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 Degree in Aeronautics from 

San Jose State University. I am currently a captain 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 below 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 commercial 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 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 the DJI Phantom models, 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 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, 

Stacey Chance

Discovery Bay Studios