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EAC Group, LLC

102 Honeytree Court

Venetia, PA 15367

724-549-8781

rich.mcelhaney@comcast.net

August 11, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

Dear Sir or Madam:

This application is being submitted on my own behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, EAC Group, LLC, operator of Small Unmanned Aircraft Systems (“SUASs”) equipped to 

conduct aerial photography and videography, hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its SUASs, 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 333.1.

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive SUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined and 3) controlled. The proposed exemption, if granted, would allow EAC Group, LLC to 

conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of 

the operational and safety requirements that Congress has set forth in Section 333.

EAC Group, LLC is an image processing company that plans to exploit the capabilities of Unmanned 

Aerial Systems to safely offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Event Photography /Videography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 

333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in 

the national airspace system before completion of the (comprehensive) plan and rulemaking required by 

section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), 

Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if 

several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations. The Petitioner Requests Relief from the Following:

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121
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14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System SUASs are oftentimes seen as superior to helicopters due to the smaller 

devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety. We are petitioning for exemption to enable EAC 

Group, LLC to operate a DJI Phantom 3 Professional equipped with three-axis gimbals and using HighDef. cameras. This SUAS has a built- in capability to limit the height it flies above the ground, to limit the 

radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including 

a no fly zone feature. The Phantom 3 Professional also has the failsafe function of the Naza-M autopilot 

system, which means when the communication between the Main Controller and the transmitter is

disconnected, the outputs of all command sticks from controller will go to the center position. If the GPS 

signal is good enough, the system will automatically trigger return to home point and will land safely.

The above specifications meet with the Model Aircraft Operating Standards as set below:

• EAC Group, LLC will only operate its SUAS in line of sight of a pilot and/or observer and will operate at 

sites that are a 'sufficient distance' from populated areas within the sterile area described in the FOPM. 

Such operations will insure that the SUAS will "not create a hazard to users of the national airspace 

system or the public."

• When flying SUAS within 3 miles of an airport, airport operators will be notified and the operator will give 

the right of way to avoid flying in the proximity of full-scale aircraft.

• Maximum flight time for each operational flight will be 25 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit.

• The SUAS will be programmed so that it will not be operated at an altitude of no more than 400 feet 

AGL, and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the SUAS Pilot, and Visual Observer.

• The SUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal).

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move 

vertically and horizontally.

• Given the small size of the SUAS and the restricted sterile environment within which they will operate, 

our SUAS operations adhere to the Reform Act's safety requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on 

combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current 

risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a 

small payload and maximum flight time of only 25 minutes, this offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than ground based imagery 

for displaying the characteristics of large, complex properties with several buildings and large trees. The 

applicants in the past have chartered 2-seat full-sized helicopters for this purpose, which has proven 

more costly than many potential clients have been able to afford. The benefits of reduced cost and 

improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of 

real estate property. Additionally, we request that we be allowed to use our system to benefit first 

responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while 

remaining subject to all limitations cited in this application as we do so.

a. No flight will be made with a Gross weight exceeding 55 pounds;

b. All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no 

more than 25 knots and no further than 3/4 NM from the PIC;

c. All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by 

voice at all times during a flight operation;

d. Operations will be restricted to flights over private property with the permission of the property owner;

e. All required permits will be obtained from state and local government prior to operation;

f. EAC Group, LLC will not operate over densely populated areas;

g. EAC Group, LLC will not be operating over any open-air assembly of people;

h. EAC Group, LLC will not be operating over heavily trafficked roads;

i. EAC Group, LLC will not be operating within 5 NM of an airport or heliport;
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We respectfully request exemption under Section 333 to enable EAC Group, LLC to operate efficient, 

limited, low-risk commercial SAUS operations for the activities stated respecting at all times the space 

and privacy of citizens and property whilst keeping our skies safe.

Sincerely,

Richard M. McElhaney

Owner, EAC Group, LLC.