### U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE 

### Washington,D.C. 20590 John F. Sesockdba Sesock Aerial Service 366 BradshawBlvd. Perry,Florida32348 RE: Exemption Request Section 333 of

### the FAAReform Act oftheFederalAviation Regulations from 

### 14 CFR 91.7(a);91.119 (c); 91.121 ; 91.151 (a)(1); 91.405(a); 91.407(a)(l); 91.409(a)(1)and (2); 91.417(a)&(b) The petition is submitted byJohn F. Sesock, DBA, Sesock Aerial Service, who will hereafter be referred to as the "petitioner". The majority ofthis request for exemption will be based on prior Exemption No. 11138 issued to Mr. Douglas Trudeau, Realtor, issued by the Federal Aviation Administration on January 6, 2015, Regulatory Docket No. FAA-2014-0481. My request for exemption will utilize the same make and model of UAS. I plan to perform the same type of operations, with certain additions to be specified, as requested in Exemption No. 11138. It is the request ofthe petitioner for exemptions listed above in orderto legally and safely operate the DJI Phantom 3Advanced, Yuneec Q500, Walkera Scout X4 UAS in the National Airspace System, forthe purpose of Unmanned Aerial Photography and Videography forthe real estate, construction, agriculture and utilities industries for commercial gain and enhancement of Public awareness of UAS operation, and finally enhanced safety for both the General Public and Flight Crews.

It is the petitioners position that the operations for which exemption is requested are safer and more cost effective than using manned aircraft, and for those reasons are in the Public Interest; and would be of benefit in identifying areas ofoperation that may need additional oversight as well as raising public awareness and interest in this rapidly growingfacet ofaviation

. (Reference Exemption No. 11138) The petitionerwill outline in this document: 1. Request for exemptions by Part and Subpart 2. Petitioners protocols and procedures for operations 3. Request for relieffrom Airport Proximity limitation 4. The Unmanned Aircraft System (UAS) 5. The Public Interest



# 1. REQUESTS FOR EXEMPTION BY PART AND SUBPART14CFR 91.7(A) Prohibits the operation ofan aircraft without an airworthiness certificate. Petitioner requests exemption based on previous Exemption No. 11138. The FAA has ruled that this make and model ofaircraft (UAS) does not require an airworthiness certificate

. 14CFR 91.119(C) States that no person may operate an aircraft below the following altitudes:

### overotherthan congestedareas, an altitude of400feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feetto any person, vessel, vehicle, or structure. The UAS utilized forthis exemption is ofexceptionally light weight and is not capable ofspeeds over 30 knots. The UAS is equipped with GPS guided auto pilot with a return home function in case loss ofcontrol by the PIC and is powered by sealed batteries thereby reducing the chance of post impactfire to nearly zero. There will be cases when the 500 footto property will need to be exempted. (Example: Aerial Video ofa 2 story home roofto determine and/ordocument extent of storm damage.) In this type ofoperation every assurance will be made to keep persons outside ofa reasonable, safe, clear area of operations and will only be conducted with the express permission ofthe property owner. See protocols and procedures section. The petitioner will implement procedures and policies to ensure that any person in the general vicinity ofoperations will be aware ofsuch operations and ensure that all non-essential personnel are cleared ofthe area ofoperations. See Protocols and procedures Section 3. The petitionertherefore requests relief in partfrom 14CFR 91.119(C) 14CFR 91.121 Altimeter Settings

. The petitioner requests relief from 91.121 forthe following reason. The UAS is equipped with GPS derived altitude capability, however due tothe limited altitude requested in this exemption, the FAA has previously granted Exemption forthese types ofoperations. Reference Exemption No.11138 14 CFR 91.151(a) No person may begin aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) unless there is enough fuel to flytothe first point of intended landing and, assuming normal cruise speeds (a)(l)Duringthe day to fly for at least 30 minutes

.The petitioner requests relieffrom 91.151(a) due to the fact thatthe UAS is equipped with a battery and percentage indicator system

.The UAS has a flight capability on full charge of approximately 

### 20to 

### 25 minutes depending on camera usage and othervariables. The petitioner has established thatthe maximum flight will be 10 minutes on afully charged battery. This constitutes landing with approximately 

### 50 percentfuel remaining. The petitioner believes that this follows the spirit and intent ofthe rule with agreat margin ofsafety. No UAS operations will be conducted at night, as defined by Federal Aviation Regulations. 14 CFR 91.405(a) Maintenance required; The petitioner requests relief in part from 91.405(a)(1) based on the Protocols and Procedures Section on Maintenance and Maintenance Records. Also reference Exemption No. 11138 14 CFR 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration; The petitioner requests relieffrom 91.407(a)(1) based on the Protocols and Procedures Section on Maintenance, Return to service after maintenance, and Maintenance records. Reference Exemption No. 11138 14 CFR 91.409(a)(1)(2) Inspections; The petitioner requests relief from 91.409(a)(1)(2) based on the Protocols and Procedures Section on Inspections. Reference Exemption No. 11138 14CFR 91.417(a)(b) Maintenance records; The petitioner requests relieffrom 91.417(a)(b) based on the Protocols and Procedures Section on Maintenance records.


