Seth Feldman

Drone on Texas

1707 Catchfly Cove

Cedar Park, TX 78613

512-947-8004

August 1, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Roomwl2-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations.

DearSirorMadam,

PursuanttoSection333oftheFAAModernization andReformAct of2012 (the "ReformAct")

and 14C.F.R. Part 11Drone on Texas seeks an exemption from Federal Aviation Regulations

("FARs ")detailedbelowforthefollowingdescribedUnmannedAircraftSystem.

THE UNMANNED AIRCRAFT SYSTEM (UAS) DETAILS:

ThemanufacturerisOJI. Itismodel Phantom 3Professional (2.8 lbgrossweightfully equipped)

battery only operated 4 motor craft in the formof a quadcopterthat takes offand lands vertically.

Itcarriesthe followingequipmentinflight:

• An on-board flight computerwithGPSnavigation and locationabilitythatreceives

signals for flight controls from a ground-based transmitter/controller.

• An on-board camera capable of capturing imagesinthe formoffull color,4Kdefinition

still photos and videos.

• Itisequipped tosend flight data fromthe on-board flightcomputertothe on-board radio

transmitterincludingaltitudeAGL, horizontal andverticalspeed, compassdirectionof

flight and direction back to its launch site.

• A2.483 GHz on-board radio transmitterthattransmitslivevideo fromtheon- board

camera plus all the flight data from the telemetry system described above.
The Unmanned Aircraft System will be operated in the field with a PIC in accordance with FAA 

Policy N 8900.227 Section 14 "Operational Requirements for UAS".

Drone on Texas respectfully requests the grant of exemption allowing us to operate lightweight, 

remote controlled UAS's lawfully and safely.

Drone on Texas also respectfully requests Exemption Request Section 333 from (but not

limited to) the Specific Sections ofTitle 14 of the Code of Federal Regulations and part 11 of the 

Federal Aviation. Regulations listed below.

14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 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) (2);

91.417 (a) & (b)

The extent of relief Drone on Texasseeks and the reasonwhy:

Drone on Texas is seeking relief from any applicable FARs operating to prevent Drone on Texas 

from conducting low level aerial shots ofreal estate and other possible legal flightoperations.

The weight ofthe UAS meets the definition of "small unmanned aircraft" found insection 331 of

"The Reform Act". Drone on Texas seeks to operate legally as a small business that caters to real

estate agents. Realtors are not allowed to use UAS's or hire unless they, or theperson they hire, is 

allowed by the FAA to fly a UAS. Drone on Texas would satisfy the need for safe and affordable 

aerial shots.

At less than 3 pounds, Drone on Texas uses a UAS that is considerably less than 55pounds 

including the camera that is attached. The UAS will be used at speeds under 30mph because of

the nature of the business and the limited physical capabilities of the UAS. It is designed to hover 

and take pictures. The UAS will be in accordance with flying below 200 ft.

The UAS, in which Drone on Texas would be using, only utilizes battery power for itsoperations.

There are no combustible fuels used in the UAS that Drone on Texas uses. The maximum flight 

time for our particular UASis 23 minutes battery life. It will fly no more than

20 minutes maximum at one time at one location. The amount of time the UAS will be in the air, 

under 200 ft, is very minimal.

A Safety system in place for Drone on Texas UAS includes a GPS mode that allows the UAS to

hover in place if communication is lost. Further, the GPS onboard allows the UAS to return

back to its launched position if the battery life of the UAS is low.
THE GROUND STATION PART OF THE SYSTEM:

• A Pilot inCommand (PIC) in operational control offlight operation frombeginning to

end andwho controlsthe UAS while inthe air. Additionally, the line ofsite ofthe UAS

will not leave the sight of the PIC.

• A 2.483 GHz radio transmitter/controller operated by thePICto control the UASwhile in

flight;

• A radio receiverreceiving live video and flight data fromthe on-board camera and

computer. It projects it all in one screen to the Pilot in Command.

The UAS, weighing lessthan Jibsfullyloaded, ispowered by batteries and operates with no

people on board, which lowerthe likelihood of death orserious bodily injury. With a small

payload consisting of electronicssuch as a camera and OPS, theUAS's onlypurpose istobe

used as a tool to take pictures and videos.

