September 22

, 2015

Exemption No. 12964 Regulatory Docket No. FAA

− 20 15

− 2735

Mr. John Pattillo

Pattillo and Associates

11007 Moonshine Road Sebastopol, CA 95472

Dear Mr. Pattillo :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 7, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Pattillo and Associates ( hereinafter petitio ner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the2

aircraf t and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or

cre w, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons f or requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Pattillo and Associates is granted an exemption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limi tations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Pattillo and Associates is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may us e either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VL OS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitte d during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documen ts needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS oper ations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any u pdate or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to condu cting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the

UAS is in a co ndition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibite d from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flig ht revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be5

operated under this exemption, including evasive and emergency maneuvers and maintaining approp riate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficie ncy, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denot ed on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made ava ilable to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from begi nning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification6

(N− Number) markings in accord ance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

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

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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

.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.7

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certific ate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available t o the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes

essenti al to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specifie d in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

This exemption terminates on September 30, 2017 , unless sooner superseded o r rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosuresPattillo	&	Associates

. 11007	Moonshine	Road,	Sebastopol,	CA	95472

john@pattilloassociates.com

707

- 827

- 3235

June	7,	2015

US	D epartment	Of	Transportation

Federal	Aviation	Administration

800	Independence	Ave	SW

Washington	DC 20591

Dear	Sir	or	M adam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012(the	reform act)	and	CFR	Part	11, Pattillo	&	Associates ,	owner	and	operator	of	Small	Un manned Aircraft	Systems	(UASs)	for	aerial	photography	and	video	for	the	real	estate	industry,
agri culture	industry,	construction	industry ,	television	and	special	events request s to	be exempted	from	the	Federal	Aviation	Regulations	(FAR)	listed	below	so that Pattillo	&

Associates may	operate	UASs	commercially	in airspace	regulated	by	the	FAA as	long	as

suc h	operations	are	conducted	with in	and	under	the	conditions	outlined	herein	or	as maybe	established	by	the	FAA	as	required	by	Section 333.

An	exception	is	being	requested	because	P&A	can	provide a	lev el	of	safety	this	is	equal

to those	provided	by	exis ting	rules,	and	the	request	is	in	the	public	interest.		The	FAA’s authority	to	issue	exemptions	from	operating	rules,	and	the	Secretary’s	authority granted	by	Section	333	of	P.L.	112

- 95,	Special	Rules	for	Certain	Unmanned	Aircraft
Systems,	provide	an oppor tunity to	authorize	certain	UAS operations in	the	National Airspace	System	(NAS)	prior	to	implementation	of	the	UAS	rule.		This	incremental	step

and opportunity will allow	P&A	to	safely	and	legally	enter	into	the	NAS. All	operations will	be	performed	with the	public’s	safety	and	right	to	privacy safeguarded at	all	times.

As	described	below,	the	requested	exception	would	permit	the	operation	of	light weight	(less	than	55	lbs.	total	takeoff	weight)	UASs	under	controlled	conditions in airspace	that is	limited,	predetermined,	subject	to controlled	access,	and would provide safety	enhancements to	the	already	safe	operation	of	those	aircraft	of	similar	size,
weight,	speed	and	operating	capability	that	have	been	granted	entry	into	the	NAS	via

the	rules	i n	Academy	of	Model	Aeronautics	(AMA)	National	Safety	Code.

Pattillo	&	Associates UASs	are	rotorcraft	weighing	less	th an	55	pounds	including payload	specifically	the DJI Inspire	1 Quad	Copter s

. They operate at speed s less	than	50

knots	and have the	capabi lity	to	hover	and	move	in	the	vertical	and	horizontal	plane simultaneously. They	also	have an	auto	return	to	launch	point	when	battery	power	isunder	25%. The	UAS	will	operate	within	the	line	of	sight	with	in	a	protected	flight	area

as	described be low	and at	200	feet	AGL	or	less	with	an	observer	located	close	at	hand	as
to	make	voice	communication	possible. These	operations	will	not	create	a	hazard	to users	of	the	nation	airspace,	public	nor	the	environment.

Pattillo	&	Associates respectfully	requests the	grant	of	an	exception	to	the	following specific	sections	of	the	Title	14	Code	of	Federal	regulations	allowing	it	to	operate lightweight	UASs	for	commercial	use,

14	CFR	21,	subpart	H,	14	CFR	45.23	(b)	14	CFR	91.7	(a),	91.9	(b)	(2)	91.103	(b)

, 9 1.109,	91.119,	91.121,91.151,(a),	91.203(a)	&(b),91.405(a),91.407(a)(1),	91.409(a)&(b).

