October 14, 2015

Stacey Chance

Discovery Bay Studios

1854 Seal Way

Discovery Bay, CA 94505

captainchance@gmail.com

Cell 925-216-4454

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,

In reference to Docket No. FAA-2015-2744 dated June 24, 2015.

I am submitting the requested additional information regarding why granting Discovery Bay Studios the 

Exemption for Unmanned Aircraft Systems operations would be in the public interest and how it would 

benefit the public as a whole.

The Reasons Why Discovery Bay Studios Request Would Be In The Public Interest; That Is, How It 

Would Benefit The Public As A Whole.

Granting the present petition will further the public interest by allowing Discovery Bay Studios to safely, 

efficiently, and economically perform aerial video and photography of real estate, events, civic 

landscape, architectural, and construction sites over local areas of the United States. Additionally, use of 

the DJI Phantom UAS will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Normally these functions would require larger manned aircraft. Notably, the 

benefits of Discovery Bay Studios proposed operation of the DJI Phantom UAS will be realized without 

implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom UAS are battery 

powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally 

utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in 

the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The DJI Phantom UAS do not require 

an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom UAS.

Conducting aerial acquisitions with the DJI Phantom UAS, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the DJI 

Phantom UAS produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel.

The DJI Phantom UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise 

pollution, as the UAS are propelled by battery powered electric motors, rather than an internal 

combustion engine. By using the DJI Phantom UAS to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated.

Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom UAS (weighing 

less than 3 pounds at their maximum gross weight, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds, and a

fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom UAS Will Benefit The 

Economy.

In addition to being safe and efficient, the DJI Phantom UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom UAS will 

allow United States based companies, like Discovery Bay Studios, to remain competitive and contribute

to growth of the U.S. economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt 

new and alternative technology in order to remain competitive. Operating the battery powered DJI 

Phantom UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft.

By operating the DJI Phantom UAS, companies such as Discovery Bay Studios, can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Phantom UAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States and abroad.

Sincerely, 

Stacey Chance

Discovery Bay Studios