U.S. Department ofTransportation DocketManagement System 1200 NewJerseyAve., SE Washington DC 20590 Re: Section333 ExemptionDocketNo.**FAA-2015-1244-~** DearMs. Robeson:

Inresponse to you letterrequesting more information concerning my application for operation ofan UnmannedAircraft System. I have included the following:

I, Ted Collins DBAThe Collins Company planto operate two UnmannedAircraft Systems, the PHANTOM 2 Vision+ and a PHANTOM 3 Professional, which are similar (in size, weight and speed) unmanned aircraft (UA, UAS orPHANTOM). The primary difference inthe two is the professional has better communication link and higher resolution camera.

The PHANTOM 2 Vision+ is a quad-copter with a gross weight ofabout 2.83 pounds including battery and propellers. It is equipped with four rotors that are driven by electric motors which is powered bybatteries. The UAhas a maximum airspeed of30 mph. Operating frequency is 5.728 GHz5.85 GHz with a range extender for visual monitoring at 2412-2462MHz

The PHANTOM 3 Professional/ Advanced is also a quad-copter with a gross weight ofabout 2. 82 pounds including battery and propellers. Itis equipped with four rotors that are driven by electric motors which is poweredby batteries. The UAhas a maximum airspeed of33 mph. Operating frequency is 

### 2.400 GHz-2.483 GHz and visual monitoring at

### 2.4GHz ISM

I, Ted Collins DBAThe Collins Company plan to operate these UASs in aerial cinematography and photography to enhance real-estate listings, ae:r:ial surveys ofland, roofs, towers and otherremote structures and properties which could benefit from an aerial viewfor their planning offuture expansions, repairs and/or advertising of products orbusiness. For most businesses and realtors in the
area, standard aerial photography has beenvery cost prohibitive. The economic impact ofbeing able to assist a business using aerial photography wouldbe substantial.

The use ofthese UASs inthe above named applications greatly reduces risk to the public and property

as there is no fuel carriedbythe Phantom 2 Vision+ and the Phantom 3, aircraft noise is greatly reduced as opposedto a standard aircraft orrotorcraft both ofwhich require repeated passes or extended lengths ofhovertime to accomplish the same task as the Phantoms can do in only a few minutes. The Phantoms only weigh about 3 pounds each and are by far, a much smallerhazardto persons or property than a standard aircraft orhelicopter inthe event ofa catastrophic in-flight failure.

Being a firefighter for 34 years and a Private Pilot for 17 years, there is no higher priority for me, other than the safety ofthe public and property. Note: for the foreseeable future, I will be the PIC

The Collins Company makes the following representations ofmy operation in whichto abide byto

ensure these exemptions ifgranted, will provide a level ofsafety at least equal to existing rules: The Phantom 2 Vision + andPhantom 3 will only be operatedby a private pilotwith atleast a 3rdclass airman medical certificate orvalid drivers license. I have over45 documented hours flight time and any future PIC will have completed at a minimum, 25 hours ofdocumented flight time usingthe Phantom 2 Vision 

### + and/or Phantom 3 withthe focus being:a) Collision avoidance b) Loss ofC2 link procedures as outlined inthe Operators manual for the Phantom 2 Vision+ v3. c) Identification ofinflighthazards i.e. aerial wires, birds inthe area, changing weather etc d) Estimating distance from objects, persons, vehicles and vessels. e) Communication withthe spotter(s) f) Completedthe DJI Phantom 2 Vision+ Phantom 3 pilot training guide maneuvers and skills. g) The ability to recognize persons or objects that are not part ofthe intended and permitted part ofthe project that enterthe 500 foot operational area unless such persons or objects

are deemed permitted bythe owner or controller ofthe property or area and the PIC makes a safety assessment ofthe risk ofoperating closer and it does not pose undue or significant risk. h) The ability to quickly and safely land the Phantom 2 vision + or Phantom 3 Profession! inthe event ofintrusion into the safe zone.
1.) A complete pre-flight checkby the PIC ofthe UA's physical condition, i.e. props, landing gear, condition indicator lights, battery capacity and overall airframe condition. Ifany ofthe above

are not within the manufacturers minimum standards no flight will take place. 2.) Written documentation ofeach physical inspection and repairs ifany, bythe PIC (pilot in command) will be kept withthe UA and will be on-site and available for review. 3.) Software in relationto the UA's operation will be checked for proper function. The most current DJI VisionAPP (for PhantomVision+) and DJI PilotAPP (for Phantom 3) and the current firmware will be installedto assure the most up to date safety features. One key component is class airspace avoidance, failure to fly within. 4.) Priorto every flight, the compass onthe UAs will be calibrated as to ensure precision location. 5.) The Collins Company will ensure the altimeter setting onthe Phantom 2 vision + andPhantom 3 is that ofAGL (above ground level) rather than GPS orbarometric pressure derived settings. 6.) Every safety feature offeredthrough the DJIAPPs will be enabled for every flight, every time. Abriefsynopsis ofthose safety features: a) Enable ground station

