1

November 11, 2015

US Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR Part 11, Wilson 

& Echols LLC requests an exemption from the Federal Aviation Regulations outlined below. Wilson & Echols LLC 

requests exemption in order to allow its use of the DJI Phantom 3 Professional Unmanned Aerial System (UAS) for 

purposes of aerial data collection services, aerial photography, videography, sensing and imaging services, including 

but not limited to aerial photography and videography for commercial and private real estate, television filming, 

news gathering, cinematography, surface mapping for geographic information system purposes, and infrared sensing 

for petrol chemical storage, transportation, transmission lines and infrastructure inspection, so long as such 

operations are conducted within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333 or Section 49 USC § 44701. 

Wilson & Echols LLC is willing to comply with conditions that the FAA has issued in recent Section 333 

exemptions, specifically Exemption 13513 (DT Aerial Photography). Due to this agreement, in addition to the 

strong similarity of Titan Aerial’s operations compared to those already approved for exemption, the FAA should be 

able to summarily process and approve this petition.
2

NAME AND ADDRESS OF THE PETITIONER 

Wilson & Echols LLC 

Attn: Adrien Echols, Christopher Wilson 

Address: 1836 West Davis, Apt 1346, Dallas, Texas 75208

Phone: (254) 291-8043, (254) 291-8864

Email: wilsonecholsllc@gmail.com

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED 

14 CFR § 61.113(a) & (b) 

14 CFR § 91.7(a) 

14 CFR § 91.119(c) 

14 CFR § 91.151(a) 

14 CFR § 91.405(a) 

14 CFR § 91.407(a) (1) 

14 CFR § 91.409(a) (1) & (2) 

14 CFR § 91.417(a) & (b)

The Petitioner also requests exemption from any other regulations the FAA deems necessary in order to operate the 

UAS as described herein.

I. DESCRIPTION OF ACTIVITIES

Wilson & Echols LLC wishes to use the DJI Phantom 3 Professional Unmanned Aerial System (UAS) for purposes 

of aerial data collection services, aerial photography, videography, sensing and imaging services, including but not 

limited to aerial photography and videography for commercial and private real estate, television filming, news 

gathering, cinematography, surface mapping for geographic information system purposes, and infrared sensing for 

petrol chemical storage, transportation, transmission lines and infrastructure inspection under controlled conditions 

in airspace that is limited, predetermined and access-controlled. Safety will be the foremost consideration in all 

operations. 

By operating a small, lightweight aircraft under a strict set of limitations, Wilson & Echols LLC will be able to 

operate UAS in the National Airspace System (NAS) while satisfying the FMRA § 333 requirement to achieve an 

equivalent level of safety when compared to traditional aircraft. Wilson & Echols LLC further believes that its 
3

proposed operations will actually increase the level of safety when compared to traditional, manned aircraft carrying 

combustible fuel.

II. DESCRIPTION OF AIRCRAFT

Wilson & Echols LLC plans to operate a DJI Phantom 3 Professional UAS system. The DJI Phantom 3 Professional 

is a multi-rotor aircraft equipped with an onboard NAZA computer stabilization controller and GPS. The maximum 

loaded takeoff weight of the DJI Phantom 3 Professional is less than 3 pounds and the maximum airspeed is less 

than 30 knots. The DJI Phantom 3 Professional operated by Wilson & Echols LLC will also contain a DJI ground 

control to provide real-time flight telemetry to the Pilot in Command (PIC). Data points include: 

• Power voltage and battery level percentage 

• Distance between aircraft and home point 

• Altitude

• Pitch/roll attitude

• Airspeed 

• GPS status 

• Aircraft nose direction 

• Vertical velocity 

• Azimuth angle 

The NAZA controller and GPS allow the operator to set flight limits restricting the maximum altitude Above 

Ground Level (AGL) and maximum horizontal distance between the home point (takeoff point) and the aircraft. 

While the PIC will always be aware of these factors, the automated geo-fencing technology provides a useful 

redundancy in keeping the aircraft within the Area of Operation (AO) and below the mandated 400ft ceiling. 

III. PILOT IN COMMAND

Section 61.113(a) and (b) prescribes that—

(a) No person who holds a private pilot certificate may act as a Pilot In Command (PIC) of an aircraft that 

is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, 

act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business 

or employment if—
4

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire.

In Grant of Exemption No. 13678 to American Drone Pros, LLC, the FAA determined that a PIC with a private pilot 

certificate operating the American Drone Pros, LLC UAS would not adversely affect operations in the NAS or 

present a hazard to persons or property on the ground. 

