U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Section333 ExemptionDocketNo. FAA-2015-1244-~ 

Dear Ms. Robeson: 

In response to you letter requesting more information concerning my application for operation of an 

Unmanned Aircraft System. I have included the following: 

I, Ted Collins DBA The Collins Company plan to operate two Unmanned Aircraft Systems, the 

PHANTOM 2 Vision+ and a PHANTOM 3 Professional, which are similar (in size, weight and speed) 

unmanned aircraft (UA, UAS or PHANTOM). The primary difference in the two is the professional has 

better communication link and higher resolution camera. 

The PHANTOM 2 Vision+ is a quad-copter with a gross weight of about 2.83 pounds including 

battery and propellers. It is equipped with four rotors that are driven by electric motors which is 

powered by batteries. The UA has a maximum airspeed of 30 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 of about 2. 82 

pounds including battery and propellers. It is equipped with four rotors that are driven by electric 

motors which is powered by 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 DBA The Collins Company plan to operate these UASs in aerial cinematography and 

photography to enhance real-estate listings, ae:r:ial surveys of land, roofs, towers and other remote 

structures and properties which could benefit from an aerial view for their planning of future 

expansions, repairs and/or advertising of products or business. For most businesses and realtors in the 

area, standard aerial photography has been very cost prohibitive. The economic impact of being able to 

assist a business using aerial photography would be substantial. 

The use of these UASs in the above named applications greatly reduces risk to the public and property 

as there is no fuel carried by the Phantom 2 Vision+ and the Phantom 3, aircraft noise is greatly 

reduced as opposed to a standard aircraft or rotorcraft both of which require repeated passes or 

extended lengths of hover time 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 smaller hazard to 

persons or property than a standard aircraft or helicopter in the event of a 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 of the public and property. Note: for the foreseeable future, I will be the PIC 

The Collins Company makes the following representations of my operation in which to abide by to 

ensure these exemptions if granted, will provide a level of safety at least equal to existing rules: The 

Phantom 2 Vision + and Phantom 3 will only be operated by a private pilot with at least a 3rd class 

airman medical certificate or valid drivers license. I have over 45 documented hours flight time and any 

future PIC will have completed at a minimum, 25 hours of documented flight time using the Phantom 2 

Vision + and/or Phantom 3 with the focus being: 
a) Collision avoidance 

b) Loss of C2 link procedures as outlined in the Operators manual for the Phantom 2 

Vision+ v3. 

c) Identification ofinflight hazards i.e. aerial wires, birds in the area, changing weather etc 

d) Estimating distance from objects, persons, vehicles and vessels. 

e) Communication with the spotter(s) 

f) Completed the DJI Phantom 2 Vision+ Phantom 3 pilot training guide maneuvers and 

skills. 

g) The ability to recognize persons or objects that are not part of the intended and permitted 

part of the project that enter the 500 foot operational area unless such persons or objects 

are deemed permitted by the owner or controller of the property or area and the PIC 

makes a safety assessment of the risk of operating 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! 

in the event of intrusion into the safe zone. 

1.) A complete pre-flight check by the PIC of the UA's physical condition, i.e. props, landing gear, 

condition indicator lights, battery capacity and overall airframe condition. If any of the above 

are not within the manufacturers minimum standards no flight will take place. 

2.) Written documentation of each physical inspection and repairs if any, by the PIC (pilot in 

command) will be kept with the UA and will be on-site and available for review. 

3.) Software in relation to the UA's operation will be checked for proper function. The most 

current DJI Vision APP (for Phantom Vision+) and DJI Pilot APP (for Phantom 3) and the 

current firmware will be installed to assure the most up to date safety features. One key 

component is class airspace avoidance, failure to fly within. 

4.) Prior to every flight, the compass on the UAs will be calibrated as to ensure precision location. 

5.) The Collins Company will ensure the altimeter setting on the Phantom 2 vision + and Phantom 

3 is that of AGL (above ground level) rather than GPS or barometric pressure derived settings. 

6.) Every safety feature offered through the DJIAPPs will be enabled for every flight, every time. 

A brief synopsis of those safety features: 

a) Enable ground station 

• Use of the DJI Ground Station GUI (graphical user interface) 

• Of particular 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. 

° Flight Battery 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) Low battery auto return home 

d) Dynamic home point 

e) Current RTH (return to home) altitude (AGL) 

f) Low battery alarm 

g) Flight will only occur with 7 satellites captured 
The 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 of PIC. Spotters will be trained in-house prior to being 

allowed on the flight line. Training will consist of, at a minimum the following: 

1. The ability to roughly identify minimum distance from objects 

2. The ability to quickly recognize unusual flight maneuvers/attitudes of the UAS 

3. The ability to communicate with the PIC the visual limitations and to never let the UA out of 

the visual line of sight (VLOS) ofthe PIC and the spotter(s). 