# 2. Protocols and Procedures for UAS operations.

A. Preflight B. Area Security C. Limitations of Operations D. Airworthiness E. Maintenance and Records F. Pilot in Command Requirements G. Visual Observer and Requirementsinspections, overhauls, or replacement of life limited components. A record ofeach preflight inspection will additionally be recorded in these logbooks. The preflight inspection must be conducted by the PIC forthat operation. Preflight signoff shall include at least the following information: date ofoperation, AircraftTotal time, aircraft serial or operating number, PIC signature and certificate number

. 

### Example: Preflight inspection completed, No defects noted. 1-1-15, ACFTI 50

.1 hours, UAS number 1, John F. Sesock. 

### (2). Any required maintenance, inspection, alteration or repair must be completed by an approved person .Atthe completion ofthis work the approved person must make an entry in the aircraft log book that at least includes: Date, Aircraft serial or operating number, brief description ofthe discrepancy, inspection, alteration or repair, the reference material used as guidance forthe repair, statement approving the aircraft for return to service, and signature of person who completed the work

. Example: 1-1-15 UAS 1, ACFTI 50.1 hours, replaced number 3 rotor with new rotor, lAW DJI Phantom 3 Advanced + User Manual. Flight or ops check completed

.Aircraft is approved for return to service. John F. Sesock (3). Maintenance records shall be kept with the UAS at all times and shall be made available to any authorized agency orthe Administrator upon request. 

### F. Pilot in Command Requirements (1). The Pilot in Command shall have at least 5 hours in make and model before performing any operation for which exemption has been requested. (2).The Pilot in Command shall preform a pre-flight inspection before each flight is conducted. (3).The Pilot in Command shall observe all Federal Aviation Regulations at all times with the exceptions ofthe exemptions requested by the operator. In those cases the Pilot in Command shall adhere to company operating standards or Federal Aviation Administration Limitations placed upon exemptions, whichever is more stringent. (4). The Pilot in Command may operate the UAS without a Visual Observer present depending on the specific mission provided VLOS is mantained. (5). The Pilot in Command must have 3 takeoff and landings within the preceding 90 days. (6). The Pilot in Command must maintain a record offlight information to establish currency and that he or she meets the requirements ofthis section . 

### G. Visual Observers: Responsibilities and Requirements (1)

. A Visual Observer may be used during any and all operations ofthe UAS System. (2)

.The Visual Observer shall maintain communication with the PIC at all times during UAS operation. (3). The Visual Observer shall maintain Visual Contact with the UAS at all times

. In the event that Visual Contact is lostthe VO will notify the PIC who will immediately cease operations and land the aircraft. (4). The Visual Observer shall also help the PIC maintain area of operations security and ensure that all nonessential persons remain clear ofthe area ofoperations. In the eventofa breach by unauthorized person(s) the VO shall notifythe PIC and operations will cease immediately

.(10) PIC must inspect and ensure that UAS and ground control station is in airworthy condition priorto each operation; ifdetermined un-airworthy, all operations will be suspended until such time as necessary maintenance has been performed and UAS is determined to be in a safe condition forflight

. (11) An operational flight test is required after any maintenance or alterations that may affect UAS operation orflight. (12) UAS maintenance must follow Manufactures aircraft/component, maintenance, overhaul, and replacement, inspection, and life limit requirements. (13) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance and inspection, and alterations must be noted in the aircraft records, including total flight hours, description ofwork performed, and the signature ofthe authorized person returning UAS to service. (14) UAS must comply with all Manufacturers' Safety Bulletins. (15) An authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. (16) Prior to operations PIC must have accumulated and logged a minimum of5 hours as a UAS pilot in make and model listed in exemption. PIC must log at a minimum 3 takeoffs and landings in the preceding 90 days to meet currency requirements. (17) PIC is required to operate the UAS with appropriate distances in accordance with 14 CFR 91.119. (18) No operations are allowed in the surface areas ofClass B, C, and D airspace. (19) No operations are allowed ifthe return home function and\or autopilot are, or are suspected to be malfunctioning

. (20) No operations shall be conducted without an appropriate Certificate ofAuthority issued by the Administrator. (21) A Visual Observer can be utilized when operatingthe UAS. (22) Should the PIC or Visual Observer detect that a manned aircraft is being operated in close proximityto the operations area, the UAS shall give right ofway to the manned aircraft, and the PIC shall cease operations and land until such time as the manned aircraft has cleared the area. (23) The UAS will not be operated any close to'any structure withoutthe express permission of the structure owner. 

