Buzz	Covington	Photography	LLC

281	Ariel	Drive	NE

Leesburg,	VA	20176

Buzz.Covington@gmail.com

(254)	466-7321	cell	phone

June	22nd,	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,	Buzz	Covington	Photography	LLC,	owner	and	

operator	of	Small	Unmanned Aircraft	Systems	(UASs),	request	to	be	exempted	from	

the	Federal	Aviation	Regulations	(FAR)	listed	below	so	that	Buzz	Covington	

Photography	LLC	may	operate	UASs	commercially	in	airspace	regulated	by	the	FAA.,	

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.

Buzz Covington	Photography	LLC	is	owned	by	John	Covington.		John	

Covington	is	in	possession	of	a	valid	Virginia	driver’s	license.		Mr.	Covington	

possesses	a	valid	commercial	pilot’s	license	(certificate	number	3343146),	has	been	

a	rated	aviator	since	1995,	and will	be	the	PIC.	All	operations	will	be	performed	with	

the	public’s	safety	and	right	to	privacy	safeguarded	at	all	times.

As	described	below,	the	requested	exception	would	permit	the	operation	of	

lightweight	(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.

Buzz	Covington	Photography’s	UASs	are	rotorcraft	weighing	less	than	55	

pounds	including	payload (The	DJI	Phantom	3	Professional	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.	They have	an	auto	return	to	launch	

point when	battery	power	is	under	25%.	The	UAS	will	operate	within	the	line	of	

sight	within	a protected	flight	area	as	described	below	and	at	200	feet	AGL	or	less	

with	an	observer located	close	at	hand	as	to	make	voice	communication	possible.	
These	operations	will not	create	a	hazard	to	users	of	the	nation	airspace,	public	nor	

the	environment.

Buzz	Covington	Photography	LLC 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).

Buzz	Covington	Photography	LLC	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	Buzz	Covington	Photography	LLC	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.	Buzz	Covington	

Photography	LLC’s	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.	Buzz	Covington	Photography	LLC	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.

Buzz	Covington	Photography’s	are	rotorcraft	weighing	less	than	55	lbs.	and	

they	operate	at	speeds	less	than	50	knots	and	have	the	capability	to	operate	in	the	

vertical	and	horizontal	plane	simultaneously.	The	UASs	will	operate	only	within	the	

line	of	sight	of	the	operator	within	a	protected	flight	area	and	at	200	feet	AGL	or	

less.	These	will	not	present	a	hazard	to	the	national	airspace	nor	the	public.
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	

Buzz	Covington Photography LLC,

1.	Flights	will	only	occur	in	the	daytime 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	manufacturer’s	recommendations.

4.	The	UASs	will	weigh	less	than 55	lbs.

5.	Flights	will	be	operated	at	200	feet	AGL	or	less.

6.	Crew	will	be	at	a	minimum	of	operator (PIC)	and	an	observer	and/or	camera	

operator (VSO).

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.

15.	UASs	will	be	used	to	photograph	and	record	video	for	real	estate	ventures,	

private	outings	and	functions,	and	sporting	events	from	a	safe	distance.

16.	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	Buzz	Covington	Photography	LLC	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.	Buzz	Covington	Photography	LLC	meets	or	exceeds	each	

of	these elements.

As	of	March	23,	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	Buzz	Covington	Photography 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	Buzz	Covington	Photography	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.	Buzz	Covington	Photography LLC	will	only	operate	its	UASs	at	or	below

200 feet	AGL.	They	will	be	operated	in a	well-defined	area 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.	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	to people	on	the	ground	or	

the	crew	has	been	reduced	or	almost erased.	The	granting	of	the	use	of	these	small	

UASs	by	Buzz	Covington	Photography	LLC	will	give	people	another	avenue	to	

envision	their	property,	event,	or	special	occasion.

Granting	Buzz	Covington	Photography	LLC	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.

Buzz	Covington	Photography	LLC	respectfully	requests	the	FAA	grant	its	

exception	without	delay.	The FAA	has	the	authority	to	issue	the	exemption	sought	

by	Buzz	Covington Photography	LLC	pursuant	to the	Federal	Aviation	Act,	85	P.L.	

726	(1958)	as	amended	(the	ACT).

Sincerely

John	R	Covington

Buzz	Covington	Photography	LLC

281	Ariel	Drive	NE,

Leesburg,	VA	20176

Buzz.Covington@gmail.com