February 22, 2016 

David Wittkamp 

490 Fortress Blvd Apt 2E 

Murfreesboro, Tn 37128 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

Re: FAA EXEMPTION 333 REQEUST 

Dear Exemption Manager, 

I am submitting this Petition for Exemption for Unmanned Aircraft Systems (UAS) operations. 

I have operated a UAS for several years and take great care in every flight I make. UAS are 

not “toy helicopters”. It is delicate hobby that I wish to use in the residential, commercial, 

and industrial industries to help others as well. 

This request is for a waiver of the sections identified below, in an effort to operate a UAS in 

the public. Extreme privacy will be taken to others during the use in public, and it will not be 

used to harm others. I will adhere to keeping operations safe, and not to harm the 

environment. 

I have a clear understanding of the FAA rules and regulations currently in place for UAS 

operations and will keep up on future rules as they are set in place. 

My intentions for this exemption is for use in the real estate market, construction market, 

and commercial marketing sectors. I have no intentions or desires for use for motion pictures 

and/or television filming. Any notice, from others, of concerns of privacy invasion will result 

in termination of operations, and discussions with all parties to rectify the situation. 

I am currently seeking exemption of: Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 

45.27(a), 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.319(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) 

and (b). 

Suggested Public Federal Register Summary: 

The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under 

the new FAA “Summary Grant” approach, announced April 9th, 2015 http://www.faa.gov/

news/updates/?newsId=82485 that will help speed up Section 333 exemption approvals for 

many commercial UAS operators prior to finalizing the small UAS proposed rules published this 

past February. 
It is my understanding that the FAA will still review each Section 333 petition individually. 

However, I am requesting that the agency will accept my particular petition, and include it in 

the next summary grant, and issue me an exemption on the presumption that the FAA has 

“already granted a previous exemption similar to this request”. 

Apparently, the new interim policy includes the granting of a Certificate of Waiver or 

Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 

exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight 

Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay 

certain distances away from airports or heliports such as 5 nautical miles (NM) from an airport 

having an operational control tower; or 3 NM from an airport with a published instrument 

flight procedure, but not an operational tower; or 2 NM from an airport without a published 

instrument flight procedure or an operational tower; or 2 NM from a heliport with a published 

instrument flight procedure. It is also understood that the “blanket” 200- foot COA allows 

flights anywhere in the country except restricted airspace and other areas, such as major 

cities, where the FAA prohibits UAS operations. 

UAS Operation: 

I am asking for an exemption for a UAS up to 55 pounds because I forecast I will be using a 

craft that will be flown operationally, weighing less than ten pounds and more specifically a 

Typhoon Q500+, and will be qualified as a UAS. 

In the event a loss of communications occurs the craft will rise up vertically to a safe height 

before beginning an automatic return to home function. The control signal may be 

reconnected in flight and the pilot can take over safe operations again if communication is 

reestablished. However in the case of a GPS failure the craft will be able to be manually 

flown to a safe landing by the pilot. The craft operates electrically, carries no flammable 

fuel, has an integrated GPS pilot system, provides location information along with height AGL, 

speed, battery life, has programmed no-fly zones for controlled airports, and provides 

direction of travel distance from the pilot. 

Additional Points:

It is my hope that you find that the enhanced safety achieved using an unmanned aircraft 

with the specifications described by the petitioner which carries 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. 

Flight Operations: 

I am well aware of conducting safe flight operations and planning flight paths that minimize 

any overflight of crowds. Flights will end when battery reserve reaches 25 percent. 

Operations will not occur under IFR conditions. In addition, preflight and post-flight checklists 

and UAS examinations will help detect any abnormalities prior to flight and after flight. Any 

UAS unable to satisfy safety checklists will be removed from service until the issue can be 

resolved. 

Speeds of flight will be kept at a slow pace as well, since main intent will be photographing 

and video recording. 

Granting this request would not adversely affect safety since operations would be in 

accordance with current UAS rules. 

Section 333 Compliance and Appropriateness: 
Based on the size of the craft, experience of the pilot, and operational goals, this request 

appears to be well suited for approval using the current criteria outlined in Section 333 of the 

FAA Modernization and Reform Act of 2012 (including new interim policies) 

I, David Wittkamp, will be the sole operator of this UAS, and am directly responsible for the 

proposed operations and maintenance, unless maintenance is required by others, which would 

be directly with authorized manufacturer. 

Sincerely, 

David Wittkamp