US Department ofTransportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591 Dear Sir or Madam: David Eckert 437 Stagecoach Drive Canyon Lake, Texas 78133 designscapetx@yahoo
.com

830-481-6033 Cell Phone

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the reform act) and CFR Part 11; I David Eckert, owner and operator of Small Unmanned Aircraft Systems (UAS's) request to be exempted from the Federal Aviation Regulations (FAR) listed below so that I, David Eckert 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. I David Eckert am an Interior and Exterior Home Design Professional and photographer with Designscape Interiors and Texas Photography Concepts in Canyon Lake, Texas. I am requesting exemption from regulations listed below to perform aerial photography of Real Estate and Landscape. All operations will be performed with the public's safety and right to privacy safeguarded at all times. David Eckert's UASs is a rotorcraft weighing less than 55 pounds including payload (The DJI Phantom 3 Professional Quad Copter). It operates at a speed of less than 50 knots and has the capability to hover and move in the vertical and horizontal plane simultaneously. It has an auto return to launch point when the 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 ofthe nation airspace, public nor the environment
. I, David Eckert, respectfully request the grant of an exception to the following specific sections ofthe 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).I David Eckert 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 David Eckert 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 integration ofthese UASs are expressly contemplated by the Reform Act I, David Eckert, would like to operate it's light weight 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 ofTransportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 of the reform Act. In making this determination, the Secretary ofTransportation 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 ofthe following. The UASs size, speed, weight and operational capability Operation ofthe UASs in close proximity to airports and populated areas Operation ofthe UASs within visual line of sight ofthe operator
DJI Phantom 3s are rotorcrafts 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 ofthe operator within the protected fight area and t 200 feet AGL or less
. These will not present a hazard to the national airspace nor the public.

The very small nature ofthese 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 333ofthe 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 request that the FAA grant the request exemption without delay.Eckert, The following will be considered as the binding limitation on operations of David
1. Flights will only occur i n the day time hours, 2
. Flights will be operated in the line of sight ofthe operator (PIC) and obser ver, (VSO) 3
. Flights will be terminated at any time weather and wind deteriorate to " unsafe for flight" by manufacturers recommendation s. 4
. The UASs will weigh less than 55 lbs. 5 . Flights will be operated at 200 Feet AGL or less. 6
. Crew will be at a minimum of Operator (PIC} and an Observer and / or Camera operator (VSO)
. 7. Operator and crew will remain in contact during the fl ight operation. 8
. The UASs operator will perform a check ofthe flight area and make certain ofthe s

afety of all persons in the area . 9
. Consent will be obta ined from all pe rsons within the video capabil ities ofthe units to further reduce the chance ofviolating anyone' s privacy. 10. All required FAA clearances, will be obtained and distances from airports s trictly observed
. 11. All UASs will have the capability to return automatically to the operator in a safe manner, with the auto return function checked and worki ng. 12
. When operated i n conjunction with fishing vessels in the gulf, a chase boat will be assigned to operate the UASs at a safe dis tance from the main fishing boat
. 13
. Flights will only operate during VFR c onditions. 14. UASs have a function on the control to tell the operator the distance from the operator and the battery power remaining. 15
. The Flight team w i ll communicate by voice, and if needed the us e oftwo way radios if the area or terrain is too big to clearly hear the vo ice of all team members. 16
. UASs will be used to video private outings and functions, boating, j et skiing, kayaking, fishing trips i n the gulf area and sporting events at a safe distance
. 17. When operating over or near water the UASs will be equ ipped 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 requ i rements for procurement of necessary certificates in relation to FAR 91.203(a)(1)
. The size, weight, and defines area of operation s for David Eckert' s UASs permits exemption from Part 21 because they meet an equivalent level of safety pursuant to Section 333 ofthe Reform Act
. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC4470(f) and Section 333 ofthe Reform Act
. Both pieces of legislation perm it the FAA to exempt UASs from the airworthiness certificates in consideration of weight, size, speed,maneuverability and proximity to areas such as airports and dense populations. David Eckert' s UASs meets or exceeds each ofthese 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. 14CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Because the UASs in unmanned and will not carry a pilot or passengers, the proposed operations can achieve a high level of safety of operation without the required pilot license. 14 CFR 91.203 (a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. 14 CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate
. As no such certificate will applicable in the form contemplated by FAR' 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 ofthe UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Designscape Interiors and Texas Photography Concepts. 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
. Designscape Interiors and Texas Photography Concept will only operate its UASs at or below 200 AGL. 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 ofconventional and traditional aircraft or rotorcraft weighing far more than 50 lbs
., operating below SOOAGL 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. AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use ofthesesmall UASs by David Eckert will give potential sellers of Real Estate of competitive edge in the market place. Granting David Eckert the above exemption will allow for the expansion of UASs systems into the future for the safe conduct offree enterprise and the enjoyment ofthe masses. I, David Eckert, respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption s ought by David Eckert pursuant to the Federal Aviation Act, 85 P.l. 726 (1958} as amended (the ACT}. Sincerely,

Designscape Interiors and Texas Photography Concepts