November 15, 2015 

ScottAire Services, LLC 

Contact: Garth R. Scott 

5294 Viking Road Northeast 

Moses Lake, WA 98837 

Email: Scottairepro@yahoo.com 

Phone: (406) 202-3797 

U. S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140 

" 1200 New Jersey Avenue SE., Washington DC 20590 

Re: Exception Request Under Section 333 of the FAA Reform Act and part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

In pursuant to Section 333 of the FAA Modernization and Reform Act of the 2012 {reform act) 

and 14 CFR Part 11, ScottAire Services, LLC, a compc;~ny that owns and operates Small 

Unmanned Aircraft Systems (UAS) requests to be exempted from the Federal Aviation 

Regulations (FAR) listed below so that ScottAire Services, LLC may operate UAS commercially in 

airspace regulated bythe FAA, as long as here said operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by section 333. 

Company Background and Planned Operations 

ScottAire Services, LLC is a Washington based company owned by Garth R. Scott. Mr. Scott is a 

retired United States military officer who presently holds a commercial rated helicopter 

instrument, airplane single engine rating with a current medical certificate and flight review 

with nearly 4000 hours of total flight time. He is an experienced UAS pilot and is familiar with 

the operations and the maintenance of the hardware and software updates for these systems. 

Our operations serves the public by collection of aerial imaging and data to enable inspections 

and assessment of industrial structures, agricultural management, surveys and photography of 

outdoor events along with videography (e.g. land and water based venues for imaging realestate, natural/scenic settings, outings, functions and events). 

Equivalent Level of Safety 

The requested exception would permit the operation of lightweight (less than 7 lbs, total 

takeoff weight) UAS under controlled conditions for commercial use by a certified fixed wing, 

and rotorcraft pilot thereby enhancing safety and fulfilling the Secretary of Transportation's 
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(the FAA Administrator's) responsibility to "establish requirements for safe operation of such 

aircraft systems in national airspace systems", Section 333 (c) of the reform act. The enhanced 

safety using an UAS in comparison to manned aircraft, including helicopters of significantly 

greater proportion and carrying crewmembers with flammable fuel is self-evident and 

beneficial to a the public interest, while being able to provide a commercially beneficial 

information and data more quickly, accurately, safely and economically with a significant less 

impact to the environment. All operations will be performed with the public's safety and right 

to privacy safeguarded at all times. 

UAS Devices 

ScottAire Services, LLC UAS(s) are battery-powered, weighing well less than 7 pounds including 

the payload. At present, our UAS fleet will include the DJ1 Phantom Series and the DJ Inspire 

Series. The specific UAS(s) to be initially included in our fleet: 

Parameter DJl Phantom 3 DJllnspire 1 

Type 4 Prop RC Helicopter 4 Prop RC Helicopter 

Weight 2.71bs 6.471bs 

Flight Speed 29 knots 42 knots 

Flight Time 20min 18min 

Camera Integrated Integrated 

The UAS(s) operate at speeds less than 50 knots and have the capability to hover and move in 

the vertical and horizontal planes simultaneously in a precisely controlled manner. ScottAire's 

primary intent is to utilize the UAS at much slower speeds for our imaging and data collection 

applications. As upgrades become available, we will incorporate more advanced systems in 

each series into our operations after we have reviewed new documentation and have trained 

to be capable and proficient with flying characteristics of other UAS (s). 

Statutory Authority for Exemptions 

ScottAire Services, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 

331-334, and seeks relief from any current applicable FARs operating that would prevent 

ScottAire Services LLC from future commercial uses of small UAS to operate in the national 

airspace system as described below. The reform Act section 332 provides for such integration 

of civil unmanned aircraft into our national airspace system as it is the public interest to do so. 

