April 14th, 2015

Dave Woll

PO BOX 60030

Grayslake, IL 60030

Docket Management FacilityU.S. Department of 

Transportation1200 New Jersey Avenue, SEWest 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 

with over 77.5 flight hours. I have been a private pilot since 2003. 

I take the skills and education for the safe operation of UAS, very 

seriously. These are UAS’s are not Toys. 

My request is for a waiver of the sections identified below in an 

effort to operate a UAS in public. I recognize the importance of 

extreme privacy as I have been in situations where I have had to 

adhere to an environment, and culture, that is based on such 

privacy. Additionally, I have many times in the past been 

entrusted with the possession of highly confidential information 

working on various engineering projects with military and 

commercial customers. 

I reference the FAA announcement dated April 23, 2015, 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 (even though 

The FAA is lowering the 

credential bar to include sport pilot certificates), and my attitude 

of safety first when it 

comes to flight operations, I believe I should be granted an 

exemption. 

1 

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 
wanting to promote its facilities)”. Any complaint by a neighboring 

member of the public 

complaining of even a hint of invasion of privacy, 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 forecast I will be using a craft that will be flown 

operationally, weighing less than ten pounds and more 

specifically a DJI Phantom Vision + , or DJI Phantom 3, and will 

be qualified as a UAS. 

2 

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 no-fly zones for controlled airports, and 
provides direction of travel distance from the pilot. 

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. 

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 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, Dave Wool