Wilson & Echols LLC proposed operation does not differ significantly from the situation described in Grant of 

Exemption No. 13678 to American Drone Pros, LLC. Wilson & Echols LLC plans to operate over property with the 

permission of the land owner/controller while also limiting access to the property during operations. 

Given the similar nature of Wilson & Echols LLC proposed operating environment to that of American Drone Pros, 

LLC and parallel nature of private pilot aeronautical knowledge requirements to those of commercial requirements, 

and the airmanship skills necessary to operate the UAS, Wilson & Echols LLC believes that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for 

the proposed operations. Therefore a PIC holding a private pilot, sport, or recreational certificate and a third-class 

airman medical certificate or driver's license is appropriate for the proposed operations.

IV. ALTITUDE

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft 

below 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. 

Relief from § 91.119(c) is necessary because the aircraft will be operated at altitudes less than 500 feet AGL. By 

definition, the UAS will be operated closer than 500 feet to persons or property. An equivalent level of safety will 

be achieved given the size, weight, speed, and material with which the DJI Phantom 3 Professional is built, as well 

as adherence to the following procedures: 

1. The UAS will not be operated over congested or densely populated areas (defined as open air assemblies 

of persons or other areas where a safe forced landing cannot be accomplished due to risk of endangering 

persons or property on the ground). 

2. Flight operations will be conducted at least 500 feet from all nonparticipating persons (persons other than 

the PIC, Visual Observer (VO), operator trainees or essential persons), vessels, vehicles, and structures 

unless: 
5

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UAS and/or debris in the event of an accident. Wilson & Echols LLC will ensure that 

nonparticipating persons remain under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the UAS, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an undue 

hazard, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 

3. All operations will be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from the land owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

In all situations, the PIC will make a safety assessment of the risk of operating closer than 500 feet to persons, 

vessels, vehicles, or structures and will only undertake the operation if he/she determines that it does not present an 

undue hazard. The FAA has approved similar exemptions in 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11110, and 11153.

V. FUEL REQUIREMENTS

Section 91.151(a) prescribes that no person may begin a flight in an airplane under Visual Flight Rules (VFR) 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed— 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

Relief from § 91.151(a) is necessary because the DJI Phantom 3 Professional will only operate for approximately 25 

minutes per charge, making operation of the aircraft impossible under this section. Safety features of the DJI 

Phantom 3 Professional include low battery warnings at 30% capacity and an automated landing when the battery 

reaches 15% capacity. These features, teamed with the small size and weight of the UAS should more than achieve 
6

an equivalent level of safety. The FAA has approved similar exemptions in 2689, 5745, 10650, 10673, 10808, 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, and 11153. 

VI. AIRWORTHINESS

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition. 

The FAA has found in numerous exemptions that similar UAS operations do not require an airworthiness certificate 

in accordance with 14 CFR part 21, Subpart H. Wilson & Echols LLC proposes that compliance with its operating 

documents be a sufficient means for determining an airworthy condition. Given the size of the aircraft and the 

requirements by which Wilson & Echols LLC has agreed to abide, an equivalent level of safety will be achieved by 

ensuring compliance with the Wilson & Echols LLC /DJI Phantom 3 Professional manuals prior to each flight. The 

FAA has approved similar exemptions in 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, and 

11153.

VII. MAINTENANCE/INSPECTION

Section 91.405(a) prescribes, in pertinent part, that each owner of an aircraft shall have that aircraft inspected as 

prescribed in subpart E of this part and shall, between required inspections, except as provided in paragraph (c) of 

this section, have discrepancies repaired as prescribed in part 43, Maintenance, Preventive Maintenance, Rebuilding, 

and Alteration. 

Section 91.407(a)(1) prescribes that no person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under 

§ 43.7 of this chapter. 

Section 91.409(a) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 

12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 and has been approved for return to service by a person 

authorized by Sec. 43.7 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21.
7

Section 91.417(a) and (b) prescribe, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records 

must include—

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft that are required to be 

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are 

maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:
8

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated 

or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service. 

Wilson & Echols LLC requests an exemption to the above inspection/maintenance Federal Aviation Regulations 

(FARs) and proposes the following maintenance/inspection procedures that will achieve an equivalent level of 

safety: 

1. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited 

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station (GSS) will be included in the preflight 

inspection. All maintenance and alterations will be properly documented in the aircraft records.

2. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. 

The PIC who conducts the functional test flight will make an entry in the aircraft records.

3. The pre-flight inspection will account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents.

4. Wilson & Echols LLC will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

5. Wilson & Echols LLC will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts will be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the 

UAS to service.

