October 28, 2015 

US Department Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam: 

Troy Grant, Owner 

Epic Foto Group, LLC 

1214 Wooded 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 under the conditions outlined herein or as maybe established by the FAA as 

required by Section 333. These activities include but will not be limited to 

1. Marketing of residential and commercial real estate 

2. Inspection surveys including roofing, 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 exception would permit the operation of light weight 

(less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial 

use. 

Epic Foto Group, LLC'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 users of the nation airspace, public nor the 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 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 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 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. 

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 Epic Foto 

Group, LLC 

1. Flights will only occur in the day time 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 manufacturers recommendations, 

4. The UASs will weigh less that SSibs., 

5. Flights will be operated at 400 feet AGL or less. 

6. PIC will do a thorough preflight inspection. 

7. The UASs operator will perform a check of the flight area and make certain of the 

safety of all persons in the area, 

8. 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. 

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 

manner with the auto return function checked and working. 

11. Flights will only operate in VFR conditions. 

12. UASs have a function on the control to tell operator the distance away from the 

operator and its battery power remaining. 

13. Flight team will communicate by voice and the use of two-way radio if the area is too 

large to hear voice from all team members. 

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 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 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. 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 of safety 

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 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 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 at or below 400AGL. 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 UAS 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 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 of the use of these 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 authority to 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 

1214 Wooded Trail 

Hurst TX 76053 

troy@troygrant.net 

817 9371772