August 18, 2015

Dan Dunn

234 S Highland Drive

Lakemoor, IL 60051

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

Re: Docket Number FAA-2015-0150

Dear Exemption Manager, 

I am submitting this Petition for Exeption for Unmanned Aircraft Systems (UAS) operations. I have 

operated a UAS for several years and take great care in every flight I make. UAS are not “toy 

helicopters”. It is delicate hobby that I wish to use in the residential, commercial, and industrial 

industries to help others as well.

This request is for a waiver of the sections identified below, in an effort to operate a UAS in the public. 

Extreme privacy will be taken to others during the use in public, and it will not be used to harm others. I 

will adhere to keeping operations safe, and not to harm the environment.

I have a clear understanding of the FAA rules and regulations currently in place for UAS operations and 

will keep up on future rules as they are set in place.

My intentions for this exemption is for use in the real estate market, construction market, and 

commercial marketing sectors. I have no intentions or desires for use for motion pictures and/or 

television filming. Any notice, from others, of concerns of privacy invasion will result in termination of 

operations, and discussions with all parties to rectify the situation. 

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). 

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 

reqeust 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 Operation: 

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. 

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. 

Speeds of flight will be kept at a slow pace as well, since main intent will be photgraphing and video 

recording.
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)

I, Dan Dunn, will be the sole operator of this UAS, and am directly responsible for the proposed 

operations and maintenance, unless maintenance is required by others, which would be directly with 

authorized manufacturer.

Sincerely, Dan Dunn