FAA Section 333 Petition Request June 25, 2015

Shawn Sherman

EarthView Aerial Photography LLC

1413 Samantha Creek Dr.

Little Elm, TX 75068

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, Re: Docket Number FAA-2015-0150

I am submitting my Petition for Exemption for Unmanned Aircraft Systems (UAS) operations on behalf 

of my newly established (non-operating until approval) EarthView Aerial Photography LLC. I am currently 

an FAA student private pilot, and am extremely well-versed in flight operations and safety. 

My request is to operate a UAS for commercial purposes. This primarily involves real estate 

development, planning and marketing, as well as property inspections and construction progress 

tracking. Search and rescue operations will also be provided, but performed as a community service.

Following specific privacy laws in Texas, any images of adjoining properties or individuals will be 

immediately deleted upon request from said individual or property owner. Safety is always of primary 

concern while adhering to any and all privacy laws and restrictions.

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 (i.e., 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.

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).

I am aware that the FAA has already granted previous exemptions similar to this request, and it is my 

hope that the FAA grants an exception to EarthView Aerial Photography for the safe operation and 

commercial use of aerial photography to provide a unique and commercially viable service to my clients. 
FAA Section 333 Petition Request June 25, 2015

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 Description:

I am asking for an exemption for a UAS up to 55 pounds. The primary UAS is a DJI Phantom 3 with 

smaller UAS used for specific purposes (high ceiling, internal shots of homes). All current UAS in 

operation are under 12 lbs. Outdoor units are all equipped with GPS (confirmed via onscreen map), and 

Return-to-Home functions, which automatically return the craft to a pre-defined location and a predefined altitude. This feature can be activated either manually or when a signal is lost. In addition, all 

outdoor UAS have an Auto-Land feature which enables the craft to safely land upon a low-battery 

emergency. 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.

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 30 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. 

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,

Shawn Sherman