4. The ability to recognize persons or objects that are not part of the intended and permitted part of 

the project that enter the 500 foot operational area unless such persons and objects are deemed 

permitted by the owner or controller of the property or area and the PIC makes a safety 

assessment of the risk of operating 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 project that enter the 500 foot operational area unless such persons and objects are deemed 

permitted by the owner or controller of the property or area and the PIC makes a safety 

assessment of the risk of operating 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. 

Prior to each flight, the PIC and the Spotter(s) will perform a pre-flight briefing detailing the estimated 

flight distance, estimated flight level AGL and the goal of the particular flight. Each preflight briefing 

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 DBA The 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), 

subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent 

level of safety under 14 CFR part 11 and Section 333 ofP.L. 112-95 (Section 333). 

I request exemption from§ 45.23 Marking of the aircraft. The Phantom 2 Vision+ and Phantom 3 are 

very small. Minimum sized lettering and wording are difficult to place on the two similar Phantoms. I 

will however affix identification on the unit which will contain contact information for the company in 

case of aircraft loss. 

I request an exemption from§§ 91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) 

Maintenance inspections and feel it should be 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 for 
compensation or hire 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 of an aircraft for compensation or hire unless the 

flight is only incidental to a business or employment. "However, in Grant ofExemption No. 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 in the NAS or present a hazard to persons or 

property on the ground." I request that an exemption allowing me,a private pilot or a future PIC 

employed by myselfDBA The Collins Company be allowed to be the PIC of the Phantom 2 Vision+ 

and/or Phantom 3 for compensation similar to the grant of exemption No.11602 to Astraeus Aerial. 

I request relief from § 91.119( c) because the aircraft will be operated at altitudes below 300 feet AGL. 

Section 91.119( c) states that no person may operate an aircraft below the following altitudes: over other 

than congested areas, an altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. The Collins Company will operate pursuant to 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 would be considered reasonable locations for pedestrians, 

vehicles or vessels to enter the area. 

• Not operate within 5 miles of airports and congested areas without permission. Congested areas 

will be defined by VFR charts as well as by contacting the local FSDO (flight standards district 

office) 

• Conduct all operations under The Collins Company's guidelines contained in the operating 

documents and will analyze flight data and other sources of information such as the 

manufacturer's website to constantly update and enhance safety. 

• Contact respective airports if operations will be within 5 miles to advise them of estimated 

flight time, flight duration, elevation of flight and other pertinent information deemed important 

by the airport. Always obtain all necessary permissions prior for operation. Permissions include 

but are not limited to a (COA) and a request for a (NOTAM) as well as permission from the 

property owner or person in control of the property and when practical will be in writing and 

kept on file for 2 years for review. If it's not possible to obtain written permission, the PIC will 

document in writing how permission was obtained i.e. phone call with date, time and party 

information. 

I request relief from 14 CFR 91.121 Altimeter Settings. DJI's Phantom 2 Vision+ and Phantom 3 have 

a barometric altimeter and GPS derived altitude capabilities. The FAA requires any altitude reported to 

ATC to be in feet AGL. I, DBA The Collins Company will set the altimeter on the Phantom 2 Vision + 

to zero feet AGL rather than local barometric pressure or field altitude before flight. 

I request relief from § 91.151 (a) Fuel requirements for flight in VFR conditions based on the 

following: 

No fuel is used in the Phantom UAS but it is battery operated. Batteries have, in my experience about 

18 minutes of quality flying time. In the interest of safety, I generally land with 35% of battery 

remaining which gives about 10 minutes of flying time per battery. 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 enough battery to 

return to home, if flight distance has exceeded battery capacity. In this event, an emergency landing 
would be made as soon as safe and practical. Both Phantom UAS also have an automated function 

which results in immediate landing when a low battery is detected. Researching previous relief 

requests, relief has been granted for manned aircraft to operate at less than prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been 

granted in exemption Nos. 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 if the 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 can be attained from the nearest 

airport by using AWOS and/or on scene. No flight will take place in any condition that would 

potentially be outside of the Phantom 2 Vision+ and/or Phantom 3 capabilities in wind. The Collins 

Company will always fly within its 30% minimum remaining battery life at its first intended landing 

point. 

If required, I will obtain an Air 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 prior to the operation. The 

UAS will always be Line of sight operation and see and avoid. 

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

Sincerely, 

Ted Collins DBA The Collins Company 

3426 Jumilla Way 

Sacramento, CA 95834 

(707) 372-6820 

thecollinscompany@sbcglobal.net or tcollins@fairfield. ca. gov