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April 14th, 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 Exemption 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 extreme 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 9th, 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. 
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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 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 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. 
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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. 

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