ScottAire Services LLC's UAS(s) will meet the definition of "small unmanned aircraft" as defined 

in Section 331 and therefore the integration of these UAS are expressly contemplated be the 

Reform Act. ScottAire Services, LLC would tike to operate its' light weight UAS(s) prior to the 

time period by which to 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 of the rule making 

required under Section 332 of the Reform Act. In making this determination, the Secretary of 

Transportation is required to determine which UAS do create a hazard to users of the national 

airspace system or the public or pose a threat to national security in light of the following: 

-The UAS size, speed, weight and operational capability 

-Operation of the UAS in close proximity to airports and populated areas 

- Operation of the UAS within visual line of sight of the operator 

Reform Act 333 (a). If the secretary determines that such "vehicles" may operate safely in the 

National Airspace System, the secretary shall establish requirements for the safe operation on 

national airspace. 

ScottAire Services, LLC utilizes multi-prop RC helicopters weighing less than 7 

lbs that operate at speeds less than 50 knots and has the capability to hover 

and operate in the vertical and horizontal plane simultaneously in a precisely 

controlled manner. The UAS will operate only the visual line-of-sight (LOS) of 

the operator with a controlled flight area and only at 400 feet above ground 

level (AGL) or less. Most operations are envisioned at less than 100 feet AGL. 

This operation will not present a hazard to the national airspace system or to 

the public. 

The very small nature of these UAS combined with the risk management 

presented below will allow for the safe operation greater than that 

envisioned by Congress for the FAA to establish and exemption allowing 

commercial operations of the UAS to commence immediately. Also due to 

the size of UAS and the controlled areas and low altitudes in which they will 

operate, approval of this exemption presents no national security issues and 

absolutely minimal safety concerns which have be~n mitigated through our 

risk management process. Given the clear direction given in Section 333 of 

the Reform Act, the authority contained the Federal Aviation Act, as 

amended, the strong equivalent level of enhanced safety, reduced emissions 

utilizing UAS verses traditional aircraft as well as the economic impact of 

greatly reducing the cost of aerial data and imaging acquisition thereby the 

FAA grant the requested the exemption without delay. 
Regulations For Exemption Request 

ScottAire Services LLC.. respectfully request the grant of exemption to following specific sections 

to the Title 14 Code of Federal regulations allowing it to operate lightweight UAS(s) for 

commercial use: 

Regulations: 

14 CFR 21, subpart H/ Air Worthiness Certificates 

14 CFR 45.23 (b)/Identification and Registration Marking 

14 CFR 91.7(a)/Civil Aircraft Worthiness 

14 CFR 91.9 (b) (2)/Civil aircraft flight manual, marking, and placard requirements 

14 CFR 91.109/Fiight Instruction; Simulated instrument flight and certain flight test 

14 CFR 91.119/Minimum safe altitudes 

14 CFR 91.121/ Altimeter settings 

14 CFR 91.151 (a) Fuel requirements for flight in VFR conditions 

14 CFR 91.203 (a) & (b) Civil Aircraft: Certifications required 

14 CFR 91.405 (a) Maintenance required 

14 CFR 91.407 (a)(l) Operation after maintenance preventive maintenance, rebuilding, or 

alteration 

14 CFR 91.409 (a) & (b)/Inspections 

(If there are any other CFRs not listed that need a request for exemption please feel free inform 

me) 

Operational Risk Management: Conditions and Limitations 

The following are our proposed procedures and limitations for the flight operations of ScottAire 

Services, LLC. These guidelines and risk management procedure will be modified as such from 

recommendations provided be the FAA in concert with the submission of this timely request: 

1. Flight will occur during the daytime hours. 

2. Flights wil,l be operated in the visual line-of-sight (VLOS) of the Pilot in Command 

(PIC) and visual observer {VO) using vision with no supplemental devices other than 

corrective lenses. 

