards- trees, utility poles and other elements that might

compromise the flight, then make a judgment as to whether to proceed.

• Check the weather for wind speed, cloud cover and any forecast changes that might

adversely affect flight safety and performance.

• Examine the aircraft- looking at connections and searching for cracks and loose parts.

• Determine that the electronic elements are performing correctly (receiving more than 8

GPS signals along with calibration of the magnetic compass)

• Determine that the barometric altimeter reflects approximately 0 feet AGL.

• Following takeoff, I will hover at an altitude of approximately 10 feet to assure that the

Home Point is solid.

• I will then exercise all controls to confirm their functionality- if one of the controls is

not functioning, the flight will be terminated immediately.

• I will fly only with a Visual Observer (VO) at my side who will double check for possible

flight hazards. The VO will provide a second pair of eyes to assist the PIC in keeping the

craft within Visual Line of Sight (VLOS). He will also assist in any emergency

maneuvers due to unanticipated events that require a quick landing. 

• I will not fly over dense traffic or crowds.

• I will give right-of-way to any manned aircraft.
• I will stay clear of FAA controlled airspace at airports (generally a five nautical mile

radius) as well as restricted and prohibited zones.

• I will fly no higher than 300' and no further than 1000' from the Home Point, recognizing

that the primary responsibility is to safely keep the aircraft safely within VLOS.

• I will stay clear of clouds and fog (500' vertically and 2,000' horizontally).

• I will perform a post-flight check of the Iris+ to determine its physical and electronic

condition.

Operating Procedures:

• After receiving permission from the property owner or representative, I will notify

abutting property owners of our intensions and anticipated time on site.

• I will not fly over neighboring properties unless permission is granted.

• I will keep individuals not involved in the flight at a safe distance (500 feet if

practical).

• I will post a sign stating: Take Notice"Aerial Photography Under Way- Stay Clear

Altitude, distance from the PIC, airspeed and battery state-of-charge are data constantly

viewable in the control monitor which is the Iris+ equivalent of an

aircraft's control panel. I maintain that the above checklist and procedures will minimize risks to

property and persons on the ground as well as other aircraft in the National Air Space.

At this writing, I have practiced extensively in the Iris +

accumulating 10:50 hrs of flight time with the craft. I continue to add flying hours to my Iris+ log. I 

have exercised all functions in the aircraft and fly only when weather conditions allow.

I have private pilot license #229946924 issued in April 29, 2004. I will reacquire my 3rct class 

medical certificate. I am fully aware of VFR flight rules. The serial number of my Iris + is 22172214

and I will mark the aircraft with whatever 'N' number the FAA requires.

Exemption Requests:

I respectfully request exemption from the following regulations with which I cannot fully

comply.

14CFR

Part 21 Airworthiness Certification

Subpart H "prescribes the procedural requirements for issuing and changing design

approval, production approval, airworthiness certificates and airworthiness approval."

(Summation from Exemption No. 11138, page 11)

Response: "The Secretary of Transportation has determined that this aircraft meets the

conditions of Section 333. Therefore, the FAA finds that the requested relief from 14

CFR part 21, and any associated noise certification and testing requirements of part 36,

is not necessary." (Summation from Exemption No. 11138, page 11

Part 61 (a)(b) Parts, General Operating and Flight Rules

(a) Prescribes the requirements for issuing pilot licenses and the privileges and

limitations associated with various ratings.

(b) Aeronautical experience means pilot time, flight simulator or flight training device

for meeting the appropriate training and flight time requirements for an airman

certificate.

Response: Organized or commercially available FAA-approved flight training has yet to

be achieved by the UA industry. While I have regularly used a flight simulator on my

computer, those skills are generally not transferable to quad-copter operation. My

sources of training are: the Flight Instruction Manual from 3DR, online

videos from the manufacturer as well as videos from users; and most importantly,

personal training in a secure location- an open area not subject to traffic and/or

uninvolved individuals. Those training flights, which have averaged 10-15 minutes each,

deal with setup, physical and electronic safety checks; lift off followed by hovering at
approximately 10 feet to confirm that the GPS system is functioning properly and has

registered its Home Point; a prescribed flight plan to familiarize and then master the

fight controls and camera; returning to the launch point and landing, either on a plastic

pad or having my VO secure the Iris+ by hand. I then conduct a post-flight

inspection for any problems, log the location and flight time and then view the video.

There are no FAA certified instructors or FAA certified study guides available at this time

as the technology continues to develop. I respectfully request an exemption from this

rule.

§91.103 (b)(2)

(b)(2) This section deals the pilot's preparations for flight, in particular runway lengths,

takeoff and landing distance information.

Response: Since a quad-copter, like a helicopter, takes off and lands vertically, an

Iris+ pilot would not need to know this information since there are no runways

involved and the return from flight is the takeoff point. The FAA has determined that

"relief is not necessary." (Summation from Exemption No. 11138, page 20)

§ 91.105

Summary: This section deals with flight crewmembers at stations.

Response: Since there are no passengers, pilots or crewmembers, I respectfully request

relief from this regulation.

§ 91.109

Summary: This sections deals with flight instruction, simulated instrument flight and

certain flight tests.

