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 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 operations. I am a licensed Airline Transport Pilot and A&P mechanic with a Bachelor’s De gree in Aeronautics from San Jose State University. I am currently a c aptain for American Airlines and have over 20,000 flight hours. I understand the importance of operating a UAS in a safe manner. My request is for a waiver of the sections identified be low in an effort to operate a UAS for commercial photography and video. My wife and I own a home based photography business. Operating a UAS would offer our customers a unique view point for their photos and video. My request is to operate a UAS for comm ercial 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 ope rations, 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, announ ced 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 h as “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 the DJI Phantom models , an d 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 integra ted GPS pilot system

. I understand the importance of conducting safe flight operations and planning flight paths which minimize flight s 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 checklists will be removed from service until the issue can be r esolved. 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, Stacey Chance Discovery Bay Studios