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Drone Consultants LLC

2406 York Minster Ct.

Arlington, TX 76006

August 15, 2015 

Docket Management Facility

US Department of Transportation 

1200 New Jersey Ave, SE 

West Building Ground Floor, Room w12-140 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir:

Pursuant to the Section 333 of the FAA Modernization and Reform Act 

of 2012 (Special Rules for Certain Unmanned Aircraft Systems), and 14 C.F.R. 

§ 11.61, Drone Consultants LLC hereby applies for an exemption from the 

following Federal Aviation Regulations (FARs) to allow commercial operation 

of the DJI F550, DJI S-800, DJI S-900, and DJI Phantom 3 small unmanned 

aerial systems (sUAS) in the National Airspace System (NAS):

14 CFR Part 21 subpart H 

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2) 

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c) 

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b)

Section 333 exemptions granted to date all prohibit sUAS flight operations at 

night. Drone Consultants LLC additionally seeks an exemption to 14 CFR § 91.205 (c)

(entitled Visual Flight Rules: Night) and Section 209 (Aircraft Lights) to fly the DJI 

Phantom 3 Professional (and only the Phantom 3 because of its unique design) at night 

up to 200 feet AGL - without having to request permission to fly each time from the FAA 

FSDO closest to proposed area of operations. Petitioner will fully outline in detail the 

reasons for this particular exemption, the economic benefit to the community, and 
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equivalent level of safety in the Basis for Exemption and Regulations from which the 

Exemption is Requested section starting on page 9.

Our Commercial Activities Would Include:

Commercial operations of sUAS, as described herein, which are

equipped with camera(s) and sensors, would operate in the following 

manner:

 Aerial photography and/or video for public and/or private use

including real estate, agriculture use, wildlife and forestry 

monitoring/preservation, architecture, land surveying, engineering

and other related professional activities.

 Aerial video and/or photography for public and/or private use including

television, public events, cinematography and news gathering.

 Aerial inspection/photography of residential/commercial structures, 

construction sites, bridge infrastructure, oil and gas facilities, flare 

stacks, and civil landscapes under contract with the owners or local

government authority.

 Aerial video/photography or providing live video feed to assist with 

search and rescue operations in cases of an emergency or natural 

disaster only when the local authorities or government has requested it 

by contract or donation.

 Conduct sUAS operator training, qualification, and demonstrations.

As described in more detail later in this document, the requested

exemptions would permit the operation of a sUAS under controlled conditions

in the NAS that would be a) limited b) controlled c) predetermined and d) will

provide safety enhancements to the already safe operations in the industry 

presently using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (and the FAA

Administrator’s) responsibilities to “....establish requirements for the safe 

operation of such aircraft systems in the national airspace system.”

Introduction and Interests of the Petitioner:

Drone Consultants LLC, specifically petitioner and President Mark Colborn has 

over thirty-five years of experience as a manned airplane and helicopter pilot. Petitioner 

holds the following FAA aircraft ratings:

 -Airline Transport Pilot – Airplane Multi-Engine Land

 -Commercial Pilot – Airplane SEL and Helicopter

 -Instrument Helicopter
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 -Instructor Pilot – Airplane SEL and Helicopter, Instrument Helicopter

 -FAA Class II Medical (no restrictions)

Petitioner is a retired Chief Warrant Officer Four from the Texas Army National 

Guard and has logged over 8500 hours in airplanes and helicopters since initially joining 

the U.S. Army in 1980. Petitioner served as an OH-58A/C and Sikorsky UH-60A/L 

Standardization Instructor Pilot, Night Vision Goggle Instructor Pilot, and Safety Officer 

during this time. Petitioner also has twenty-five years of experience as a helicopter pilot 

and instructor with a police aviation unit in a large city. Petitioner, in addition to the 8500 

hours mentioned above, has also logged an additional 4500 hours as a Tactical Flight 

Officer employing a high powered searchlight and sensor equipment on board small 

police observation helicopters. Petitioner also flew a turbine powered helicopter as a 

relief pilot for a major television station for approximately two and a half years, and 

became intimately familiar with the process of filming and reporting the news from an 

aerial platform.