Pattillo	&	Associates submits	this	application	in accordance	with	the	Reform	Act 112

P.L.	95	331

- 334,	seeking	relief	from	any	currently	applicable	FAR’S	operating	t o	prevent

Pattillo	&	Associates future	commercial	use	of	small UASs	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	in	the public’s	interest	to	do	so. Pattillo	&	Associate s	UASs	meet	the	definition	of	“small
unmanned	aircraft”	as	defined	in	Section	331	and	therefor	the	integration	of	these	UASs are	expressly	contemplated	by	the	Reform	Act. Pattillo	&	Associates would like	to operate	its	light	weight	UASs	prior	to	the	time	period	by	which	the	Reform	Act	requires the	FAA	to	promulgate	rules	governing	such	aircraft.

The	Reform	Act	directs	the	Secretary	of	Transportation	to	consider	whether	certain

unmanned	aircraft	s ystems	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	UASs	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	UASs	size,	speed,	weight	and	operational	capability

Operation	of	the	UASs	in	close	proximity	to	airports	and	populated	areas

Operation	of	the	UASs	within	visual	line	of	sight	of	the	operator

Reform	Act	333(a).	If	the	secretary	determines	that	such	vehicles	“may	operate	safely
in	National	Airspace	System,	the	secretary	shall	establish	requirements	for	the	safe
operation	i n	national	airspace.

Pattillo	&	Associates UASs	are rotorcraft	weighing	less than	55 lbs. and	the y operate	at speeds	less	than	50	knots	and	have	the	capability	to	operate	in	the	vertical	and horizontal	plane	simultaneously.	The	UASs	will	operate	only within	the	lin e	of	sight	of
the	operator	with in	a	protected flight	area	and	at	200	feet	AGL	or	less. These	will	not present	a	hazard	to	the	national	airspace	nor	the	public.The	very	small	nature	of	these	UASs	combined	with	the	safe	guards	presented	b elow, will	allow	for	the	safe	operation	greater	than	that	envisioned	by	Congress	for	the	FAA	to establish	and	by	exemption	allow	commercial	operations	of	UASs	to	commence immediately.	Also	due	to	the	size	of	UASs	and	the	areas	and	altitudes	they	will	opera te approval	of	this	exception	presents	no	national	security	issues	and	absolutely	minimal safety	concerns	which	have	been	mitigated	through	our	rigorous	risk	management process.	Given	the	clear	direction	given	in	Section	333	of	the	Reform	Act,	the	authorit y contained	in	the	Federal	Aviation	Act,	as	amended,	the	strong	equivalent	level	of enhanced	safety,	reduced	emissions	utilizing UASs verse s traditional	aircraft	as	well	a s the	economic	impact	of	greatly	reducing	the	cost	of	aerial	photography	thereby

bene fiting	the	greater	public’s	interest.	Accordingly,	the	applicant	requests	that	the	FAA grant	the	requested	exemption	without	delay.

The	following	will	be	considered	as	the	binding	limitation	on	operations	of Pattillo	&

Associates

,

1. Flights	will	only occur	in	the	day	time	hours,

2. Flights	will	be	operated	in	th e	line	of	sight	of	the	operator ( PIC ) and	Observer, (VSO)

3. Flights	will	be	terminated	at	any	time	weather	and	wind	deteriorate	to	“unsafe	for flight”	by	manufacturers	recommendations,

4. The	UASs will weigh	less	that	55	lbs.,

5. Flights	will	be	operated	at	200	feet AGL	or	less.

6. Crew	w ill	be	at	a	minimum	of	operator (PIC) and	an observer	and/or	camera

operator (VSO)

, 7. Operator	and	crew	will	remain	in	contact	during	the	flight	operation,

8. The	UASs	operator	w ill	perform	a	check	of	the	flight	area	and	make	certain	of	the safety	of	all	persons	in	the	area,

9. Consent	will	be	obtained	from	all	persons	with	in	the	video	capabilities	of	the	units	to further	reduce	the	chance	of	violating	anyone’s	privacy.

10. All	requir ed	FAA	clearances,	will	be	obtained	and	distances	from	airports	strictly

observed.

11. All	UASs	will	have	the	capability	to	return	automatically	to	the	operator	in	a	safe manner	with	the	auto	return	function	checked	and	working.

12. Flights	will	only	operate	in VFR	conditions.

13. UASs	have	a	function	on	the	control	to	tell	operator	the	distance	away	from	the
operator	and	its	battery	power	remaining.

14. Flight	team	will	communicate	by	voice	and	the	use	of	two

- way	radio	if	the	area	is	too big	to	hear	voice	from	all	team members.

15. UASs	will	be	used	to	video	private	outings and	functions

, boating,	kayaking and
sporting	e vents	f rom	a	safe	distance.

