September 22, 2015

Exemption No. 12964

Regulatory Docket No. FAA−2015−2735

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 petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography and videography.

See Appendix A for the petition submitted to the FAA describing 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, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public 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 the 
2

aircraft 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, Certification 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 collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 Labs, 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 

crew, 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 for 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 limitations 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 (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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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 use 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 (VLOS) 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; 

electronic messaging or texting is not permitted 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 documents 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 operations 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 update 

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 FAA’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 conducting 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 condition 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 

prohibited 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 Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review 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 be 
5

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate 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 

(training, proficiency, 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 

training, 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 symbol as denoted 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 available 

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 signal, the UA must return to a 

pre-determined location within the private 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 beginning 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 conducted 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 identification 
6

(N−Number) markings in accordance 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 nonparticipating 

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 remain 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 controlled-access property with 

permission from the property owner/controller or authorized 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 operational area as defined by the applicable COA must be reported 

to the FAA'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.
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29. The operator must have a motion 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 area 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 the 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 certificate 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 to 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 

essential 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 specified 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 or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Pattillo	&	Associates.

11007	Moonshine	Road,	Sebastopol,	CA	95472

john@pattilloassociates.com

707-827-3235

June	7,	2015

US	Department	Of	Transportation

Federal	Aviation	Administration

800	Independence	Ave	SW

Washington	DC 20591

Dear	Sir	or	Madam:

						 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	Unmanned	

Aircraft	Systems	(UASs)	for	aerial	photography	and	video	for	the	real	estate	industry,	

agriculture	industry,	construction	industry,	television	and	special	events	requests 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	

such	operations	are	conducted	within	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	level	of	safety	this	is	equal	

to those	provided	by	existing	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	opportunity 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	in	Academy	of	Model	Aeronautics	(AMA)	National	Safety	Code.

		Pattillo	&	Associates UASs	are	rotorcraft	weighing	less	than	55	pounds	including	

payload	specifically	the	DJI	Inspire	1 Quad	Copters. They operate at speeds less	than	50	

knots	and	have the	capability	to	hover	and	move	in	the	vertical	and	horizontal	plane	

simultaneously. They	also	have an	auto	return	to	launch	point	when	battery	power	is	
under	25%. The	UAS	will	operate	within	the	line	of	sight	with	in	a	protected	flight	area	

as	described	below	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),	

91.109,	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	to	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	&	Associates	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	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	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	in	national	airspace.

						Pattillo	&	Associates UASs	are rotorcraft	weighing	less than	55	lbs. and	they 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	line	of	sight	of	

the	operator	within	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	below,	

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	operate	

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	authority	

contained	in	the	Federal	Aviation	Act,	as	amended,	the	strong	equivalent	level	of	

enhanced	safety,	reduced	emissions	utilizing	UASs	verses traditional	aircraft	as	well	as	

the	economic	impact	of	greatly	reducing	the	cost	of	aerial	photography	thereby	

benefiting	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	the	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	will	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	will	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	required	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	events	from	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	lithium	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	exempt	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,	speed,	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	under	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.	As there	are	no	

pilots	or	passengers,	and	given	the	size	of	the	UASs	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	No’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.	

Pattillo	&	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	over	

private	property	with	the	owner’s	permission and	with	all	persons	within	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.,	operating	below	500	

AGL	with	flammable	fuel, UASs	operations	present	a	far	smaller	risk	to	the	public.
					Approval	of	these 333	Exemptions allowing	commercial	operations	of	small	UASs	in	the	

service	of	aerial	photography	will	greatly	enhance	safety	by	reducing	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	small	UASs	of	55	lbs. or	less,	battery	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	

the	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