Petitioner has flown small remote control electric quadcopters and hexacopters

recreationally since July 2013 and at the time of this petition has logged 3,780 minutes

(63 hours) of sUAS flight experience.

The petitioner believes his experience in the military, police, and recreational 

sUAS flying will provide clients (which include private sector businesses and non-profits, 

along with local, state, and federal agencies) with expertise and knowledge in video and 

multimedia marketing, advertising, public relations and training using advanced 

technologies and solutions. The objective of Drone Consultants LLC and our DJI 

sUAS aerial operations is to provide a more affordable, high-quality production system 

for a variety of commercial, public, and residential uses.

Small Unmanned Aerial Systems Descriptions and Operating Standards:

The DJI F550, S-800, S-900, and Phantom 3 Professional are vertical takeoff 

and landing (VTOL) sUAS with a Ground Control Station (GCS) utilizing either an

electronic tablet or smart phone, or a 7” LCD screen system. The DJI F550, S-800 and 

S-900 employ a hex, or six rotor design, and are equipped with either a DJI NAZA, 

WooKong-M, or A-2 flight controller. For brevity, each controller’s manual is available for 

download at the following web sites:

http://www.dji.com/product/a2/download

http://www.dji.com/product/wookong-m/download

http://www.dji.com/product/naza-m-v2/download

The DJI F550 is a kit built, high strength frame design, equipped with six 10”

rotors driven by Lithium Polymer (Li-Po) battery powered electric motors. The F550

utilized by Drone Consultants LLC weighs 5.6 pounds total with Go-Pro Hero camera, 

gimbal, DJI NAZA-M V-2 or WooKong-M controller, video transmitter and 14-volt,

8000mAh, 4-cell Li-Po battery - and has a diagonal dimension of 550mm or 1.8’.

http://www.dji.com/product/flame-wheel-arf
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The DJI S-800 Spreading Wings hexacopter is equipped with a DJI A-2 flight 

controller and is larger than the F550 with diagonal dimensions of 1000mm x 1080mm 

by 500mm tall. Empty weight of the frame is 2.6kg or 5.7 pounds and the motors are 

powered by a 22-volt, 6-cell Li-Po battery. This machine is capable of carrying a larger 

payload to include a high resolution 20-mexapixel camera or a broadcast quality high 

definition (HD) camera/video recorder.

http://www.dji.com/product/spreading-wings-s800/spec

The DJI S-900 Spreading Wings (also equipped with the DJI A-2 flight controller)

is a highly portable (folding arms), powerful aerial system designed for demanding 

filmmakers. Because of its sturdy carbon fiber frame and tubular arm design this 

machine actually weighs less than its predecessor; the S-800.

http://www.dji.com/product/spreading-wings-s900/spec

The DJI Phantom 3 Professional quadcopter has a maximum gross weight of 

approximately 2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of 

approximately 16.4 fps. The DJI Phantom 3 Professional ships as a ready-to-fly 

package and is amazingly stable in winds up to 15mph.

http://www.dji.com/product/phantom-3/download

All of the above models weigh less than 55 pounds, have the capability to be 

programmed with a maximum flying height of 122 meters or 400’ AGL and maximum 

distance to limit the radius of the distance it can fly from the operator. Each system also 

has a failsafe function of the autopilot system. When communications between the flight 

controller and the operator’s GCS is lost, the system will automatically trigger the 

Return-to-Home feature. The machine automatically flies back to the original takeoff 

point, descends vertically, and lands safely.

Drone Consultants LLC agrees to adhere to the following standard Section 333 

limitations and conditions (*except for one requested exception starting on page 9)

when conducting commercial operations under an FAA issued exemption:

 The sUAS will have a maximum operating speed of no more than 100mph, or 87 

knots (none of the sUAS listed above even begin to approach this speed 

capability).

 Minimum crew for each operation will consist of the sUAS Pilot, the 

Visual Observer (VO) and may include but not limited to a Camera 

Operator.

 Flights will be operated within constant visual line-of-sight (VLOS) of

the Pilot in Command (PIC) and Visual Observer (VO).

