730 Eddy Studios, INC

PO. BOX 346

Spring Lake, MI 49456

Andy@730Eddy.com

616-350-5112

October 10th, 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. 

       730 Eddy Studios, INC (a marketing and video production company) is owned by Andrew Atkins, a 

Michigan resident, with a Michigan Drivers license. Andrew Atkins will be the PIC at all times. 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.  

      730 Eddy Studios' UASs (The DJI Phantom 3 and DJI Inspire 1) 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. 

     730 Eddy Studios 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). 

    730 Eddy Studios, INC 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 730 Eddy Studios, INC

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. 730 Eddy Studios, INCs 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. 730 Eddy Studios, INC 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. 

730 Eddy Studios, INCs 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 730 Eddy Studios, INC:

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, video productions 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. 730 Eddy Studios, 

INC 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 730 Eddy Studios, INC 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 730 Eddy Studios, INC 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. 730 Eddy Studios, INC 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 730 Eddy Studios, INC 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. UAS based video production 

will allow for unique angles to improve the dynamic content and allow for further expansion of a Michiganbased business.

730 Eddy Studios, INC  respectfully requests the FAA grant its exception without delay. The FAA has the 

authority to issue the exemption sought by 730 Eddy Studios, INC pursuant to the Federal Aviation Act, 85 

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

Sincerely 

Andrew Atkins

Owner/Creative Director

730 EDDY STUDIOS, INC

PO. BOX 346

Spring Lake MI 49456

Andy@730Eddy.com

616-350-5112