Waste Control Specialists, LLC 9998 West Highway 176 Andrews, Texas 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, 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 athand as to make voice and/or radio communication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment. WCS 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,(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:• Flightswill only occurinthe daytime hours, • Flightswillbe operated

inthelineof sightof the operator( PIC) and Observer,(VSO) • Flightswillbe terminated

at anytime weather andwind deteriorate

to"unsafe for flight" by manufacturers recommendations, •The UASs will weigh lessthat55 lbs., •Crew willbeataminimum
of operator( PIC) andanobserver and/or camera operator(VSO), •Operator andcrewwill remain
incontact during the flight operation, •The UASs operatorwill perform

acheckof the flight areaandmake certainof the safety of all persons
inthe area, •Consent willbe obtained from all personswithinthevideo capabilities

of theunitsto further reduce the chanceof violating anyone's privacy. •All requiredFAA clearances,willbe obtained and distances from airports strictly observed. •All UASs willhavethe capability
toreturn automatically

tothe operator

inasafe mannerwiththeautoreturnfunction checked and working. • Flightswill only operate

inVFR conditions. •UASs have
afunction onthe controltotell operatorthe distance awayfrom the operatorandits battery power remaining. • Flight teamwill communicate

byvoiceandtheuseof two-wayradios. •UASs willbeusedtotake pictures andvideoof WCS operations, property,and possibly future property perimeter security surveillance. 14CFR part21 Subpart
H: Airworthiness Certificate
14CFR 91.7(a), 91.203(a)(1) Subpart
H, entitled Airworthiness Certificates, setsforth requirements
for procurement

of necessarycertificates

in relation toFAR 91.203(a)(1). The size, weight and defined areaof operations for WCS flights permit exception from Part21because they meetan equivalent levelof safety pursuant
toSection 333of the Reform Act.TheFAAis authorized

to exempt aircraft from the airworthiness certificate requirement under boththeAct (49 USC 4470(f) and Section 333of the Reform Act.Both piecesof legislation permit theFAAto exemptUASs from airworthiness certificates

in consideration

of weight, size, speed, maneuverability
and proximity
toareassuchas airports and dense populations.
ME Drone Video LLC meetsor exceeds eachof these elements Asof March 23,2015theFAAhas stated thatitwill automatically grant
a"blanket" COA for flights atorunder 200AGL to anyUASs operatorwith
asection 333 exemption. 14CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable
for thesamereasonsstated above. The equivalent levelof safetywillbe achieved by maintaining such certifications and registrations

atWCS. 14CFR91.7
(a) prohibits the operation
of anaircraft without anairworthiness certificate.
Asno such certificate willbe applicable

intheform contemplated

byFAR'sthis 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 WCS. 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. 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