 Prior to each flight, the PIC will conduct a pre-flight inspection and 

determine the sUAS is in a condition for safe flight. The pre-flight 
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inspection must account for all potential discrepancies, e.g., 

inoperable components, items, or equipment. If the inspection

reveals a condition that affects the safe operation of the sUAS, the 

aircraft is prohibited from operating until the necessary maintenance

has been performed and the sUAS is found to be in a condition for 

safe flight.

 The operator must follow the sUAS manufacturer’s maintenance, 

overhaul, replacement, inspection, and life limit requirements for the 

aircraft and aircraft components.

 Each sUAS operated under this exemption must comply with all 

manufacturer safety bulletins and firmware updates.

 Maximum flight time for each operational flight will be 20 minutes. 

Flights will be terminated at 25% battery power reserve or 20 minutes

of flight time whichever occurs first.

 Flights will be operated at an altitude of no more than 400 feet Above

Ground Level (AGL).

 The sUAS pilot will be the designated Pilot in Command (PIC) and hold 

an FAA Pilot’s License with a Third or higher Class Medical Certificate

or valid state drivers’ license. 

 A briefing will be performed regarding the planned sUAS

operations prior to each flight and will consist of all planned

production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) 

only and may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

 If operations will be within a 5 mile radius of the geographic

center/Airport Reference Point (ARP) of a tower controlled or

uncontrolled airport the respective airports will be contacted advising 

them of the estimated flight time, flight duration, elevation of flight and 

other pertinent information.

 The PIC and VO will have been trained in operation of sUAS and 

receive up-to-date information for the particular sUAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all 

times.
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 The UAS will have the capability to abort a flight in case of 

unpredicted obstacles, weather, or emergencies.

 All flight operations will be entered into a log book, with all records

available for viewing by governing agencies.

 Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by

the exemption must be reported to the FAA's UAS Integration 

Office (AFS−80) within 24 hours. Accidents must be reported to 

the National Transportation Safety Board.

 All operations over private or controlled-access property shall be 

conducted with permission from the property owner/controller or 

authorized representative. Permission from property

owner/controller or authorized representative will be obtained for

each flight to be conducted.

 The sUAS may not be operated by the PIC from any moving

device or vehicle.

 The DJI F550, S-800, S-900 and Phantom 3 models that will be 

operated by Drone Consultants LLC will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well 

as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

 The sUAS must remain clear and give way to all manned aviation 

operations and activities at all times.

The Public Benefit from Decreased Congestion of the NAS:

The above described DJI sUAS’s are battery powered and serve as a safe, 

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain 

aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of the described DJI sUAS’s would reduce 

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. 

The listed DJI sUAS’s do not require an airport to takeoff or land. Likewise, a reduction 

of manned aircraft conducting aerial video and photography missions would result in 

fewer aircraft that must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations.
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The Public Benefit from the Safety and Efficiency of the Listed DJI sUAS’s:

Conducting aerial acquisitions with the described DJI sUAS’s, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the described DJI sUAS’s produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial 

video and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The described DJI sUAS’s, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery 

powered electric motors, rather than an internal combustion engine. 

By using the described DJI sUAS’s to perform aerial acquisitions, the substantial 

risk to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Phantom 3 sUAS for instance (weighing approximately 2.8 pounds at their 

maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on 

board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned helicopter that typically conduct similar 

operations (weighing approximately 3,200 pounds with a rotor diameter of 39.7 feet, and 

a fuel capacity of 91 gallons, and burn 26 gallons per flight hour). 

Performing Aerial Video and Photography Operations with the DJI sUAS’s Will 

Benefit the Economy:

In addition to being safe and efficient, sUAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of sUAS 

will allow United States based companies, like Drone Consultants LLC, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising 

cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory 

actions phasing out leaded aviation fuels, U.S. owned and operated companies must 

adopt new and alternative technology in order to remain competitive. Operating battery 

powered sUAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

By operating sUAS, companies such as Drone Consultants LLC can remain 

competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use of DJI sUAS’s, 

provides a stable workforce that increases consumer spending; improves local, state, 

and federal tax revenues; and allows companies to invest in research and development 

in order to remain competitive both in the United States and abroad. 
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Basis for Exemption and Regulations from Which the Exemption is Requested:

