ProCarPhotography

CEO Jeffrey W New

2212 Jonathan Creek DR.

Little Elm TEXAS 75068 

TEXAS DRIVERS LICENCE NUMBER 20864005

FAA Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE 

West Building, Ground Floor, Room W12-140 Washington, DC 20590 

Dear Exemption Manager

I am submitting my Petition for Exemption for Unmanned Aircraft Systems operations. I take the skills 

and education for the safe operation of UAS, very seriously. These UAS are not Toys and I take the 

operation of my UAV very seriously . 

My request is for a waiver of the sections identified below in an effort to operate a UAS in public. I 

recognize the importance of extreme privacy as I have been in situations where I have had to adhere to 

an environment and culture, that is based on such privacy. . 

I reference the FAA announcement dated April 9th, 2015 

http://www.faa.gov/news/updates/?newsId=82485 which includes language that references the 

FAA’s experience in reviewing Section 333 petitions and that they seem to be generally falling into two 

categories ie: film/television production and aerial data collection, and that most of the exemption 

requests in these categories will likely be handled through the new summary grant process. 

With my clear understanding of FAA rules, my awareness of operational and restricted airspace, and my 

attitude of safety first when it comes to flight operations, I believe I should be granted an exemption. 

My request for a waiver of the section is not for operations for the purpose of “closed-set motion 

picture and television filming” but are identified below. 

My request is to operate a UAS for commercial purposes. Flights would only be on privately owned land 

parcels with the express permission of the property owner. Specifically, to “record digital video data and 

other aerial photography data of privately owned fee simple real estate which will assist an owner in the 

promotion of their inventory for sale. And to benefit the public by showcasing vehicles of an 

automobile dealer, thereby helping people to save gas ,time and help with traffic congestion. Any 

complaint by a neighboring member of the public, who gives even a hint of invasion of privacy, 

founded in fact or not, and with the camera lens facing inward and focused only onto an owners 

parcel, will instantly be honored, resulting in immediate termination of aerial operations. 

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). If I have erroneously 

omitted any other relevant section or, overstated any relevant section for my intended operations, 

please feel free to suggest the missing or overstated section(s). 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. 

I am hoping 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” 200foot COA allows 

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

the FAA prohibits UAS operations. 

UAS Description: 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 DJI 

Phantom Vision + , or DJI Phantom 3, and will be qualified as a UAS. At no time will my flights use POV 

or FPV systems flights will be LOS only .

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. there will not at any time be any flights over 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. 

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)

Sincerely, 

Jeffrey W. New

214-707-1156

2212 Jonathan Creek DR.

Little Elm TEXAS 75068

geojef@hotmail.com