Andrew Collins, Owner

North Texas Aerial Photography

208 Suntide Dr.

Sunnyvale TX 75182

acollinsdal@yahoo.com

214 728 0361

June 18, 2015

US Department Of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC 20591

Dear Sir or Madam:

 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 Federal 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 such operations are conducted 

within 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 including 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 

commercial use by a certified private pilot thereby enhancing safety and fulfilling the 

Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish 
requirements for safe operation of such aircraft systems in national airspace systems.” 

Section 333(c), of 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 below and at 200 feet AGL or less. These operations 

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 regulations 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 operating to 

prevent North Texas Aerial Photography future commercial use of small UASs to operate 

in the 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 interest to do so. North Texas Aerial Photography UASs 

meet the definition of “small unmanned aircraft” as defined in Section 331 and therefor 

the integration of these UASs are expressly contemplated by the 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 

of 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 operator

 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 combined 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 verses traditional aircraft as well as 

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 ME Drone 

Video LLC,

1. Flights will only occur in the day time hours,

2. Flights will be operated in the 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 manufacturers 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 flight 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 violating 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 working. 

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 hear 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 defined 

area of operations 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 airworthiness 

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 certifications 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 regulation 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. As there are no 

pilots or passengers, and given the size of the UASs this regulation is inapplicable. 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,9565,9565B,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 certain conditions. North 

Texas Aerial Photography will only 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 the owner has consented and all persons within 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 fuel UASs operations present a far smaller risk to the public.
 Approval of these 333 Exemptions 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 small UASs of 55 lbs. or less, battery operated and fling below 200 feet 

AGL 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 requests the FAA grant its exception without delay. The 

FAA has the authority to issue 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