James C SENGUL

1 Randolph Terrace

Fair Lawn, NJ 07410

May 18, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

Washington, DC 20590

RE:​Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(1)(2); 91.417(a)(b); 91.119(c)

ATTACHMENTS:

Dji F550 Flame Wheel user Manual V.1.9

Dear Sir or Madam:

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform

Act"), AMA member and Professional Photographer James C SENGUL (the "applicant"),

operator of an DJI F550 Unmanned Aircraft Systems ("UAS") seeks an exemption from the

Federal Aviation Regulations ("FARs") to allow for

1.​Aerial photography and/or video for public and/or private use including real estate,

architecture,land surveying, engineering and other related professional activities.

2.​Aerial video and/or photography for public and/or private use including television, public

events,cinematography and news gathering.

3​. Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

4.​Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation

In order to operate small unmanned aircraft systems (UAS) commercially in airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial
photography, cinematography, videography, mapping, crop surveying, inspections and

other flight operations that could be performed safely and more cost effectively with the

use of small UAS at low altitude within the U.S. national airspace system as compared

to a manned aircraft. Operations will be performed only at the request of and with the

authorization and permission of clients or their authorized agents in order to facilitate

commerce and raise awareness of the beneficial uses of small unmanned air systems.

So long as such operations are conducted within and under the conditions outlined

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

PUBLIC INTEREST

My ultra lightweight UAS is battery powered and creates no emissions that can harm the

environment. The consequence of our ultra lightweight UAS crashing is far less than a

full size helicopter or fixed wing aircraft; which are heavy, contain a pilot, many

gallons of combustible fuel and can cause catastrophic devastation to the public. The Smart

Battery employed in UAS provides immediate visual awareness and percent battery

charge remaining as well as similar information during flight through Ground Control

Station.The public’s interest is further supported by minimizing the potential for ecological

damage and crash threats by permitting aerial video/photo capture through my

battery operated ultra lightweight UAS's. Permitting james C SENGUL to immediately

fly within national air space furthers economic growth. Granting my exemption request

substantially furthers the economic impact for the New York, New Jersey and Connecticut area

for companies and families looking to relocate or build in the areas as well as Not­forProfit / Search and Rescue / Fire Fighting needing enhanced local awareness, all of which

serve to strengthen and stimulate the community

APPLICANT CONTACT INFORMATION

The name, address, and additional contact information for the applicant is:

James C. SENGUL

1 Randolph Terrace

Fair Lawn, NJ 07410

Phone # 201­923­5710

Email: csengul@gmail.com

www.jamescsengul.com
Regulations from which the exemption is requested:

14 C.F.R. 61.113(a)&(b); 91.7(a); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1)(2);

91.417(a)(b); 91.119(c)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section

333(a) through (c) of the Reform Act.

This law directs the Secretary of Transportation to consider whether certain unmanned aircraft

systems may operate safely in the national airspace system (NAS) before completion of the

rulemaking required under Section 332 of the Reform Act. In making this determination, the

Secretary is required to determine which types of UAS do not create a hazard to users of the

NAS or the public or pose a threat to national security in light of the following:

The UAS size, weight, speed, and operational capability;

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

Operation of the UAS within visual line of sight of the operator.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part

11, I, James C SENGUL, a professional photographer with 20 + experience. Preparing this

exemption request myself, would like to apply for an exemption from the following Code of

Federal Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned

Aircraft Systems (UAS) for aerial imaging and video of Tri State Area ( New York, New Jersey,

Connecticut )

I have own a hobby grade DJI F550 hexacopter. (maximum gross weight 10 pounds, equipped

with six rotors that are driven by electric motors powered by batteries, the UAS has a maximum

airspeed of 30 knots) manned only with a Sony A6000 camera for the intent of aerial

photography/videography and videos; following an exemption and approval by the FAA. I have

flown hobby grade quadcopter for last 3 years without any accident or crash.

My exemption request would permit operation of ultra­lightweight, unmanned (piloted by remote

control) in predetermined areas away from general public, airports, heliports and vehicular

traffic, daylight hours only, under 300 ft. and after carefully reviewing, inspecting and examining

the area of aerial observation.

