June 28, 2015

Julian R Noel

9536 Heatherdale Dr.

Dallas, TX 75243

214-502-5889

Dear Exemption Manager, Re: Docket Number FAA-2007-0001

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

currently hold an FAA, ATP certificate and have over 20,000 hours of accident free flight time.

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

Toys.

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

have many times in the past been entrusted with the possession of highly confidential 

information working on various projects with military and commercial customers.

I reference the FAA announcement dated April 23, 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, 

my experience as a pilot license holder (even though The FAA is lowering the credential bar to 

include sport pilot certificates), and my attitude of safety first when it comes to flight 

operations, I believe I should be granted an exemption.
1.

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. 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 improved/unimproved parcel of land, for ultimate 

disposition and sale” or “other promotional purposes (ie. a country club wanting to promote its 

facilities)”. Any complaint by a neighboring member of the public complaining of even a hint of 

invasion of privacy, founded in fact or not, and even within the private boundaries of the 

specific land parcel owner, 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.

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

However, 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” 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 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 3, and will be qualified as a UAS.

2.

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. 

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,

Julian R Noel