• Use ofthe DJI Ground Station GUI (graphical user interface)

• Ofparticular interest are the following: 

## ° Flight attitude and radar function 

## ° Flight parameters, RTH (return to home) altitude, horizontal distance from home point, altitude-vertical distance from home point, speed-horizontal flying speed. 

## ° FlightBattery Level indication

0 There is a built in pre-flight checklist within the DJI visionAPP which is completed prior to each flight.

0 The Collins Company's UASs will always fly with parameters displayed in order to assist in maintaining safe distances from persons and objects and to adhere to the flight plan. b) Compass calibration c) Lowbattery auto return home d) Dynamic home point e) CurrentRTH (return to home) altitude (AGL) f) Lowbattery alarm g) Flight will only occur with 7 satellites capturedThe Collins Company will operate with a minimum of(1) one spotter for every flight. They will be familiarized with the Phantom 2 Vision+ and/or Phantom Vision 3, their abilities according to the operators' manual as well as the abilities ofPIC. Spotters will betrained in-house prior to being allowed onthe flight line. Training will consist of, at a minimumthe following: 1. The ability to roughly identify minimum distance from objects 2. The ability to quickly recognize unusual flight maneuvers/attitudes ofthe UAS 3. The ability to communicate withthe PIC the visual limitations and to never let the UAout of the visual line ofsight (VLOS) ofthePIC andthe spotter(s). 4. The ability to recognize persons or objects that are not part ofthe intended and permitted part of the projectthat enter the 500 foot operational area unless such persons and objects are deemed permitted by the owner or controller ofthe property or area and the PIC makes a safety assessment ofthe risk ofoperating at a closer range and it does not pose undue or significant risk to those persons or objects. 5. The ability to recognize persons or objects that are not part ofthe intended and permitted part of the projectthat enter the 500 foot operational area unless such persons and objects are deemed permitted bythe owner or controller ofthe property or area andthe PIC makes a safety assessment ofthe risk ofoperating at a closer range and it does not pose undue or significant risk to those persons or objects. 6. The training will take place under strict, safe conditions away from persons or large obstacles. i.e. large open fields.

Priorto each flight, the PIC and the Spotter(s) will perform a pre-flightbriefing detailing the estimated flight distance, estimated flight levelAGL and the goal ofthe particular flight. Eachpreflightbriefing will be documented by the PIC to include flight details, pilot name, spotter(s) name, weather details, time and date.

Written and/or verbal consent will be obtained from the person/business requesting the flight.

I, Ted Collins DBAThe Collins Company believe that given the size, weight, speed, and limited operating area associated with the Phantom 2 Vision+ and Phantom 3, requests an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and§ 91.203 (a) and (b) (Certifications required), subjectto certain conditions and limitations, is warranted and meets the requirements for an equivalent level ofsafety under 14 CFRpart 11 and Section 333 ofP.L. 112-95 (Section 333).

I request exemption from§ 45.23 Marking ofthe aircraft. The Phantom 2 Vision+ and Phantom 3 are very small. Minimum sized lettering and wording are difficultto place onthe two similarPhantoms. I will however affix identification onthe unit which will contain contact information for the company in

case ofaircraft loss.

I request anexemption from§§ 91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) Maintenance inspections and feel it shouldbe granted since they only apply to aircraft with an airworthiness certificate. I have developed maintenance inspections and documentation methods for the Phantom 2 Vision + and Phantom Vision 3 professional from personal experience as well as the manufacturer's user manual.