I will abide all FAA requirements to ensure this exemption will provide a level of safety at least

equal to existing rules and will only operate in a safe environment that is strictly controlled, area

way from power lines, elevated lights, airports and actively populated areas; and I will conduct

extensive preflight inspections and protocols, during which safety carries primary importance
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203

Given the size, weight, speed, and limited operating area associated with the aircraft to be

utilized, I am asking exemption from 14. CFR part21,Subpart H(Airworthiness

Certificates)and§91.203 (a) and (b) (Certifications required),subject to certain conditions and

limitations, is warranted and meets

the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L.

112­95 (Section 333).

14 C.F.R. 45.27(a): Location of marks; non fixed­wing aircraft. 14 C.F.R. 45.29 (3)

(c)(d)(e)(f)(h):

Size of Marks

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally

two­inch lettering is difficult to place on such a small aircraft with dimensions smaller than the

minimal lettering requirement. I understand the need for markings and will mark my UAS in the

largest possible lettering by placing the word “Experimental” or assigned number or name

(based on a request or ruling by the FAA ) on its fuselage as required by §45.29(f) so that anyone

assisting him as a spotter will see the markings.

I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b)

Maintenance inspections may be required and should be granted since they only apply to aircraft

with an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection

of my UAS before each flight as outlined in this operating documents.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command​.

Under §61.113 (a) and(b) private pilots are limited to non­commercial operations, however I can

achieve an equivalent level of safety as achieved by current regulations because my UAS does

not carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control

piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the

commercial activities outlined in 14 CFR part 61,et seq., I requests an exemption

from §61.113 Private Pilot Privileges and Limitations.
14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

If granted an exemption I agree to additional safety procedures including, but not limited to:

1) ​Keeping my UAS within a radius distance of 1000 feet from the controller to both aid in direct

line of sight visual observation.

2)​Operate the UAS for 3­7 minutes per flight; land my UAS according to the manufacturer’s

recommended minimum level of battery power.

3)​Operate my UAS only within visual line of sight (VLOS).Daylight hours only.

4) ​Use the UAS’s global positioning system (GPS) flight safety feature; it hovers and then

slowly lands if communication with the remote control.

5)​Conduct all operations under my own personal and flight safety protocols (including posting a

warning sign reading: “Attention Aerial Photography in Progress–Remain Back 150 feet”).

6)​I will operate and will actively analyze flight data and other sources of information to

constantly update and enhance my safety protocols.

7)​Contact respective airports if operations will be within 5 miles to advise them of his estimated

flight time, flight duration, elevation of flight and other pertinent information.

8)​Always obtain all necessary permissions prior to operation.

9) ​Have procedures in place to abort flights in the event of safety breaches or potential danger.

14 C.F.R. 91.119­ Minimum safe altitudes: General

James C SENGUL seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe

altitudes. As this exemption is for a sUAS that is a helicopter and the exemption requests

authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform

from which filming is planned, an exemption may be needed to allow such operations.

As set forth herein, except for the limited conditions stated in the Manual, the UAS will never

operate at higher than 400 AGL. It will however be operated in a restricted area with security

perimeter, where buildings and people will not be exposed to operations without their

pre­obtained consent. The equivalent level of safety will be achieved given the size, weight,

speed of the UAS as well as the location where it is operated. No flight will be taken without

the permission of the property owner or local officials. Because of the advance notice to

the property owner and participants in the filming activity, all affected individuals will

be aware of the planned flight operations as set forth in the Manual. Compared to flight

operations with aircraft or motorcraft weighting far more than the maximum 55lbs. proposed

herein and the lack of flammable fuel, any risk associated with these operations is far less

than those presently presented with conventional aircraft operating at or below 500 AGL

in the movie industry. In addition,the low­altitude operations of the sUAS will ensure separation

between these small­ UAS operations and the operations of conventional aircraft that must

comply with Section 91.119
Aerial videography for geographical awareness of real estate marketing has been around for a

long time through manned fixed winged aircraft and helicopters, but for small business owners,

its expense has been cost­prohibitive. Granting this exemption would allow me to provide this

service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to

the public given its small size and lack of combustible fuel when compared to larger manned

aircraft

Therefore, James C SENGUL respectfully requests the FAA grant an exemption

pursuant to its application as outlined above.

Sincerely

James C SENGUL

Professional Photographer

Thank you for your consideration