3. Flight will be terminated at any time the weather and wind deteriorate to being 

"unsafe for flight"/based on manufactures recommendations and the PIC's 

experience. Operations will' follow the anticipated guidelines of this exemption 

(operations under visual meteorologica,l conditions-VMC, and standard visual flight 

rules-VFR) 

4. All documents, manuals and maintenance logs associated with the UAS will be 

present on the site of operations. In addition, the credentials of the PIC (pilot 

certificate, pilot logbook with current flight review, current medical, and proper 

identification) will be available on site. 
5. The UAS will be assessed fgrairworthiness by the PIC prior to each flight session 

using a checklist submitted by the manufacturers manual. All necessary calibrations 

and testing prior to the flight session will be performed. 

6. The UAS will weigh less than 3 lbs/71bs respectively with speeds will less than 30/50 

knots 

7. Flight will be operated at 400 feet AGL or less. 

8. Crew will be a minimum of the PIC and VO/camera operator. The PIC will be 

responsible for flying the UAS and the monitoring its status and flight dynamics, 

while maintaining the line of sight and visualization and keeping the system 

operations with the specified factory limits (flight range, battery power, etc). The 

VO will be involved in monitoring the airspace for other aircraft, the ground for 

unintended vehicles and bystanders, and will also look for additional hazards that 

could compromise safe operations. 

9. Operator (PIC) and crew including VO will remain in voice contact during the entire 

flight operation. 

10. Prior to operations, weather forecasts, weather radar, and air traffic patterns for the 

.area will be reviewed. The proximity ofthe intended location with respect to 

airports and rFRs will be determine using Foreflight software and all available 

information and flight service capabilities when possible. If operations are 

anticipated within 5 nautical miles of airport reference points, the airport 

management or Air Traffic Control (ATC) tower will be notified prior to the operation 

identifying the location, anticipated time, and the intent of the flight operations. 

When in the vicinity of non-towered airports, we will monitor air traffic in the area 

and be able to inform them of our operations as needed. 

11. The UAS PIC will perform final check of the flight area and make certain of the safety 

all persons present and property in the controlled area prior to initiating flight 

operations. 

12. All UAS will have the capability to return automatically to the operator in a safe 

manner in the event ofthe lost RC communication or a system problem. The auto 

return function will be checked and verified for proper operation on a regular b;;~sis. 

A starting GPS home-position will be established prior to each new flight. 

13. The UAS will have indicators on the control and/or displays to inform the PIC of the 

UAS's distance away from the operator, its altitude and velocity, and its remaining 

battery power. 

14. Written and /or oral permission from the relevant property holders will be obtained 

when flights are conducted over private or controlled access property. 

Benefits to the Public as Whole 

Approval of these 333 exemptions in general will allow commercial operations of small UAS to 

provide a magnitude of public services that we will all benefit from this imaging platform. 

Operating safely in the national airspace while serving public demands and reducing risk to life 

and limb is the overall goal on ScottAire Services, LLC. Traditional aerial imaging requires large 

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aircraft with flammable fuel flying in close proximity of congested areas and people and often in 

less than optimal states of power in the height avoid areas at low altitudes. With the use of 

UAS, the risk of injury of people on the ground or the crew is greatly minimized in comparison 

to the operation of the traditional aircraft. The granting of the use of these small UAS by 

ScottAire Services LLC, will allow companies like ours to grow and provide employment and 

career opportunities while enhancing safety through more efficient means of aerial imaging. 

ScottAire Services LLCJ believes in free enterprise and would offer assistance to other 

companies wishing to work collaboratively to increase the safety and awareness of hazards and 

threats to our way of living. 

ScottAire Services LLCJ respectfully requests the FAA grant its exemption without delay. The 

FAA has the authority to issue the exemption sought by ScottAire Services LLC pursuant to the 

Federal Aviation Act, 85 P.L. 726 {1958) as amended {the ACT}. 

Please contact me if I can provide additional information and clarification to help expedite the 

process. 

Sincerely 

Garth R. Scott 

ScottAire Services, LLC 

5294 Viking Road Northeast 

Moses lake, WA 98837 

Scottairepro@yahoo.com 

(406} 202-3797 

Commercial Instrument Helicopter-Single Engine Fixed Wing Pilot 

Certificate Number: 3633289 {25 AUG 2015)