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