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, Waste Control Specialists, LLC (WCSL owner and operator of a Small Unmanned 

Aircraft System (UAS), request to be exempted from the Federal Aviation Regulations (FAR) 

listed below so that WCS 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 

maybe established by the FAA as required by Section 333. 

WCS is a Limited Liability Company that is primarily involved in the storage, treatment and 

landfill disposal of various types of industrial and hazardous waste, including low-level and 

mixed radioactive waste. The facility is located on 14,739 acres of land in a remote area west 

of Andrews, Texas and east of Eunice New Mexico. Of the total acreage, 13,882 acres are 

located in Texas and 857 acres are located in New Mexico. Currently licensed or permitted 

operations are conducted on 1,338 acres located within the Texas portion of the site. WCS is 

headquartered in Dallas Texas. 

Waste Control Specialists is ultimately a subsidiary of Dallas, Texas based Contran Corporation. 

Contran Corporation is a privately owned organization, based in Dallas, Texas that owns or 

financially controls a number of other companies and organizations; some public and some 

private. These organizations are generally industrial in nature. 

WCS' video equipped UASs are rotorcraft weigh less than 55 pounds including payload and will 

be used to take photographic and video of landfill operations. The vehicle is the DJI Phantom 2 

Vision Plus Quad Copter which operates at a speed less than 50 knots and has the capability to 

hover and move in the vertical and horizontal plane simultaneously. The vehicle has an auto 

return to launch point function that activates when battery power is under 25% or when the 

control signal has been lost. The UAS will operate within the line of sight with in a protected 

flight area as described below and at 200 feet AGL or less with an observer located close at 
91.121,91.151,(aL 91.203{a) &(b ),91.405(a),91.407(a)(1), 91.409{a)&(b ). 

WCS 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 WCS 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. WCS UASs meet the definition of "small 

unmanned aircraft" as defined in Section 331 and therefor the integration of these UASs a~~ ,- / 

expressly contemplated by the Reform Act. WCS would like to operate its light weight UA~ 

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. 

WCS's UASs 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. 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 which include 

standard operating procedures, preventative maintenance programs, operator training, 

emergency action procedures, and area notifications. 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 WCS: 
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• 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 with in 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 two-way radios. 

• UASs will be used to take pictures and video of WCS operations, property, and possibly 

future property perimeter security surveillance. 

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 WCS 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. ME Drone Video LLC 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 WCS. 

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 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. 

It allows helicopters to be operated at lower altitudes in certain conditions. WCS will only 

operate its UASs at or below 200AGL. They will be operated on a well defined Area of 

Operation 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 WCS for 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. 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. 

WCS respectfully requests the FAA grant its exception without delay. The FAA has the 

authority to issue the exemption sought by WCS pursuant to the Federal Aviation Act, 85 P.L. 

726 (1958) as amended (the ACT). 

Sincerely, 

Douglas Frenette 

Director of Operations 

Waste Control Specialists, LLC