October 14, 2015 Stacey Chance Discovery Bay Studios 1854Seal Way Discovery Bay, CA 94505 captainchance@gmail.com Cell 925-216-4454
FAA Docket Management Facility U.S. DepartmentofTransportation 1200 NewJersey Avenue, SE West Building, Ground Floor, Room W12-140 Washington, DC 20590 Dear Exemption Manager,
In reference to Docket No. FAA-2015-2744 datedJune 24, 2015. .,,.,_.'.'" ;•.

. '

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I am submittingthe requested additional information regarding why granting Discovery Bay Studios the Exemption for Unmanned Aircraft Systems operations would be in the public interest and how itwould benefitthe 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 AWhole. Granting the present petition will furtherthe 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 ofthe United States. Additionally, use of the DJI Phantom UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits tothe economy. Normallythese functions would require larger manned aircraft. Notably,the benefits of Discovery Bay Studios proposed operation ofthe 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 tothe manned aircrafttraditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa 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 aircraftwill be reduced. The DJI Phantom UAS do not require an airporttotakeoffor land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraftthat must be handled by airtraffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.2. The Public Will Benefit From The SafetyAnd 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 ofair and noise pollution generated duringtraditional aerial video and still photographyflight operations. By using battery power and electric motors, the DJI Phantom UAS produce no air pollution, and is the mostviable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraftthat 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 ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, ratherthan an internal combustion engine. By usingthe 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 withtraditional manned aircraftflight operations, will be substantially reduced or completely eliminated.
Aside from the lack offlight crew members located onboard the aircraft, the DJI Phantom UAS (weighing less than 

### 3 pounds attheir maximum gross weight, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and inthe air, compared tothe manned aircraftthattypically conduct similar operations (weighing approximately 6,000 pounds, and a fuel capacity of 

### 180 gallons).
3. PerformingAerial Video and Photography OperationsWithThe OJI Phantom UAS Will BenefitThe Economy.
In additionto being safe and efficient, the DJI Phantom UAS are also an economical alternativeto using manned aircraftto conduct similar aerial operations. 

### As such, operation ofthe DJI Phantom UAS will allow United States based companies, like Discovery Bay Studios, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, withthe rising cost ofaviation 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 orderto remain competitive. Operatingthe battery powered DJI Phantom UAS is one such technology that notonly allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility withoutthe high operational cost ofa traditional manned aircraft. By operatingthe DJI Phantom UAS, companies such as Discovery Bay Studios, can remain competitive and profitable, and therefore, provide greaterjob stabilityto employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use ofthe DJI Phantom UAS, provides a stable workforcethat increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in orderto remain competitive both in the United States and abroad.
Sincerely, 

# /t; // -:;--- h_-- Stacey

### Ch~·nce Discovery Bay StudiosUSDepartment ofTransportation 

### FederalAviation 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 youthat we are unable to process your petition for anexemption 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) ofTitle 14, Code ofFederal Regulations (14 CFR). Itexplains why we cannot process yourrequest and what you should do inthe next 30 days. Why We Cannot Process YourRequest We received yourJune 24, 2015 exemption request onbehalfofDiscovery Bay Studios filed inDocketNo. FAA-2015-2744,butwe are unable to process your request any further. Your petition does not comply with therequirements of§ 11.81 (copy enclosed). Forus to consider the request any further, you must send us all ofthe following:

• The reasons why granting the request wouldbe 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. Formore detailed information relating to submitting petitions for exemption, please visit http://aes.faa.gov/petitionlindex.html. This website helps the petitionerto meet Federal Aviation Administration (FAA) requirement outlines in § 11.81 and helps answer any questions you may have. WhatYou Should Do Ifyou want us to process your request any further, you must submitthe requested information within 30 days. Please note that§ 11.63(d) requires you to sendyourpetitionfor exemption at least 120 days before the proposedeffective date ofthe exemption.

### If

### We Do NotHear From You Ifwe do not receive the information, we will close the docket without notifying youfurther. Ifyouhave any questions youmay call the 333 Information Line (202) 267-2999. Sincerely,



# .**~t~~** BrittanyNewton Program Analyst, Airmen and

Airspace Rules Division Enclosures 

### 2June 24, 2015 Stacey Chance Discovery Bay Studios 1854Seal Way Discovery Bay, CA 94505 captainchance@gmail.com Cell 925-216-4454
FAA Docket Management Facility U.S. Department ofTransportation 1200 NewJersey 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 forAmerican Airlines and have over 20,000 flight hours. I understandthe importance ofoperating a UAS in a safe manner. My request is for awaiver ofthe sections identified below in an effortto operate a UAS for commercial photography and video. Mywife and I own a home based photography business. Operating a UAS would offer our customers a uniqueview pointfortheir photos and video. My request is to operate a UAS forcommercial 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) underthe new FAA "Summary Grant'' approach, announced April 9th, 2015 http://www.faa.gov/news/updates/?newsld=82485that will help speed up Section 333 exemption approvals for many commercial UAS operators priorto finalizing the small UAS proposed rules published this past February.
It is my understandingthatthe FAAwill still review each Section 333 petition individually. However, I am hopingthatthe agency will accept my particular petition, and include it in the nextsummary grant, and issue me an exemption on the presumption thatthe FAA has "already granted a previous exemption similartothis request''.Apparently, the new interim policy includes the granting ofa Certificate ofWaiver or Authorization (COA) forflights at or below 200 feetto any UAS operatorwith a Section 333 exemption for aircraftthatweigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate withinvisual line ofsight (VLOS) ofthe pilots, and stay certain distances awayfrom airports or heliports such as 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airportwith a published instrumentflight procedure, but not an operational tower; or 2 NM from an airportwithout a published instrumentflight procedure or an operational tower; or 2 NM from a heliport with a published instrumentflight procedure. It is also understood thatthe "blanket" 200- foot COA allows flights anywhere inthe country except restricted airspace and other areas, such as major cities, wherethe 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** thatwill be flown o_pera!ionally, weighing less thanten pouQds and**mor.e..___~** specificallythe DJI Phantom models, and will be qualified as a UAS.
In the event a loss ofcommunications occurs the craft will rise upverticallyto a safe height before beginning an automatic return to homefunction. The control signal may be reconnected in flight and the pilot can take over safe operations again ifcommunication is reestablished. However in the case ofa GPS failure the craft will be able to be manually flown to a safe landing bythe pilot. The craft operates electrically, carries no flammable fuel, and has an integrated GPS pilot system.
I understand the importance ofconducting 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 afterflight. 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 ofthe craft, experience ofthe pilot, and operational goals, this request appears to be well suited for approval usingthe current criteria outlined in Section 333 ofthe FAA Modernization and Reform Act of2012 (including new interim policies)

Sincerely, 

# Jt;**~** Stacey Chance · Discovery Bay Studios