October 28, 2015

USDepartment OfTransportation Federal Aviation Adminis tration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam : Troy Grant, Owner Epic Foto Group, LLC 1214Wooded Trail

Hurst, TX 76053 troy@troygrant.net 817 9371772

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11 , Epic Foto Group, LLC, owned by Troy Grant, request to 

### be exempted from the Federal Aviation Regulations {FAR) listed below so that Epic Foto Group, LLC may operate Small Unmanned Aircraft System (UAS) commercially in airspace regulated by the 

### FAA.

To conduct aerial photography and inspection, as long as such operations are conducted within and underthe conditions outline d herein or as maybe established by the FAA as required by Section 333

. These activities include butwill not be limited to

1

. Marketing of residential and commercial real estate 2. Inspection surveys including roofi ng, oil & gas and agriculture 3. Other aerial photography and video production

All operations will be performed with the public's safety and right to privacy safeguarded at all times.

As described below, the requested ex ception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial
use

. Epic Foto Group, L LC's UAS is a DJI Phantom 3 Professional quad copter, is rotorcraft weighing less than 55 pounds including payload. It operates at a speed less than SO knots and has 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 400 feet AGL or less. These operations will not create a hazard to usersofthe nation airspace, public northe environment

. Epic Foto Group, LLC respectfully requests the grant of an exception to the following specific sections of t he Title 14 Code of Federal regulations allowing it to operate a lightweight UAS 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). Epic Foto Group, LLC submitsthis application in accordance with the Reform Act ,112 P.L. 95 331-334, seeking relief from any currently applicable FAR'S operating to prevent Epic Foto Group, LLC future commercial use of small UAS 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. Epic Foto Group, LLC's UAS meet the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of this UAS are expressly contemplated by the Reform Act. Epic Foto Group, LLC would like to operate its light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governingsuch 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 ofthe national airspace system or the public or pose a threatto 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 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 ofthese 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 ofgreatly reducing the cost ofaerial photographytherebybenefitingthe 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 Epic Foto Group, LLC
1. Flights will onlyoccur in the daytimehours,2. Flightswill beoperated in the line ofsight ofthe 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 SSibs., 5. Flights will be operated at400feetAGL or less. 6. PIC will doathorough preflight inspection. 7. The UASs operator will perform a check of the flight area and make certain of the safety ofall persons in the area, 8. Consent will be obtained from all persons with in thevideo capabilities ofthe unitsto further reduce thechance ofviolating anyone's privacy. 9. All required FAA clearances, will be obtained and distances from airports strictly observed. 10. All UASs will have the capability to return automatically to the operator in a safe
mannerwiththe auto return function checked and working. 11. Flights will onlyoperate in VFR conditions. 12. UASs have a function on the control to tell operator the distance away from the operatorand its battery power remaining. 13. Flight team will communicate by voice and the use oftwo-way radio ifthe area is too large to hearvoice from all team members.

CFR part21 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 of operations for Epic Foto Group, LLC's UAS flights permit 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 ofthe 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. Epic Foto Group, LLC meets or exceeds each of these elements

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 ofsafety will be achieved by maintaining such certifications and registratfons at Epic Foto Group, LLC's operations center.
14CFR91.7 (a) prohibits the operation of an 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 Aircraft14 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 Epic Foto Group, LLC's operations center.
The FAA has previously issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,956SB,10167,10167 A,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. Epic Foto Group, LLC will only operate its UAS ator below400AGL. 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 propertythat 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 morethan 50 lbs., operating below 500 AGL withflammable fuel UAS operations present afarsmaller risk tothe public.

Approval ofthese 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 ofsmall UASs of 55 lbs. or less, battery operated and flying below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting ofthe use ofthese small UASs by Epic Foto Group, LLC will give the people another avenue to express themselves and to have a video record to share with family and friends forever. Epic Foto Group, LLC respectfully requests the FAA grant its exception without delay. The FAA has the authorityto issue the exemption sought by Epic Foto Group, LLC pursuant to the Federal Aviation Act, 85 

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

ant Epic Foto Group, LLC 1214Wooded Trail HurstTX 76053 troy@troygrant.net 817 9371772