ME Drone Video LLC
17595 East View Loop Foley, AI 36535 cmergle@hiwaay.net
256-142-4277 cell phone April 4, 2015 US Department OfTransportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam: : .:_;

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012(the reform act) and CFR Part 11, ME Drone Video LLC, owner and operatorofSmalt Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations {FAR) listed below so that ME Drone Video LLC may operate UASs commercially in airspace regulated bythe FAA., as long as such operations are conducted within and underthe conditions outlined herein or as maybe established by the FAA as required by Section 333.
ME DroneVideo LLC is co- owned by Clarence M Ergle and Gary Jeff Michaels. Both are Alabama Peace Officers with active taw enforcement certificates. Both have Alabama Drivers licenses. Mr. Ergle has a private pilot's license and will be the PIC. 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 permitthe operation of light weight (less than 55 lbs. total takeoffweight) UASs under controlled conditions for commercial use by a certified private pilotthereby enhancing safety and fulfilling the Secretary ofTransportation's (the FAA Administrator's) responsibility to" establish requirementsforsafe operation ofsuch aircraft systems in national airspace systems." Section 333(c), ofthe Reform Act. ME Drone video UASs are rotorcraft weighing less than 55 pounds including payload. (The DJI Phantom 2 Vision Quad Copter and Parrot PF 725100 Bebop Drone 14MP.)They operate at a speed less than 50 knots and have the capabilityto hover and move in thevertical and horizontal plane simultaneously. Both have an auto return to launch point when battery power is under 25%. The UAS will operate within the line ofsight with in 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 ofthe nation airspace, public northe environment.

ME Drone Video LLC respectfully requests the grant ofan exception tothe following specific sections oftheTitle 14 Code of Federal regulations a11owing itto operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14CFR 45.23 (b) 14CFR 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).

ME Drone Video LLC submits this application in accordance with the Reform Act ,112 P

.L. 95 331-334, seeking relieffrom any currentlyapplicable FAR'S operating to prevent ME Drone Video LLC future commercial use ofsmall 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 interestto do so. ME Drone Video LLCs UASs meetthe definition of "small unmanned aircraft" as defined in Section 331 and thereforthe integration ofthese UASs are expressly contemplated by the Reform Act. ME DroneVideo LLC would like to operate its lightweight UASs priorto the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.
The Reform Act directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 ofthe reform Act. In making this determination, the Secretary ofTransportation is required to determine which UASs do create a hazard to users ofthe national airspace system orthe public or pose athreatto national security in light ofthefollowing:

The UASs size, speed, weight and operational capability Operation ofthe UASs in close proximityto airports and populated areas Operation ofthe UASs within visual line ofsight ofthe operator Reform Act 333(a}. Ifthe secretary determinesthat such vehicles "may operate safely in National Airspace System, the secretary shall establish requirements forthe safe operation in national airspace.

ME Drone Video LLC are rotorcraft weighing less than 55 lbs. and theyoperate at speeds less than 50 knots and have the capabilityto operate in the vertical and horizontal plane simultaneously. The UASs will operate onlywithin the line ofsight of the operatorwithin a protected flight area and at 200 feet AGL or less. These will not present a hazard tothe national airspace northe public.The very small nature ofthese UASs combined with the safe guards presented below, will allowforthe safe operation greaterthan that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due tothe size of UASs and the areas and altitudes theywill operate approval ofthis 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 ofthe 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 ofgreatly reducing the cost ofaerial photography thereby benefitingthe greater public's interest. Accordingly, the applicant requests that the FAA grantthe requested exemption without delay. The followingwill be considered as the binding limitation on operations of ME Drone Video llC, 

### 1. Flights will only occur inthe day time hours, 2. Flights wilt be operated in the line ofsight ofthe operator{ PIC) and Observer,(VSO) 3. Flights will be terminated atanytime weather and wind deteriorateto "unsafe for flight" by manufacturers recommendations, 4. The UASs will weigh less that 55 lbs., 5. Flights 

### will be operated at 200feet AGL or less. 6. Crew 

### will be at a minimum ofoperator(PIC) and an observer and/orcamera operator(VSO), 7. Operator and crew will remain in contact duringtheflight operation, 8. The UASs operator will perform a check ofthe flight area and make certain ofthe safety ofall persons in the area, 9. Consent will be obtained from all persons with in thevideo capabilities ofthe unitsto further reduce the chance ofviolating anyone's privacy. 10. All required FAA clearances, will be obtained and distances from airports strictly observed. 11. All UASs will have the capabilityto return automaticallyto the operator in a safe mannerwith the auto return function checked and working. 12. When operated in conjunction with fishing vessels inthe gulf, a chase boat

### will be assigned to operatethe UASs at a safe distance from the main fishing boat. 13. Flights 

### will only operate in VFR conditions. 14. UASs have afunction on the control totell operatorthe distance away from the operator and its battery power remaining. 15. Flightteam will communicate byvoice and the use oftwo-way radio ifthe area is too bigto hearvoice from all team members. 16. UASs will be used to video private outings and functions, boating, jet skiing, kayaking, fishing trips in the gulfarea and sporting eventsfrom a safe distance.l •

17. When operating over or near waterthe 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 14CFR 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 ofoperations for ME Drone Video LLC UASs flights permits exception from Part 21 because they meet an equivalent level ofsafety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both theAct (49 USC 4470(f) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAAto exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. ME DroneVideo LLC meets or exceeds each ofthese elements As of March 

### 23, 2015 the FAA has stated that itwill automatically granta "blanket" COA

forflights at or under 200 AGL to any UASs operatorwith a section 333 exemption. 14CFR 91.203(a&b) providesforcarrying ofcivil aircraft certificationsand registrations. These are inapplicable forthe same reasons stated above. The equivalent level ofsafety will be achieved by maintaining such certifications and registrations at ME Drone Video LLC operations center.

14CFR91.7 (a) prohibitsthe operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in theform contemplated by FAR's this regulation is inapplicable.
14CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft
14 CFR 91.9(b)(2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UASs this regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining such certifications and registrations at ME Drone Video LLC operations center. The FAA has previously issued exemptions tothis regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167 A,10602,10700 and 32827.

14CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. ME Drone Video lLC 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 thepresence ofany persons not essential forthese operations. Flights will only be over private propertythatthe owner has consented and all persons within this video area also give consent forthis filming. Compared toflight operations ofconventional and traditional aircraft or rotorcraft weighingfar more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a far smaller risk tothe public.

Approval ofthese 333 Exemptions allowing commercial operations ofsmall UASs in the service ofaerial 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 ofsmall UASs of55 lbs. or less, batteryoperated and fling below 200 feet AGL the risk ofinjury ofpeople on the ground orthe crew has been reduced or almost erased. The granting ofthe use ofthese small UASs by ME Drone Video LLC will give the people anotheravenue to express themselves and to have avideo record to share with family and friends forever. Granting ME Drone Video LLC the above exemption will allow forthe expansion of UAS systems intothe future forthe safe conduct offree enterprise and the enjoyment ofthe masses. ME Drone Video LLC respectfully requests the FAA grant its exception without delay. The FAA has the authorityto issue the exemption sought by ME Drone Video LLC pursuant to the Federal Aviation Act, 85 

### P.l. 726 {1958) as amended {the ACT).

Clarence M Ergle ME Drone Video LLC 17595 East View loop, Foley AI 36535 cmergle@hiwaay.net