June 24th, 2015

Charles A. Worsnop

108 Bridlewood Trail

Mills River, NC 28759

Tonywrealty@gmail.com

828-779-1148

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 rated for single engine land and sea with over 1200 flight 

hours logged. I have been a private pilot since 1999 and understand the requirements of safe 

flight and US airspace. My request is specifically for aerial real estate video. I am a licensed 

real estate broker in North Carolina.

My request is for a waiver of the sections identified below in order to operate a UAS in public

and in commercial operations. I recognize and understand the importance of safety and privacy. 

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 and my attitude of safety first when it comes to flight 

operations, I believe I should be granted an exemption.

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 or golf course wanting to 

promote its facilities)”. Any complaint by a neighboring member of the public complaining of 
privacy invasion, 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 own a DJI Phantom Vision 

Plus and a DJI Inspire 1, both of which are under 10 lbs. I understand that both of these 

models have already been accepted and approved under Section 333.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 nofly zones for controlled airports, and provides direction of travel distance from the pilot on a 

google map.

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. I have been flying a DJI Phantom Vision Plus for a year and have proficiency in 

piloting the aircraft in a safe manner always having respect for the FAA rules and public 

awareness. I have just taken delivery of a DJI Inspire 1 which is technically superior to m

Phantom and has additional safe flight operations.

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 20 percent. Both DJI UAS’s 

have a battery indicator on the controller. Operations will never 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,

Charles A. Worsnop