April 14 th , 2015

Dave W oll PO BOX 60030 Grayslake, IL 60030
Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SEWest Building, Ground Floor, Room W 12

- 140 W ashington, DC 20590 Dear Exemption Manager, Re: **Docket Number FA A** 
**- 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 educatio n 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 militar y 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/televisionproduction and aerial data

collection, and that most of the exemption requests in these categories **wi ll likel**  **y be** 
**handled through the new summary grant process** 

.
Wi th my clear unde rstanding 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 parce l of land, for ultimate disposition and sale” or “other promotional purposes (ie. a country clubwanting 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 cu rrentl**  **y 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 Summar y:**  “The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new FAA “Summary Grant” approach, announced April 9 th , 2015 http://www.faa.gov/news/updates/?newsId=82485 that will help speed up Section 333 exemption approva ls 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 acc ept 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 W aiver 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 visua l 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 no t 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 fli ghts anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA prohibits UAS operations.
**UA S 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 t o 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 co ntrolled airports, andprovides direction of travel distance from the pilot.

**Ad ditional 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 Operat ions:**  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 an d 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 Ap**  **propriateness:** Based on the size of the craft, experience of the pilot, and operational goals, this reques t 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 W ool