September	2,	2015

To:

U.S.	Department	of	Transportation,	Docket	Operations

West	Building	Ground	Floor,	Room	Wl2-140

1200	New	Jersey	Avenue,	SE

Washington,	DC	20590

From:

William	Westover

808	E	Christopher	St.

San	Tan	Valley,	AZ	85140

480-200-3323

chad@chadwestover.com

Petitioning	for	Exemption	Under	Section	333.	FAA	authorization	to	operate	a	UAS	

for	civil	(non-governmental)	purposes	other	than	for	recreation	or	hobby.	This	is	

the	new	FAA	streamlined	UAS	for	commercial	operation	at	or	below	200	feet.

I	seek	relief	of	operation	of	a	UAS	for	commercial	photography	and	videography.

It	will	benefit	the	public	by	flying	at	a	lower	altitude	and	by	providing	unique	views	

in	video	and	photographs.

Safety	will	not	adversely	be	affected	since	the	FAA	created	safety	guidelines	that	will	

be	followed.

The	rule	is:

PUBLIC	LAW	112-95--FEB.	14,	2012	126	STAT.	77

SEC	336.	SPECIAL	RULE	FOR	MODEL	AIRCRAFT.

(I)	the	aircraft	is	flown	strictly	for	hobby	or	recreational	use;	

The	exemption	requested	is	to	operate	a	UAS	for	commercial	purposes	at	or	below	

200	feet.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	

"Reform	Act")	and	14	C.P.R.	Part	11,	William	Westover,	an	individual,	seeks	

exemption	from	requirements	of	14	C.F.R.	§	21,	Subpart	H;	14	C.F.R.	§	43.11;	14	

C.F.R.	§	91.103;	14	C.F.R.	§	91.105;	14	C.F.R.	§	91.109;	14	C.F.R.	§	91.119;	14	C.F.R.	§	

91.121;	14	C.F.R.	§	91.151(a);	14	C.P.R.§	91.405(a)	and	(d);	14	C.P.R.§	91.407(a)(l);	

14	C.F.R.	§	91.409(a)(2);	14	C.P.R.	§	417(a)	and	(b) to	operate	an	unmanned	aerial	

vehicle	(UAV)	in	support	of	commercial	aerial	photography	and	videography	of	

individual	commercial,	public,	and	residential	properties	and	structures	with	

owners/operators	permission	and	appropriate	authorization.	In	addition,	William	

Westover	seeks	to	operate	said	UAV	for	the	purposes	of	aerial	photography	and	
filmmaking,	construction	site	inspection	and	monitoring,	event	

photography/videography,	and	for	the	general-purpose	photography	and	

videography	suitable	for	commercial	usage	as	needed.	

The	request	for	this	exemption	is	in	the	Public	Interest	as	there	are	many	consumer	

applications	for	the	services	that	can	be	provided	by	UAV	that	are	currently	

conducted	by	manned	aircraft.	Usage	of	a	UAV	for	many	of	these	applications	

creates	an	environmentally	friendly,	lower	cost	solution	to	both	the	operator	and	

consumer.	These	aircraft	can	be	operated	safely,	and	without	significant	financial	

impact	to	the	operator	or	any	person	or	property	on	the	ground	in	the	event	of	the	

loss	of	an	aircraft.	Utilizing	these	UAV	will	create	a	safe	and	more	productive	work	

environment,	reduce	environmental	pollution	and	have	a	positive	impact	on	the	

local	economy,	which	is	in	the	Public	Interest.