16. When	operating over	or	near	water	the	UASs	will	be	equipped	with	flotation	devices
so	that	recovery	can	be	made	as	to	prevent	lit hium	battery	exposure	to	the	water

table.14	CFR	part	21	Subpart	H:	Airworthiness Certificate 14	CFR	91.7(a),	91.203(a)(1)

Subpart	H, entitled	Airworthiness	Certificates,	sets	forth	requirements	for	procurement of	necessary	certificates	in	relation	to FAR	91.203(a)(1).	The	size,	weight	and	defined
area	of	operations	for Pattillo	&	Associates UASs	flights	permits	exception	from	Part	21 because	they	meet	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform

Act.	The	FAA	is	authorized	to	exe mpt	aircraft	from	the	airworthiness	certificate requirement	under	both	the	Act	(49	USC	4470(f)	and	Section	333	of	the	Reform	Act.
Both	pieces	of	legislation	permit	the	FAA to	exempt	UASs	from	airworthiness	certificates in	consideration	of	weight,	size,	spe ed,	maneuverability	and	proximity	to	areas	such	as airports	and	dense	populations. Pattillo	&	Associates meets	or	exceeds	each	of	these

elements

As	of	March	23,	2015	the	FAA has	stated	that	it will	automatically	grant	a	“blanket”	COA

for	flights	at	or	unde r	200	AGL	to	any	UASs	operator	with	a	section	333	exemption.

14	CFR	91.203(a&b)	provides	for	carrying	of	civil	aircraft	certifications	and
registrations.	These	are	inapplicable	for	the	same	reasons	stated	above.	The	equivalent
level	of	safety	will	be achieved	by	maintaining	such	certifications	and	registrations	at

Pattillo	&	Associates operations	center.

14CFR91.7	(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness
certificate.	As	no	such	certificate	will	be	applicable	in	the	form contemplated	by	FAR’s this	regulation	is	inapplicable.

14	CFR	91.9(b)(2)	Civil	Aircraft	Flight	Manual	in	Aircraft

14	CFR	91.9(b)(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	A s there	are	no pilots	or	passengers,	and	given	the	size	of	the	U ASs	this	regulation	is	inapplicable. An equivalent level	of	safety	will	be	achieved	by	maintaining	such	certifications	and
registrations	at Pattillo	&	Associates operations	center.

The	FAA	has	previously	issued	exemptions	to	this	regulation	in	Exemptions	N o’s
8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700	and	32827.

14	CFR	91.119	Minimum	safe	altitudes,	prescribes	safe	altitudes	for	operation	of	civil aircraft.	It	allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.

Pat tillo	&	Associates will	only	operate	its	UASs	at	or	below	200AGL .		They	will	be	operated

on	a well

- defined AOR	that	has	been	carefully	reviewed	for	hazards	and	minimizes	the presence	of	any	persons	not	essential	for	these	operations.	Flights	will	only	be	o ver private	property with	the	owner’s	permission and with all	persons	with in	this	video	area also	giving	their consent	for	this	filming.	Compared to	flight operations	of	conventional
and	traditional	aircraft	or	rotorcraft	weighing	far	more	than	50 lbs. ,	op erating	below	500

AGL	with	flammable	fuel

, UASs	operations	present	a	far	smaller	risk	to	the	public.Approval	of these 333	Exemption s allowing	commercial	operations	of	small	UASs	in	the service	of	aerial	photography	will	greatly	enhance	safety	by	re ducing	the	overall	risk associated	with	traditional	aircraft.	Traditional	aerial	photography	requires	large	aircraft with	flammable	fuel	to	fly	in	close	proximity	of	populated	areas	and	people in	general.

With	the	use	of	sma ll	UASs	of 55	lbs. or	less,	batt ery	operated	and	fling	below	200	feet AGL	the	risk	of	injury	of	people	on	the	ground	or	the	crew	has	been greatly reduced and

almost eliminated

.

Granting Pattillo	&	Associates the	above	exemption	will	allow	for	the	expansion	of	UAS systems	into	the	future for	the	safe	conduct	of	free	enterprise and	the	enjoyment	of	the

masses.

Pattillo	&	Associates respectfully	requests	the	FAA	grant	its	exception	without	delay.	The
FAA	has	the	authority	to	issue	the	exemption	sought	by Pattillo	&	Associates pursuant	to

th e	Federal	Aviation	Act,	85	P.L.	726	(1958)	as	amended	(the	ACT).

Sincerely

John	Pattillo

Pattillo	&	Associates,	Inc.

11007	Moonshine	Road

Sebastopol,	CA	95472

john@pattilloassociates.com