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, Room wl2

- 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.**

Dear Sir or Madam, Pursuant to Section 333 ofthe FAA Modernization and ReformAct of2012 (the "Reform Act") and 14 C.F.R. Part 11 Drone on Texas seeks an exemption from Federal Aviation Regulations ("FARs ") detailedbelow forthe following describedUnmannedAircraft System.

THE UNMANNED AIRCRAFT SYSTEM (UAS) DETAILS: The manufacturer is OJI. It is model Phantom 3 Professional (2.8 lb gross weight fully equipped) battery only operated 4 motor craft in the form ofa quadcopter that takes offand lands vertically. Itcarries the following equipment in flight:

• An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground

-based transmitter/controller.

• An on-board camera capable ofcapturing images in the form offull color, 4K definition still photos and videos.

• It is equipped to send flight data from the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site.

• A 2.483 GHz on-board radio transmitter that transmits live video from the on- 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 ofthe Code ofFederal Regulations and part 11 ofthe 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 Texas seeks 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 in section 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 the person 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 55 pounds 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 UAS is 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 in Command (PIC) in operational control offlight operation from beginning to end and who controls the UAS while in the air. Additionally, the line ofsite ofthe UAS will not leave the sight of the PIC.

• A 2.483 GHz radio transmitter/controller operated by the PIC to control the UAS while in flight;

• A radio receiver receiving live video and flight data from the on-board camera and computer. It projects it all in one screen to the Pilot in Command.

The UAS, weighing less than Jibs fully loaded, is powered by batteries and operates with no people on board, which lower the likelihood ofdeath or serious bodily injury. With a small payload consisting ofelectronics such as a camera and OPS, the UAS's only purpose is to be used as a tool to take pictures and videos. Low level aerial photos and video from several angles are far more effective than ground based photos. Low level aerial video and pictures show the layout ofproperties with the advantage of seeing more in one photo or short video. Current applicants have chartered helicopters and small planes forthis purpose. The cost offuel, time, and emissions ofsuch aircraft (helicopters and planes) is not efficient enough for most customers to afford. The benefits ofreduced cost and improved efficiency ofthe UAS allows future customers to afford this service with a faster turnaround time at a lesser cost. Additionally we respectfully request that Drone on Texas be allowed to use the UAS to benefit possible first responders in my area for actions that could benefit the public. Such as, forest fires and/or search andrescue.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 conducts aerial photography ispredeterminedwhich allows fora controlled environmentto operate safely. With allowing Drone on Texas to conduct business with a light weight UAS, it will help the economy and benefit people in first response situations. Further, Aerial Endeavors' UAS is considerably lighterthan the alternative, which is a helicopter or small plane. Currently, Drone on Texas has only one UAS which only operates off23 minutes ofbatterypower. Therefore, the UAS used by Drone on Texas would only have a flight time of5

- 20 minutes at one time. The likelihood ofinjury or even death with such a small unmanned aircraft, compared to an aircraft flownby aperson loadedwith combustible fuel, is considerably low.

SUMMARY: Drone on Texas will follow the safety guidelines ofthe FAA PolicyN 8900.227 Section 14 "Operational Requirements forUAS" withthe appropriate exemptions for flying a small UAS. (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 no more than 200 ft. AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the Pilot In Charge; (c) Operations will berestricted to flights overprivate propertywith the permission ofthe property owner; (d) All required permits will be obtained from state and local government prior to 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) The PIC will brief

the property owner aboutthe operation andrisk before the first flight at each new location; (l) No flightma

ybe made without a Pre

-Flight Inspectionbythe PIC before each operation to ascertain that the UAS is in a condition safe for flight.

### My operations above, [(a) through (I)], are the bare minimum safetyrequirements Drone on

Texas will follow. Drone on Texas is also more thanwillingto follow any additional safety requirements if not listed above. As stated by President Barak Obama in his recent memorandum for the heads ofexecutive depai1ments and agencies concerning aUAS, published on February 15, 2015. "As comparedto mannedaircraft, UAS mayprovide lower

-costoperationandaugmentexisting capabilitieswhile reducing risks to human life. Estimates suggest the positive economic impactto U.S. industry of the integration ofUAS into theNAS couldbe substantial and likelywill grow forthe foreseeable future". Drone on Texas believes fly ing its UAS as a small business within the safety parameters of

the FAA, canhelp people andpromote the economy. Thename and contact inf

ormation ofthe applicant is: Drone on Texas Attn: Seth Feldman Phone: 512

-947

-8004 Email: sfeldman65@gmail.com We understand safety is paramount in dealing with the airspace andpeople. Please contactus at anytime ifanyadditional information is needed or any questions needto be answered. Drone on Texas respectfullyrequests thatthe FAA grant its exemptionrequestwithoutdelay

. I do look forwardto working with you. Thank you for yourtime. Sincerely,
Seth Feldman Drone on Texas 512

-947

-8004