William	Westover	respectfully	requests	that	the	FAA	grant	the	following	

exemptions:	

14	C.P.R.§	21,	Subpart	H;	14	C.P.R.§	43.11;	14	C.P.R.§	91.103;14	C.P.R.§	91.105;

14	C.P.R.§	91.109;	14	C.P.R.§	91.119;	14	C.P.R.§	91.121;	14	C.P.R.§	91.151(a);

14	C.P.R.§	91.215;	14	C.F.R.	§	91.405(a)	and	(d);	14	C.F.R.	§	91.407(a)(1);

14	C.F.R.	§	91.409(a)(2);	14	C.F.R.	§	417(a)	and	(b).

14	C.P.R.	21,	Subpart	H:	Airworthiness	Certificate

William	Westover	requests	an	exemption	from	14	C.P.R.	21,	Subpart	i-L	This	

Subpart	establishes	the	procedures	for	the	issuance	of	an	airworthiness	certificate.	

William	Westover	requests	an	exemption	from	Part	21,	Subpart	H	because	the	UAV	

is	under	50	pounds	(including	payload)	and	meets	an	equivalent	level	of	safety	

pursuant	to	Section	333	of	the	Reform	Act	due	to	its	small	size,	light	weight,	and	

restricted	operating	environment.

14	C.F	.R	43.11:	Records	for	Inspections

William	Westover	requests	an	exemption	from	14	C.P.R.	43.11.	This	part	provides	

that	maintenance	record	entries	be	maintained,	that	the	inspector	list	discrepancies,	

and	to	affix	placards	to	the	aircraft.	Due	to	its	small	size	the	UAV	proposed	for	use,	

does	not	have	room	for	placards	to	be	placed	in	or	on	it	and	no	inspections	for	UA	V	

have	been	certified	by	FAA	at	the	present	time.	However,	as	a	condition	to	the	grant	

of	the exemption,	William	Westover	will	perform	the	inspections	and	time	

replaceable	items	recommended	by	the	manufacturer	and	keep	records	and	log	

books	of	all	maintenance	and	repairs.

14	C.F	.R	91.103:	Preflight	Action

William	Westover	requests	an	exemption	from	14	C.F	.R.	91.103.	This	regulation	

requires	each	pilot	to	take	certain	actions	before	flight	to	insure	the	safety	of	flight.	

As	FAA	approved	flight	manuals	will	not	be	provided	for	the	UAV,	an	exemption	is	

needed.	William	Westover	will	follow	the	manufactures	preflight	inspection.

14	C.F.R	91.105:	Flight	Crewmembers	at	Stations
William	Westover	requests	an	exemption	from	14	C.F	.R.	91.105.	William	Westover	

requests	an	exemption	from	14	C.P.R.	91.105	since	this	part	is	not	applicable	due	to	

the	UAV	carrying	no	flight	crewmembers.	An	equivalent	level	of	safety	will	be	

maintained	by	ensuring	the	pilot	does	not	change	inflight.

SUMMARY	THAT	CAN	BE	PUBLISHED	IN	THE	FEDERAL	REGISTER

Department	of	Transportation

Federal	Aviation	Administration

Petitioner:	William	Westover

Petition	of	exemption	from	sections	of;

14	CFR	61.113,

14	CFR	91.7,	91.119,	91.121,	91.151

14	CFR	91	Subpart	E	(91.405,	91.407,	91.409,	91.417)

Description	of	relief	sought;

William	Westover seeks	an	exemption	for	commercial	operation	of	an	unmanned	

aerial	vehicle	that	is	less	than	50	pounds	including	payload.

The	unmanned	aircraft	vehicle	has	an	onboard	camera	system	capable	of	acquiring	

high-resolution	data.

Proposed	operations	will	include real	estate	aerial	photography	and	videography,	

aerial surveying	services	for	other	commercial	industries such	as	construction	and	

development,	event	photography	and	videography,	and	the	creation	of	promotional	

and	advertising	images	as	needed	for	commercial	purposes.	

This	Petition	for	Exemption	is	similar	in	nature	to	exemptions	granted	to	Desiree	

Ekstein	of	OnTheGoVideo.biz	(Docket	#	FAA-2015-1190-0001)	and	Stephen	

Warriner	(Docket	#	FAA−2015−0978).