### 1 April 14 th , 2015

Adam Palitz

PO BOX 40051 Long Beach, CA 90804
adam@cloudfire.cc

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, Re: Docket Number FAA-2015-0150

I am submitting my Petition for Exempti on for Unmanned Aircraft Systems operations. I am currently a FAA licensed private pilot with over 77.5 flight hours. I have been a private pilot since 2003. I take the skills and education for the safe operation of UAS, very seriously. These are UAS’s are not Toys.

My request is for a waiver of the sections identified below in an effort to operate a UAS in public. I recognize the importance of ex treme 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 engineering projects with military

and commercial customers.

I reference the FAA announcement dated April 9 th , 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.

### 2 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 9 th , 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 Vision + , or DJI Phantom 3, and will be qualified as a UAS.

### 3 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 signific antly 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 sa tisfy 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,

Adam Palitz