Epic aerials

September 4, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. part 

11, Epic Aerials, a photography and videography design company, hereby applies for an 

exemption from the Federal Aviation Regulations listed below to allow operation of our Small 

Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration, so long as such operations are conducted under the conditions outlined herein 

or as may be established by the FAA as required by Section 333.

The requested exemption would permit us to pursue our commercial interests in providing 

services to clients using a small advanced sUAV in the following areas:

 Real Estate

 Marketing

 Special Events

 Aerial Inspections

All sUAS flights will occur over private or controlled access property and will do so with the 

property owner’s knowledge and consent, and only with the presence of people who have 

consented or otherwise agreed to be in the area where videography will take place.

Additionally, Epic Aerials requests an option to allow operations in Class G airspace, over people 

not involved in the operation. The owner/operator possesses a private pilot certificate 

(#3620371), as well as a Transportation Worker Identity Credential (TWIC) issued by the 

Transportation Security Administration. The owner/operator has been operating radiocontrolled aircraft for over 30 years.
Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23

14 C.F.R. 91.7

14 C.F.R. 91.9

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151

14 C.F.R. 91.23

14 C.F.R. subpart E 91.401-91.417

Small unmanned aircraft systems are seen as superior to helicopters, and other full-scale 

aircraft, due to the smaller size, less costly equipment and personnel costs, reduced noise, and 

significantly smaller environmental impact. I will be utilizing pre and post flight inspections of 

the aircraft to ensure all systems are fully operational, thus providing a safe flight environment.

Epic Aerials is petitioning for an exemption to operate a Blade Chroma with a built-in stabilized 

HD camera and GPS safety features to limit the flight altitude and radius of flight. The Blade 

Chroma also features a failsafe system that, in the event of a loss of communication with the 

transmitter, automatically returns the sUAV to its point of flight origin and safely lands. In 

addition, the ST-10 transmitter provides full telemetry of the sUAV, including battery level, 

altitude, airspeed, heading, and latitude/longitude position

The commercial services that Epic Aerials would like to provide are photography and 

videography of real estate property for the purposes of marketing and/or inspection, general 

marketing, and special events. I would be flying the sUAS within the guidelines of the 

exemption, and will meet the specifications of the Model Aircraft Operating Standards as noted 

below:

 The sUAS wil only be operated in line-of-sight of the pilot, and will be flown in such a 

way as to not create a hazard to users of the national airspace system, or the public.

 A spotter will be present, along with the pilot in command (PIC).

 When flying the sUAS within five (5) miles of an airport, airport operators will be 

notified and the PIC will yield the right-of-way to full scale aircraft.

 Maximum flight time for each operation will be 30 minutes.

 Flights will be terminated with sufficient battery level to allow reserve flight time to 

safely land the sUAS.

 The sUAS will be programmed so that it will not operate at an altitude that exceeds 400 

feet AGL.

 The Blade Chroma weighs less than 15 pounds, including all payload.
The use of the sUAS by Epic Aerials will not adversely affect the safety of the public because it 

will be operated within the restrictions of the exemption, and will be flown within line-of-sight 

of the PIC and observer. Use of the sUAS will provide a level of safety higher than that of a full 

scale aircraft due to its lightweight, size, performance capability, reduced noise, and smaller 

environmental impact. Additionally, the owner/operator already possesses aeronautical 

knowledge, and has been vetted by the Transportation Security Administration (TSA).

The sUAS will operate at speeds of no more than 20 knots. It can hover, and can simultaneously 

move vertically and horizontally. Given the small size of the sUAS, and the restricted 

environment within which it will operate, Epic Aerials operations would adhere to the reform 

act’s safety requirements.

I respectfully request an exemption under Section 333, to enable Epic Aerials to provide 

efficient, limited, low-risk commercial sUAS operations for the activities stated, respecting the 

space and privacy of citizens and property while keeping the airspace safe.

Sincerely,

David Engelhard

Epic Aerials

215 Rochelle Drive

Morehead City, NC 28557

252-725-2695
Davided1@ec.rr.com