### D. UAS Airworthiness (1). The PIC shall ensure that the UAS is in an airworthy condition before each flight. Airworthiness shall be determined by a preflight inspection in accordance with DJI operating documents and any and all applicable Federal Aviation Regulations, and any additional requirements as defined by the Administrator. PIC shall document each preflight inspection by date, Aircraft total Flight time to date, any discrepancies noted, and signature and certificate number. Any discrepancy noted shall be addressed before UAS operation

. 

### E. UAS Maintenance and Records (1). The operator shall maintain aircraft maintenance logbooks. Each UAS shall have its own and separate maintenance log book. DJI documents, handbooks, user manuals, supplements, Safety Bulletins, etc., shall be the only approved documents for performing repairs, maintenance,H. Reporting of Incidents and Accidents 

### A. Preflight Inspection of UAS (1). Preflight of Unmanned Aerial System will followthe instructions on in the DJI instruction and User Manual. The Pilot in Command will certifythat a preflight inspection has been accomplished with the date and time and signature in UAS logbook. The preflight shall include the aircraft, transmitter, and batteries, motors, rotors, landing gear, and camera and gimbal mount. As a part ofthe preflight the Pilot in Command will assure that weather conditions, batteries, area security, and any other information essential to safe operation has been obtained. 

### B. Area Security (1). The PIC ofthe UAS will ensure thatthe operational area for the purposes of UAS flight shall be cleared ofall nonessential persons at all times the UAS is in flight. Additionally all nonessential persons shall be required to remain clear ofthe operations area by a minimum distance of 150 feet during operations. PIC shall ensure that clearly marked signs are posted at all ingress\egress points to the operations areas. These signs will be ofwhite background with red lettering stating the following: "Unmanned aircraft operations underway. Please remain clear ofthis area during operations." 

### (2). In the event ofa breach of nonessential persons into the operations area duringflight of UAS, the PIC shall immediatelyterminate flight operations until such time as the area can be cleared ofsuch persons. 

### (3). The UAS area ofoperation is defined as the Horizontal flight path(s) ofthe UAS as well as the Vertical flight path and Maximum altitude to be reached. Additionallythe area between the UAS's current position and its Home location is also considered operational area as itwill proceed directto its home location in the eventual of loss ofground control. All nonessential persons will not be allowed within 150feet ofany part ofthe operational area duringflight operations. 

### C. Limitations of Operations (1) The UAS shall be operated in Day time only, as defined by 14 CFR (2) UAS night operations are prohibited. (3) The UAS shall be operated by VLOS at all times (4) When aVisual Observer is utilized they must maintain VLOS. (5) The UAS shall remain within lOOOft horizontal distance ofthe PIC. (6) The UAS to be utilized is the DJI Phantom 3 Advanced, Yuneec QSOO, and Walkera Scout X4 Unmanned Aircraft System. (7) The UAS will have an altitude restriction of400 feet. (8) The UAS will not be operated at a speed exceeding 30 Knots

. (9) Operations Documents will be accessible to the PIC at all times and must be accessible during UAS operations and made available tothe Administrator upon request.

### (5)

.The Visual Observer shall also assist the PIC in looking for manned aircraft traffic near the operations area. If manned aircrafttraffic is observed near the operations area, the VO will notifythe PIC who will immediately cease operations and land the UAS. 

### H. Reporting of Incidents and/orAccidents Any incident or accident, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA will be reported within 24 hours to: FAA UAS Integration Office (AFS-80) Accidents: National Transportation Safety Board www.ntsb.gov. 

# 4. The Unmanned Aircraft System UAS
The petitioner will operate the DJI Phantom 3 Advanced Yuneec QSOO 4K and Walkera Scout X4 

### + UAS System. The Petitioner will make available to the Administratorthe operating and user documents forthe DJI Phantom 3 Advanced, Yuneec QSOO 4K and Walkera Scout X4 

### systems upon request. 

# 5. The Public Interest
The request forthis exemption is in the Public Interest as it is safe to assume thatthere are many consumer applications for the services that can be provided by UAS systems. It is clear that the Congress ofthe United States, the business sector, and the consumer want to integrate Unmanned Aircraft Systems intothe National Airspace System and utilize their unique and cost effective capabilities

. It is also in the Public Interestthat many ofthe low level flight operations now conducted by manned aircraft could be accomplished with these light, fire resistant unmanned aircraftthat can operate at afraction ofthe cost to both the operator and consumer. These aircraft can be operated without risk of loss of life or limb, without significant financial impacttothe operator or any person or property on the ground in the event ofthe loss ofan aircraft. Finally the petitioner believes that granting this exemption would help to further Public Interest by the Administrators process of integration of UAS systems and possibility help to create additional regulations and guidance to be used as these systems become more widely utilized. Please forward any questions or concerns to the address or email below

. Sincerely, John F . Sesock, DBA, Sesock Aerial Service 

### 366 Bradshaw Blvd. Perry, Fl. 32348 johnfsesock@yahoo

.com . (\

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