UAS Pilot in Command (PIC) Under§ 61.113 (a) and (b) private pilots are limited to non-commercial operations. I will only use, at a minimum a pilot with a private pilot license with a current 3rd class airmen medical certificate or valid drivers license. Under current regulations, civil operations forcompensation orhire require a PIC holding a commercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in accordance with pertinent parts of 14 CFR 61.113(a) and (b), a pilot holding a private pilot certificate cannot act as a PIC ofan aircraft for compensation or hire unless the flight is only incidental to a business or employment. "However, in Grant ofExemptionNo. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations intheNAS or present a hazard to persons or property onthe ground." I request that an exemption allowing me,a private pilot or a future PIC employed by myselfDBAThe Collins Company be allowedto be the PIC ofthe Phantom 2 Vision+ and/or Phantom 3 for compensation similar to the grant ofexemptionNo.11602 to AstraeusAerial.

I request relieffrom 

### § 91.119(c) because the aircraft will be operated at altitudes below 300 feetAGL. Section 91.119(c) states that no person may operate an aircraftbelowthe following altitudes: over other than congested areas, an altitude of500 feet above the surface, except over open water or sparsely populated areas. Inthose cases, the aircraft may notbe operated closerthan 500 feet to any person, vessel, vehicle, or structure. The Collins Company will operate pursuantto the following restrictions related to § 91.119:

• Operate in reasonably safe environments that are closely monitored by ground assistants and signage placed in locations that wouldbe consideredreasonable locations for pedestrians, vehicles or vessels to enterthe area.

• Not operate within 5 miles ofairports and congested areas without permission. Congested areas will be definedbyVFR charts as well as by contactingthe local FSDO (flight standards district office)

• Conduct all operations under The Collins Company's guidelines contained inthe operating documents and will analyze flight data and other sources ofinformation such as the manufacturer's website to constantly update and enhance safety.

• Contactrespective airports ifoperations will be within 5 miles to advise them ofestimated flight time, flight duration, elevation offlight and other pertinent information deemed important by the airport. Always obtain all necessary permissions prior for operation. Permissions include but are not limitedto a (COA) and a request for a (NOTAM) as well as permission from the property owner orperson in control ofthe property and when practical will be in writing and kept onfile for 2 years for review. Ifit's not possible to obtain written permission, the PIC will document inwriting how permission was obtained i.e. phone call with date, time andparty information.

I request relieffrom 14 CFR 91.121 Altimeter Settings. DJI'sPhantom 2 Vision+ andPhantom 3 have

a barometric altimeter and GPS derived altitude capabilities. The FAArequires any altitude reported to ATC to be in feetAGL. I, DBAThe Collins Company will setthe altimeter onthe Phantom 2 Vision 

### + to zero feetAGL rather than local barometric pressure or field altitude before flight.

I request relieffrom 

### § 91.151 (a) Fuel requirements for flight inVFR conditions based onthe following:

No fuel is used inthe Phantom UAS but it is battery operated. Batteries have, in my experience about 18 minutes ofquality flying time. Inthe interest ofsafety, I generally land with 35% ofbattery remaining which gives about 10 minutes offlying time perbattery. The Phantom UAS has an audible battery state warning system. The Collins Company will always follow the manufactures minimum battery warning which is 30% remaining. There is also an on-screen warning of, not enoughbattery to return to home, ifflight distance has exceededbattery capacity. In this event, an emergency landingwould be made as soon as safe and practical. BothPhantom UAS also have an automated function which results in immediate landing when a lowbattery is detected. Researching previous relief requests, reliefhas been granted for manned aircraft to operate at less than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similarUAS-specific reliefhas been granted in exemptionNos. 8811, 10808, and 10673 for daytime, VFR conditions. The Collins Company will adhere to all VFR minimums as well as VMC conditions when planning and/or executing any flights. There is little purpose for aerial video or pictures ifthe weather is less than desirable. Following VFR minimum standards will at least ensure a safe flight. Wind and forecast weather will be a key in deciding suitable conditions. Local weather canbe attained from the nearest airport by usingAWOS and/or on scene. No flight will take place inany conditionthat would potentially be outside ofthe Phantom 2 Vision+ and/or Phantom 3 capabilities in wind. The Collins Company will always fly within its 30% minimum remainingbattery life at its first intended landing point.

Ifrequired, I will obtain anAir Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations. I will also request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. The UAS will always be Line ofsight operation and see and avoid.

Ifthere are any areas that have not been addressed, please contact me for additional information.
Sincerely,

Ted Collins DBA The Collins Company 3426 JumillaWay Sacramento, CA 95834 (707) 372-6820 thecollinscompany@sbcglobal.net ortcollins@fairfield.ca.gov