### June 

### 24, 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 ofTransportation 1200 NewJersey 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 am a licensed Airline Transport Pilot and A&P mechanic with a bachelor's degree in Aeronautics from San Jose State University. I am currently a captain forAmerican Airlines and have over 

### 20,000 flight hours. I understand the importance ofoperating a UAS in a safe manner.
My request is for awaiver ofthe sections identified below in an effortto operate a UAS for commercial photography and video. Mywife and I own a home based photography business. Operating a UAS would offer our customers a uniqueview pointfortheir photos and video.
My request is to operate a UAS for commercial purposes to record aerial video and photography of real estate, general photography, and special events.

I am 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 aircraftsystem (UAS) underthe new FAA "Summary Grant" approach, announced April 9th, 2015 http://www.faa.gov/news/updates/?newsld=82485thatwill help speed up Section 333 exemption approvals for many commercial UAS operators priorto finalizing the small UAS proposed rules published this past February.

It is my understandingthatthe FAA will still review each Section 333 petition individually. However, I am hopingthatthe agency will accept my particular petition, and include it in the next summary grant, and issue me an exemption on the presumption thatthe FAA has "already granted a previous exemption similartothis request".Apparently, the new interim policy includes the granting ofa Certificate ofWaiver or Authorization (COA) forflights at or below 200 feet to any UAS operatorwith a Section 

### 333 exemptionfor aircraftthatweigh less than 

### 55 pounds, operate during daytimeVisual Flight Rules (VFR) conditions, operate withinvisual line ofsight (VLOS) ofthe pilots, and stay certain distances awayfrom airports or heliports such as 

### 5 nautical miles (NM) from
an airport having an operational control tower; or

### 3 NM from an airportwith a published instrumentflight procedure, but notan operational tower; or

### 2 NM from an airportwithout
a published instrumentflight procedure or an operational tower; or

### 2 NM from a heliport with a published instrumentflight procedure. It is also understood thatthe "blanket" 200- foot COA allows flights anywhere in the country except restricted airspace and other areas, such as major cities, wherethe FAA prohibits UAS operations.

UAS Description: I am asking for an exemption fora UAS upto 

### 55 pounds because Iforecast Iwill be using a craftthat will be flown operationally, weighing less thanten pounds and more specificallythe DJI Phantom models, and will be qualified as a UAS.

In the event a loss ofcommunications occurs the craft will rise upverticallyto a safe height before beginning an automatic return to homefunction. The control signal may be reconnected in flight and the pilot can take over safe operations again ifcommunication is reestablished. However in the case ofa GPS failure the craft will be able to be manuallyflown to a safe landing by the pilot. The craft operates electrically, carries no flammable fuel, and has an integrated GPS pilot system.

I understand the importance ofconducting safe flight operations and planning flight paths which minimizeflights over crowds. Flights will end when battery reserve reaches no less than 25 percent. Operations will notoccur under IFR conditions. In addition, preflight and post-flight checklists and UAS examinations will help detect any abnormalities prior to flight and afterflight. Any UAS unableto satisfy safety checklists will be removed from service until the issue can be resolved.
Grantingthis 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 ofthe craft, experience ofthe pilot, and operational goals, this request appears to be well suited for approval usingthe current criteria outlined in Section 

### 333 ofthe FAA Modernization and Reform Act of2012 (including new interim policies)



# Si~~ Stacey Chance Discovery Bay Studios