Response: None of these functions are applicable to a quad-copter flight and, as stated

earlier, there are no FAA certified instructors or FAA certified study guides available at

this time for quad-copter operation. I respectfully request an exemption from this rule.

§ 91.119 (a) (b) (c)

Summary: This section deals with minimum safe altitude stating that if the power fails

anywhere, an aircraft should have an altitude sufficient so that an emergency landing

can occur without hazard to persons or property (91.119 a). It also sets minimum

altitudes over congested areas and uncongested areas as well as has a paragraph on

helicopters (91.119 b). It also sets minimum distance (500 feet) from any person, vessel,

vehicle, or structure (91.119 c). Iris+ returns to its Home Point around the 20% battery level. 

I respectfully request an exemption from this rule.

§ 91.405

Summary: This section deals with aircraft maintenance including regular inspection, the

keeping of appropriate maintenance records and replacement of inoperable

instruments

Response: Maintenance on the Iris+ is quite straight forward. If, in landing, a rotor

blade is damaged, it is quickly replaced. The traditional instrument cluster

in an aircraft is replaced by a data stream from the Iris+, visible in the remote control

monitor. Replacement of minor parts are performed by the PIC and a

major 'overhaul' that can't be easily resolved will go back to the manufacturer for

repair. Currently, there are no required inspections by 'authorized' maintenance

personnel and there would be no space/room on board to install a placard of

inoperability. I respectfully request an exemption from this rule.

§ 91.407

Summary/Response: This section addresses requirements after maintenance has been

performed. Again, approval of the maintenance before flight is essentially in the hands

of the PIC. Whatever maintenance is performed will be entered in the aircraft log, unless

a separate maintenance log is required. Paragraph (b) refers to the prohibition of a pilot

carrying passengers or crewmembers, if the flight characteristics have been substantially

affected, before a rated pilot performs an operational check of the maintenance. Again,
this is a PIC's responsibility to preflight the Iris+ and determine its flyability. And, as

mentioned earlier, there is no pilot, crewmembers or passengers on board the

Iris+. I respectfully request an exemption from this rule.

§ 91.409

Inspections: This section deals with the necessity of annual and 100-hour inspections or

"progressive inspections" and approval by authorized persons which will lead to the

"issuance of an airworthiness certificate."

Response: As stated earlier, there is no FAA approved inspection protocols nor

authorized inspection personnel. The PIC handles those issues each time the Iris+ is

prepared for flight. The pre-flight check list enumerated earlier will be followed to

determine its mechanical and electronic integrity. I respectfully request an exemption

from this rule.

§ 91.417

Maintenance Records: This section requires a maintenance record be kept on repair,

replacement and condition of vital parts (rotors, engines & airframe). Certain records

must be retained for one year while other record must be kept with the aircraft even

when sold to another part.

Response: The details of this section would be impractical with an Iris+, but repair

issues can be entered into the aircraft log. I respectfully request an exemption from this

rule.

The above requests for exemptions follow the guidance published by the FAA.

The Iris+is a UAS with multiple safety features to assure a safe and efficient

flight, minimizing personal injury and property damage and integrating with minimal risk into

the NAS. They include:

• A GPS flight system that allows for stable remote control of the aircraft.

• The ability to hover in place by simply taking hands off the controls.

• A Return to Land function if electronic contact between the Remote Control and the

aircraft is lost. If the aircraft begins to show unstable flight, I will land it immediately.

• The ability to limit height (<300') and distance (<1000') from the PIC through the control

software.

• Readout of the battery's state of charge so that there is sufficient power to bring the UA

home.

• The weight, size, speed and limited flight which focuses on inanimate objects (homes)

reduces the likelihood of significant personal or property damage. Flight of the UA risks

no on board lives, as in helicopter or plane photography. The safety features associated

with the Iris+ as well as my pre-flight checklist and procedures will assure that

public safety is not adversely affected .

Public Service:

In my business I have several non-profit organizations and I intend to help them with fund raising by 

providing aerial video to augment their videos and to provide aerial photos as a fund raising effort for 

our local school. If approved, these activities would be

donated for the benefit of the community.

Airports and Prohibited Area:

Since I intend to conduct flights primarily in the greater Boston area, there are several airports that 

require additional precautions. They are 

• Boston (BOS)- FAA control tower Class B airspace with well known upside down wedding cake 

airspace.

• Lawrence Municipal (LWM) Class D Airspace

• Norwood Municipal Also Class D
• Hanscom Field Class D

In North Carolina there is:

• Cape Hatteras National Seashore and MOA

I respectfully request exemptions from the above listed regulations in order to conduct aerial

photography of residential and commercial properties in order to assist realtors and developers

in their marketing efforts. In addition, my commitment to public education and safety will focus on 

local charities and schools

Signed,

D. Logan Seale Jr.

Pertinent Links

Iris Plus User Manual on Line 

http://3drobotics.com/wp-content/uploads/2014/10/IRIS-Plus-Operation-Manual-vC-web.pdf

Manufacturer Video Explanation of GPS Systems

https://youtu.be/sj96PqV1mN0

Manufacturer Video Explanation of Iris + GPS based Flight Modes

https://youtu.be/n2JtSQ7vDGA