6. Each UAS operated under the exemption will comply with all manufacturer Safety Bulletins. 

7. The authorized person will make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

Adherence to the above procedures, as well as others included in the attached documentation (including a preflight 

checklist) should provide more than an equivalent level of safety to the above FARs. The FAA has approved similar 

exemptions in 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, and 11153.
9

VIII. PUBLIC INTEREST

Manned aircraft conducting aerial photography/videography can weigh 6,000 pounds or more and contain one or 

more living souls on board. Wilson & Echols LLC UAS will weigh less than 3 pounds and contain no living crew 

(the PIC and VO being remotely located from the UAS). The limited weight significantly reduces the potential for 

harm to participating and nonparticipating individuals or property in the event of an incident or accident. There is 

no risk to an onboard crew while using a UAS. 

Traditional manned aircraft contain highly-flammable fuel and are at risk of fuel spillage and fire in the event of an 

incident or accident. The battery-powered DJI Phantom 3 Professional carries no fuel, eliminating this fire and 

environmental risk. 

Traditional aerial photography/videography operations using conventional aircraft can operate in very close 

proximity to persons and property on the ground. While the FAA mitigates these risks in a variety of ways, the 

proposed UAS operations would reduce risks even further due to the limited size, weight, speed, operating 

conditions, and safety features of the DJI Phantom 3 Professional. 

Furthermore, as Congress outlined in the FAA Modernization and Reform Act, integration of UAS into the NAS is 

inherently in the public interest, as long as it can be accomplished safely. As described above, not only will the 

proposed UAS operations provide an equivalent level of safety to current operations – they will actually provide a 

greatly-improved level of safety to the public and its property. 

IX. NATIONAL SECURITY

No national security issue is raised by the grant of this exemption. Given the size, load carrying capacity, speed at 

which it operates, and the fact that it carries no explosives or other dangerous materials, the DJI Phantom 3 

Professional poses no threat to national security.

X. PRIVACY

All operations will be conducted over private or controlled-access property with permission from the land 

owner/controller or authorized representative. Permission from the land owner/controller or authorized 

representative will be obtained for each flight to be conducted.
10

XI. SUMMARY OF Wilson & Echols LLC. SECTION 333 EXEMPTION REQUEST

For publication in the Federal Register, Wilson & Echols LLC hereby provides, pursuant to Part 11, a summary of 

its exemption application to allow commercial operation of the DJI Phantom 3 Professional unmanned aerial vehicle 

in aerial data collection services, aerial photography, videography, sensing and imaging services, including but not 

limited to aerial photography and videography for commercial and private real estate, television filming, news 

gathering, cinematography, surface mapping for geographic information system purposes, and infrared sensing for 

petrochemical infrastructure inspections. An exemption is requested from the following regulations:

14 CFR § 61.113(a) & (b) 

14 CFR § 91.7(a) 

14 CFR § 91.119(c) 

14 CFR § 91.151(a) 

14 CFR § 91.405(a) 

14 CFR § 91.407(a) (1) 

14 CFR § 91.409(a) (1) & (2) 

14 CFR § 91.417(a) & (b)

XII. CONCLUSION

In summary, Wilson & Echols LLC seeks exemption from the FARs listed above in order to commercially operate a 

small unmanned aerial vehicle of less than three pounds for the purposes of aerial data collection services, aerial 

photography, videography, sensing and imaging services, including but not limited to aerial photography and 

videography for commercial and private real estate, television filming, news gathering, cinematography, surface 

mapping for geographic information system purposes, and infrared sensing for petrol chemical storage, 

transportation, transmission lines and infrastructure inspections. 

Approval of this exemption will enhance safety by removing the many risk factors caused by traditional, manned 

aircraft undertaking these operations. By replacing these large, heavy, fuel-laden aircraft with small, lightweight, 

battery operated UAS system, the threat to persons and property can be virtually eliminated.

The operation of the UAS described herein, under the strict conditions outlined above and in the operating 

documents, will provide an equivalent level of safety to support the grant of the requested exemptions.
11

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, operating 

capabilities, proximity to airports and populated areas, operation within visual line of site and with no threat to 

national security – more than justify the grant of the requested exemptions. This request is consistent with numerous 

exemptions already granted.

If we can be of further assistance in processing this request or if you have any questions or concerns, please do not 

hesitate to contact Wilson & Echols LLC directly. Thank you for your time and attention to this request.

Respectfully Submitted,

Adrien Echols Christopher Wilson

Co-Founder of Wilson & Echols LLC. Co-Founder of Wilson & Echols LLC.