Andrew Collins, Owner North Texas Aerial Photography

208 Suntide Dr. Sunnyvale TX 75182 acollinsdal@yahoo.com

214 728 0361

June 18 , 2015

US D epartment Of Transportation

Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or M adam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, North Texas Aerial Photography , owned by Andrew S. Collins, a private pilot for over 10 years , request to be exempted from the Feder al Aviation Regulations (FAR) listed below so that North Texas Aerial Photography may operate Small Unmanned Aircraft Systems (UASs) commercially in airspace regulated by the FAA. To conduct aerial photography and inspection , as long as suc h operation s are conducted with in and under the conditions outlined herein or as maybe established by the FAA as required by Section 333. These activities include but will not be limited to

1. Marketing of residential and commercial real estate 2. Inspection surveys incl uding roofing, oil & gas and agriculture 3. Assist local law enforcement in emergency matters 4. Television production and other aerial photography and video production North Texas Aerial Photography is owned by Andrew S. Collins, who has been a private pilot for over 10 years. All operations will be performed with the public’s safety and right to privacy safe guarded at all times. As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for

c ommercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establishrequirements for safe operation of such aircraft systems in national airspace systems.”

Section 333(c) , o f the Reform Act. North Texas Aerial Photography UASs are rotorcraft weighing less than 55 pounds including payload. ( The DJI Phantom 3 Advanced quad copter ) They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will operate within the line of sight with in a protected flight area as described be low and at 200 feet AGL or less

. These op erations will not create a hazard to users of the nation airspace, public nor the environment. North Texas Aerial Photography respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulation s allowing it to operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b) , 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

North Texas Aerial Photography submits this application in accordance with the Reform Act ,112 P.L. 95 331

- 334, seeking relief from any currently applicable FAR’S operati ng to prevent North Texas Aerial Photography future commercial use of small UASs to operate in th e national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public’s intere st to do so. North Texas Aerial Photography UASs meet the d efinition of “small unmanned aircraft” as defined in Section 331 and therefor the integration of these UASs are expressly contemplated by th e Reform Act. North Texas Aerial Photography would like to operate its light weight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion

o f the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following: The UASs size, speed, weight and operational capability Operation of the UASs in close proximity to airports and populated areas Operation of the UASs within visual line of sight of the opera tor Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.The very small nature of these UASs combi ned with the safe guards presented below,

will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verse s traditional aircraft as well a s the economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay. The following will be considered as the binding limitation on operations of M E Drone Video LLC,

1. Flights will only occur in the day time hours, 2. Flights will be operated in th e line of sight of the operator ( PIC ) and Observer, (VSO) 3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by manufactu rers recommendations, 4. The UASs will weigh less that 55 lbs., 5. Flights will be operated at 200 feet AGL or less. 6. PIC will do a thorough preflight inspection just as he would with any airplane operation 7. Operator and crew will remain in contact during the f light operation, 8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area, 9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of viol ating anyone’s privacy. 10. All required FAA clearances, will be obtained and distances from airports strictly observed. 11. All UASs will have the capability to return automatically to the operator in a safe manner with the auto return function checked and wor king. 12. Flights will only operate in VFR conditions. 13. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining. 14. Flight team will communicate by voice and the use of two

- way radio if the area is too big to h ear voice from all team members, an observer will always be present. 15. When operating over or near water the UASs will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement

of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and def ined area of o perations for North Texas Aerial Photography UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthines s certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. North Texas Aerial Photography meets or exceeds each of these elements

As of 2015 the FAA has stated that it will automatically grant a “blanket” COA for flights at or under 200 AGL to any UASs operator with a section 333 exemption. 14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining such c ertifications and registrations at ME Drone Video LLC operations center. 14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regula tion is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. A s there are no pilots or passengers, and given the size of the UASs this regulation is inapplicabl e. An equivalent level of safety will be achieved by maintaining such certifications and registrations at ME Drone Video LLC operations center. The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,95 65B,10167,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certai n conditions. North Texas Aerial Photography will onl y operate its UASs at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that t he owner has consented and all persons with in this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs. , operating below 500 AGL with flammable fu el UASs operations present a far smaller risk to the public.Approval of these 333 Exemption s allowing commercial operations of small UASs in the

service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of sma ll UASs of 55 lbs. or less, battery operated and fling below 200 feet AG L the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by ME Drone Video LLC will give the people another avenue to express themselves and to have a video record to share with family and friends forever. Granting North Texas Aerial Photography the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masses. ME Drone Video LLC respectfully re quests the FAA grant its exception without delay. The FAA has the authority to i ssue the exemption sought by North Texas Aerial Photography pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely

Andrew S. Collins

North Texas Aerial Photography

208 Suntide Dr. Sunnyvale TX 75182 acollinsdal@yahoo.com

214 728 0361