February 16, 2016

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,

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

I am a licensed Light Sport Pilot, certificate numbers 3191624, and I hold a Repairman Light 

Sport Aircraft, also shown on my license. I have over 700 hours in Experimental Light Sport 

Powered Parachutes and have been flying since 2004. I understand the importance of operating 

a UAS in a safe manner.

My request is for a waiver of the sections identified below in an effort to operate a UAS for 

commercial photography and video. Operating a UAS would offer our potential customers a 

unique view point for their photos and video.

My request is to operate a UAS for commercial purposes to record aerial videos and 

photography of real estate, general photography, and special events. 

I am seeking exemption of: 

Section of 14CFR: 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) (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/?newstd=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, 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, carry crew in addition to flammable fuel, gives the FAA good cause to find that the 

UAS operation enable by this exemption is in the public interest. 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 fights at or below 200 feet to any UAS operator with a Section 333 

exemption for aircraft that weight is 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 county 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, weighting less than five pounds and more specifically the DJI 

Phantom models as well as the Yuneec Q300 model, and will be qualified as a UAS.

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, and has an integrated 

GPS pilot system. I understand the importance of conducting safe flight operations and 

planning flight paths which minimize flights over crowds. Flights will end when battery reserve 

reaches no less than 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 checklist 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 submitted, 

Robert P. Coffman

3207 State Route 746

Cardington, Ohio 43315

(614)313-2746

Email: rcoffman135@hotmail.com