Lowlevel aerial photos and video fromseveral angles are far more effective than ground based

photos. Lowlevel aerial video and picturesshowthe layout of propertieswith the advantage of

seeing more in one photo orshort video.

Current applicantshave chartered helicopters and small planesforthispurpose. The costoffuel,

time, and emissions ofsuch aircraft (helicopters and planes) is not efficient enough for most

customers to afford.

Thebenefits ofreduced cost and improved efficiencyoftheUASallowsfuture customersto

afford thisservicewith a fasterturnaround time at a lesser cost.

Additionally we respectfully request that Drone on Texas be allowed to use the UAS to benefit

possible firstresponders inmy area for actionsthat could benefit the public. Such as,forestfires

and/orsearchandrescue.
Drone on Texas will not operate a UAS near airports and generally does not fly over crowds.

Situational awareness is important. The areas where Drone on Texas conductsaerial

photographyispredeterminedwhichallowsforacontrolledenvironmenttooperatesafely. With

allowingDrone on Texas toconduct businesswith a lightweightUAS, itwill help the

economy and benefit people in firstresponse situations. Further, Aerial Endeavors' UAS is

considerably lighterthanthe alternative,whichisahelicopter orsmall plane. Currently, Drone 

on Texas hasonlyoneUASwhichonlyoperates off23 minutesofbatterypower.Therefore,

theUAS used byDrone on Texas would only have a flight time of 5 - 20minutes at one time.

The likelihood ofinjury or even death with such a small unmanned aircraft, compared to an

aircraftflownby aperson loadedwithcombustible fuel,isconsiderably low.

SUMMARY:

Drone on Texas willfollowthe safety guidelines ofthe FAAPolicyN 8900.227 Section 14

"OperationalRequirementsforUAS"withtheappropriateexemptionsforflyingasmallUAS.

(a) No flight will be made with a UA Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at nomore than 200 ft. AGL, at an

airspeed of no more than 25 knots and no further than 3/4 NM fromthe Pilot InCharge;

(c) Operationswill berestrictedtoflightsoverprivatepropertywiththepermission ofthe

property owner;

(d) All required permits will be obtained from state and local government priorto operation;

(e) The UAS will not be operated over densely populated areas;

(f) The UAS will not be operated at air shows;

(g) The UAS will not be operated over any open-air assembly of people;

(h) The UAS will not be operated over heavily trafficked roads;

(i) The UAS will not be operated within 5 NM of an airport or heliport;

(j) Operations will be restricted to day only and weather conditions equivalent to VFR;

(k) ThePICwill briefthepropertyowner aboutthe operationandrisk before the firstflightat

each new location;

(l) NoflightmaybemadewithoutaPre-FlightInspectionbythePICbeforeeachoperationto

ascertain that the UAS is in a condition safe for flight.
Myoperations above,[(a)through (I)], arethe bareminimumsafetyrequirementsDrone on 

Texas willfollow. Drone on Texas isalsomorethanwillingtofollowanyadditional safety 

requirements if not listed above.

Asstated byPresidentBarak Obama in hisrecent memorandumforthe heads of executive

depai1mentsandagenciesconcerningaUAS,publishedonFebruary 15,2015. "Ascomparedto

mannedaircraft,UASmayprovidelower-costoperationandaugmentexistingcapabilitieswhile

reducingriskstohumanlife. EstimatessuggestthepositiveeconomicimpacttoU.S.industryof

theintegrationofUASintotheNAScouldbesubstantial andlikelywillgrowforthe foreseeable

future". Drone on Texas believesflying its UAS as a small business within the safety

parametersoftheFAA,canhelppeopleandpromotetheeconomy.

Thenameandcontactinformationoftheapplicantis:

Drone on Texas

Attn: Seth Feldman

Phone: 512-947-8004

Email:sfeldman65@gmail.com

Weunderstandsafetyisparamountindealingwith the airspaceandpeople. Pleasecontactus at

anytimeif anyadditionalinformationisneededor anyquestionsneedtobeanswered.

Drone on Texas respectfullyrequeststhattheFAAgrantitsexemptionrequestwithoutdelay.I

dolook forwardtoworkingwith you.Thank youfor yourtime.

Sincerely,

Seth Feldman

Drone on Texas

512-947-8004