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Drone Consultants LLC operation of the 

listed DJI sUAS models meets the conditions of FMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Drone Consultants LLC requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Drone Consultants LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Drone Consultants LLC will use experienced personnel 

or technicians to perform maintenance, alterations, or preventive maintenance on the 

sUAS using the methods, techniques, and practices prescribed in the operating 

manuals for each DJI model. Furthermore, Drone Consultants LLC will document and 

maintain all maintenance records for each DJI sUAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges and limitations: Pilot in command, is requested by Drone Consultants 

LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or 

higher level certificate, as well as an airman medical certificate, and who has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC 

is able to safely operate the DJI Phantom sUAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Drone Consultants LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI F550, S-800, S-900 and Phantom 3 sUAS do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Drone Consultants LLC submits that they will ensure that the DJI sUAS models 

mentioned above is in an airworthy condition, prior to every flight, by determining that 

the sUAS are in compliance with all DJI Operator/Instruction manuals, and that the 

aircraft are in a condition for safe flight. Drone Consultants LLC also ensures all 

firmware upgrades are immediately installed in each model as quickly as possible after 

being released by DJI.

Drone Consultants LLC also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the listed DJI models will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI F550, S800, S-900 and Phantom 3 sUAS will be provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the sUAS to the GCS for active monitoring of the flight path. This 

altitude information, combined with Drone Consultants LLC’s operation of the DJI

sUAS models within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 
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Drone Consultants LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Drone Consultants 

LLC submits that safety will not be affected by operation of each listed DJI sUAS during 

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power to fly for a total duration of approximately 15 to 20 minutes. The DJI 

NAZA and A2 flight controllers on the F550, S-800 and S-900 models display the 

battery voltage on the operator’s FPV screen. The DJI Phantom 3 displays the 

percentage of battery remaining on the operator’s smart phone or tablet. Small battery 

power alarms are also available to give the operator an audible warning of low battery 

power. The DJI Phantom 3 model will revert to return-to-home (RTH) mode if battery 

power goes below a certain threshold - which can be set by the operator.

*Drone Consultants LLC additionally seeks an exemption from Section 91.205 

(Visual Flight Rules: Night) and Section 91.209 (Aircraft Lights) to fly the DJI Phantom 3 

(and only the Phantom 3 because of its unique LED lighting design) at night up to 200 

feet AGL - without having to request permission to fly each time from the FAA FSDO

closest to proposed area of operations. 

Petitioner has worked the night shift for the majority of his 25-year police pilot

career and has logged over 4500 hours of night flight. Petitioner has also logged 281 

hours utilizing Night Vision Goggles. Petitioner is intimately familiar with all aspects of 

flying at night, to include depth perception issues and common visual illusions all pilots 

who fly at night experience. Most of the petitioner’s night flying experience has been 

gained flying at altitudes below 1000’ AGL. Many hours were logged flying at either napof-the earth or tree-top level – where constant vigilance must be maintained to avoid 

uncharted or unlit obstructions.

sUAS can be flown at night, and it can be done with a reasonable level of safety. 

The common perception is that sUAS cannot be seen by manned aircraft or avoided at 

night. Petitioner contends that most sUAS equipped with some form of Light-Emitting 

Diode (LED) system are more visible at night than they are during the daytime;

observed from either below and above. This is especially true of the DJI Phantom 3. Its

unique LED system makes the machine very easy to see and fly at night. The human 

eyeball keys in on movement, especially a moving light source at night. Because of this, 

the Phantom 3 is highly visible at night and can be kept in constant VLOS at a farther 

slant range than during daylight hours. The bright LED status lights (two constant red

lights to the front and two flashing green to the back on the underside of the 

quadcopter’s arms) enables the operator to maintain proper flight orientation at all times 

at night.
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DJI Phantom 3 Professional Quadcopter (photo © Mark Colborn)

Night operations will be limited to VLOS and conducted in a relatively tight

operational area very close to the ground (below 200’ AGL). The main objective of

green and red navigation lighting on aircraft is for determining right-of-way. Since a 

sUAS most likely won’t be flying in a constant direction while operating in such a small 

operational area, conventional positional lighting would be ineffective or unnecessary.

