October 14, 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, 

In reference to Docket No. FAA-2015-2744 dated June 24, 2015. 

.,,.,_.'.'" ;•. 

. ' 

. -~ 

I am submitting the requested additional information regarding why granting Discovery Bay Studios the 

Exemption for Unmanned Aircraft Systems operations would be in the public interest and how it would 

benefit the public as a whole. 

The Reasons Why Discovery Bay Studios Request Would Be In The Public Interest; That Is, How It 

Would Benefit The Public As A Whole. 

Granting the present petition will further the public interest by allowing Discovery Bay Studios to safely, 

efficiently, and economically perform aerial video and photography of real estate, events, civic 

landscape, architectural, and construction sites over local areas of the United States. Additionally, use of 

the DJI Phantom UAS will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Normally these functions would require larger manned aircraft. Notably, the 

benefits of Discovery Bay Studios proposed operation of the DJI Phantom UAS will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom UAS are battery 

powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally 

utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in 

the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The DJI Phantom UAS do not require 

an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations. 
2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom UAS. 

Conducting aerial acquisitions with the DJI Phantom UAS, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the DJI 

Phantom UAS produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. 

The DJI Phantom UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise 

pollution, as the UAS are propelled by battery powered electric motors, rather than an internal 

combustion engine. By using the DJI Phantom UAS to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located on board the aircraft, the DJI Phantom UAS (weighing 

less than 3 pounds at their maximum gross weight, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds, and a 

fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The OJI Phantom UAS Will Benefit The 

Economy. 

In addition to being safe and efficient, the DJI Phantom UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom UAS will 

allow United States based companies, like Discovery Bay Studios, to remain competitive and contribute 

to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt 

new and alternative technology in order to remain competitive. Operating the battery powered DJI 

Phantom UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the DJI Phantom UAS, companies such as Discovery Bay Studios, can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Phantom UAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States and abroad. 

Sincerely, /t; // 

-:;--- h_--

Stacey Ch~·nce 

Discovery Bay Studios 
US Department 

of Transportation 

Federal Aviation 

Administration 

October 2, 2015 

Mr. Stacey Chance 

Discovery Bay Studios 

1854 Seal Way 

Discovery Bay, CA 94505 

Dear Mr. Chance: 

800 Independence Ave .. SW 

Washington. D.C. 20591 

This letter is to inform you that we are unable to process your petition for an exemption from 

Part21 and§§ 45.23(b), 45.27(a), 61.113(a)(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)(b), 91.319(a)(l), 91.405(a), 91.407(a)(1), 

91.409(a)(2), and 91.417(a)(b) of Title 14, Code of Federal Regulations (14 CFR). It explains 

why we cannot process your request and what you should do in the next 30 days. 

Why We Cannot Process Your Request 

We received your June 24, 2015 exemption request on behalf of Discovery Bay Studios filed 

in Docket No. FAA-2015-2744, but we are unable to process your request any further. Your 

petition does not comply with the requirements of§ 11.81 (copy enclosed). For us to consider 

the request any further, you must send us all of the following: 

• The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

• Any additional information, views, or arguments available to support your request. 

For more detailed information relating to submitting petitions for exemption, please visit 

http://aes.faa.gov/petitionlindex.html. This website helps the petitioner to meet Federal 

Aviation Administration (FAA) requirement outlines in § 11.81 and helps answer any 

questions you may have. 

What You Should Do 

If you want us to process your request any further, you must submit the requested information 

within 30 days. Please note that§ 11.63(d) requires you to send your petition for exemption 

at least 120 days before the proposed effective date of the exemption. 
If We Do Not Hear From You 

If we do not receive the information, we will close the docket without notifying you further. 

If you have any questions you may call the 333 Information Line (202) 267-2999. 

Sincerely, 

. 

Brittany 

~t~~ Newton 

Program Analyst, Airmen and 

Airspace Rules Division 

Enclosures 

2 
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)(l), 91.405(a), 91.407(a)(l), 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/?newsld=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 

usinga cr~ft that will be flown o_pera!ionally, weighing less than ten pouQds and mor.e..___~ 

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, Jt; ~ 

Stacey Chance · 

Discovery Bay Studios