West Edge Collective, LLC

1935 Eagle Drive

Cheyenne, WY 82009

chad@westedge.us

307.920.3405 cell phone

June 3, 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, West Edge Collective, LLC, owner and operator of Small Unmanned Aircraft Systems (UASs),

requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that West Edge

Collective, 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 may be established by the

FAA as required by Section 333.

West Edge Collective, LLC (a marketing and advertising company) is owned by Chad W. Willett, a

Wyoming resident, with a Wyoming Drivers license. Mr. Willett also has a private pilot’s license (VFR SEL)

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 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.

West Edge Collective UASs (The 3dr solo quadracopter and soon­to­be hexo+) are rotorcraft weighing

less than 55 pounds including payload.They operate at a speed less than 50 knots and have the capability

to hover and move in the vertical 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 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.

West Edge Collective, 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).

West Edge Collective, LLC submits this application in accordance with the Reform Act ,112 P.L. 95

331­334, seeking relief from any currently applicable FAR’S operating to prevent West Edge Collective, 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. West Edge Collective, LLCs 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. West Edge Collective, LLC would like to operate its lightweight

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.

West Edge Collective, LLC 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 West Edge Collective, LLC,

Flights will only occur in the daylight hours,

Flights will be operated in the line of sight of the operator(PIC) and Observer,(VSO)

Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by manufacturers

recommendations,

The UASs will weigh less that 55 lbs.,

Flights will be operated at 200 feet AGL or less.

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

Operator and crew will remain in contact during the flight operation,

The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the

area,

Consent will be obtained from all persons within the video capabilities of the units to further reduce the

chance of violating anyone’s privacy.

All required FAA clearances, will be obtained and distances from airports strictly observed.
All UASs will have the capability to return automatically to the operator in a safe manner with the auto return

function checked and working.

Flights will only operate in VFR conditions.

UASs have a function on the control to tell operator the distance away from the operator and its battery

power remaining.

Flight team will communicate by voice and the use of two­way radio if the area is too big to hear voice from

all team members.

UASs will be used to video for commercial marketing and advertising.

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 West Edge

Collective, 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. West Edge

Collective, 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 West Edge Collective, 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 West Edge Collective, 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. West Edge Collective, 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 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.
Granting West Edge Collective, 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.

West Edge Collective, LLC respectfully requests the FAA grant its exception without delay. The FAA has the

authority to issue the exemption sought by West Edge Collective, LLC pursuant to the Federal Aviation Act,

85 P.L. 726 (1958) as amended (the ACT).

Sincerely

Chad W Willett

CEO & Executive Producer

West Edge Collective, LLC

1935 Eagle Drive

Cheyenne, WY 82009

chad@westedge.us

307.920.3405 cell phone