Section 205 (c) (3) calls for an approved aviation red or aviation white anti-collision light 

system for night flight. Since there are no approved aviation red or white anti-collision

lights for sUAS, the only suitable alternative are small, low powered (but highly visible) 

clear or red flashing LEDs. These small flashing LEDs could conceivably be installed on 

the Phantom 3, but their installation could interrupt the reception of the critical GPS 

signal. Their installation could also degrade radio contact between the operator’s GCS 

and the sUAS’s flight controller. The Phantom 3 ships as a ready-to-fly package - any 

such after-market additions could feasibly turn the operator into a test pilot - likely 

voiding the manufacturer’s warranty. The petitioner, however, recognizes that the

machine must be highly visible to avoid a potential, yet highly unlikely, collision with a 

manned aircraft. The Phantom 3’s existing system of bright solidly illuminated red and

flashing green LEDs provide an equivalent or higher level of lighting and safety to that 

provided by conventional manned aircraft lighting required by Sections 91.205 and

91.209.

Section 91.205 (c) (4) requires one electric landing light if operating for hire. 

Again, this is an unnecessary requirement since no passengers are being carried. An 

equivalent level of safety is provided by the solidly illuminating red LEDs on the 

Phantom 3 which provide sufficient illumination of the ground for night takeoffs and 

landings.
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Also, since sUAS flight operations under this exemption will be prohibited within 

5-miles of an operational airport (without permission) and in controlled or restricted

airspace, the chances of a conflict with a manned airplane or helicopter flying at night 

below 200’ AGL are statically rare. Even if an emergency medical services helicopter 

were to arrive over the same area where a sUAS is operating VLOS, the sUAS operator 

would have plenty of time to land the craft before the helicopter finished a high altitude 

reconnaissance, slowed and began their vertical approach. A 200’ AGL night restriction 

would also de-conflict by 200 feet or more any sUAS operations from police helicopter

traffic (normal police helicopters fly patrols at 600’ AGL at night, but occasionally 

descend to 400’ AGL during a suspect search or to check a rooftop for burglars). 

The DJI Phantom 3 is equipped with an outstanding 4K quality camera that 

provides excellent light gathering capability in low light conditions. However, this 

camera, like all cameras, needs some light to render an acceptable broadcast quality

image. Therefore, Drone Consultants LLC will never fly a sUAS in “dark night” 

conditions. There will always have to be street lamps, a partial or full moon, or other city 

lights providing illumination in the close proximity to any planned operations. This level 

of illumination of the night sky would be a necessity to see and safely avoid any 

prospective obstacles such as power lines or unlit cell towers.

A daylight restriction only for commercial sUAS operations is unnecessary and 

would hinder Drone Consultants LLC’s plans to engage in contract electronic news 

gathering and other prospective aerial filming operations at night. 

Drone Consultants LLC Requests that the Publication and Comment Procedures 

be Waived in Accordance with 14 C.F.R. § 11.87.

Notwithstanding the night flight exemption request above, this petition is identical 

to Section 333 exemptions granted previously. If a local FAA FSDO can grant

commercial sUAS night flight waivers on a case-by-case basis, the Administrator, 

through the UAS Integration Office (AFS-80), most certainly has the authority to grant 

this exemption. Given the small size of the sUAS involved and restricted sterile 

environment within which the petitioner will be allowed to operate, the petitioner falls 

squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of sUAS to 

commence immediately. The approval of this application presents no national security

issues. Regarding the level of safety surrounding the proposed operations and the 

public benefit, reduction in environmental impacts, including but not limited to reduced

emissions and noise, the grant of the requested exemption is in the public interest.

Accordingly the applicant, Drone Consultants LLC, respectfully requests AFS-80 to 

determine that good cause exists to dispense with publication of the summary of this 

petition in the Federal Register and grant the requested exemption without delay. 
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Sincerely,

Mark Colborn

President 

Drone Consultants LLC

2406 York Minster Ct.

Arlington, TX 76006

817-640-7052

kd5elf@tx.rr.com