LINES AND ASSOCIATES, INC.

P.O. BOX 457

AVON, OHIO 44011

Telephone: 440

- 892

- 7873 , Cell: 440

- 479

- 0094

Email: plines@lines

- assoc.com

April 2 0 , 2015

U. S. Department of Transportation

Docket Management System

West Building Ground Floor, Room w12

- 140

1200 New Jersey Avenue, SE

Washington DC 20590

RE: Exemption Request Section 333 of the FAA Refo rm Act

Dear Sir or Madam :

We resp ectfully request exemption und er Section 333 of the FAA Reform ACT and Part 11 of

the Federal Aviation Regulations

.

Petitioner:

Patricia A. Lines and Associates, Inc. (PAL)

P.O. Box 457

Avon, Ohio 44011

Telephone: 440

- 892

- 7873

Cell: 440

- 479

- 0094

Email: plines@lines

- assoc.com

PAL is a small business with SBA 8(a) status. PA L intends to incorporate the use of sUASs for

a variety of projects which may include but not be limited to project and construction

management, inspections and monitoring ; environmental review projec ts; aerial surveying;

agricultural projects; educational and research projects; remote sensing projec ts, wildlife and

forestry monitoring projects; aerial filmmaking, photography and real estate purposes; search and

rescue, etc.

Specific Section(s) seeking exemption:

14 C.F.R Part 21

14 C. F.R. 45.23(b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9( b)(2)

14 C.F.R. 91.109U. S. Department of Transportation

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April 20 , 2015

Page Two

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) and (b)

14 C.F.R. 91.215

14 C.F.R. 91.104 through 91.417

Extend of relief requested:

T o permit commercial operation of Small Unmanned Aircraft Systems ( sUASs ) for operations

conducted within and under the conditions outlined herein or as may be established by the FAA

as required by Section 333.

Said exemption would permit the operation of sUASs under controlled conditions in limited,

predetermined and controlled airs pa ce. Upo n granting of this proposed exemption request, PAL

would conduct commercial operations of sUASs meeting or exceeding all operational and safety

requirements per Section 333.

Public Benefit:

1. Project and construction management, inspections and monitoring. T he use of sUASs on

construction sites may i mprove the safety of workers, local residents and general public

by assessing potential dan gerous situations. Falls and injuries may be reduced or

eliminated through a more thorough review of the con struction sites. In some cases,

sUASs may reduce the reliance of helicopters or small aircraft to monitor said sit es. T his

may improve safety as well as red uce environmental impact by reducing energy us age;

2. Environmental Review projects. The use of sUASs during the process of reviewing

projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in

- depth

Environmental Review of the project site as well as surrounding areas. Reliance of

helicopters or smal l aircraft may be eliminated;

3. Aerial surveying. The use of sUASs in connection with aerial surveying of s mall er areas

may eliminate the use of helicopters or ai rcraft. This could provide a more cost effective,

safer and more energy efficient product;

4. Agricul tural projects. Wildlife and Forestry projects. The use of sUASs could assist with

surveying agricultural projects as well as wildlife and forestry projects by providing

information when problems occur, vermin infestation, fire hazards, etc. ;

5. Remote Sensing projects. The use of sUASs could provide views and informa tion for

remote and i n access i ble areas. Thi s c ould promote worker safety as well as reduce the

reliance on helicopters and aircraft ;U. S. Department of Transportation

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April 20 , 2015

Page T hree

6. Educational and Research projects. The use of sUASs could provide information for said

projects in a more cost effective and efficient manner than other available options;

7. A erial filmmaking, photography and real estate purposes

. The use of sUASs may

provide a point of view previously unavailable through other means. They w ould be

more cost effec tive, efficient and more safely than helicopters and aircraft; and

8. Search and rescue. The use of sUASs may provide assistance to local law organizations

during se arch and rescue missions. SUASs may reach areas unattainable or viewable

with helicopters and aircraft. SUASs may be implement ed quicker as t ime is of the

essence d uring search and rescue operations.

Reasons why the exemption would not adversely affect safety or how the exemption would

provide a level of safe ty at least equal to the existing rule.

Proposed operations using sUASs provide increased safety enhancement especially when

compared with helicopters and aircraft for the following reasons:

1. The sUASs will weigh less than ten (10) pounds;

2. Flights will be operated within the visual line of sight of the pilot;

3. Maximum total flight time for each operational flight will be thirty (30) minutes . Flight

times may be less than thirty (30) minutes as t he UAS will continuously monitor battery

reserve and return to the g r ound station with at lea st 20% battery power reserved;

4. Flights will be operated at an altitude of 200 feet AGL. Flights w ill never exceed 400

feet AGL;

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer;

6. A briefing will be conducted daily by all personnel working with said sUAS;

7. All onsite personnel and client employees will be required to execute a waiver

. V erbal/written consent will be required of all pe rsons within 100 feet of flight operation;

8. Written and/or oral permission from relative property owners will be obtained prior to

operating the sUAS;

9. All permits, permissions, etc. will be obtained from local government offices as requi red;

10. The sUAS operated will weigh less tha n 55 pounds including payload (camera, lens,

gimbal, etc.); and

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move

vertically and horizontally ;

12. The sUAS will have the capability to return and land at the pre

- determined location with

the Security Perimeter should the sUAS lose communication or GPS signal during any

operatio ns;

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies;

14. Operations will not be conducted over densely populated areas or heavily traffic

highways; andU. S. Department of Transportation

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April 20 , 2015

Page Four

15. Operations will not be conducted within five (5) NM of an a irport or heliport.

PAL will abide by all regulations including the following:

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness

Certificates;

2. 14 C.F.R. 45.23 Display of marks; g eneral and 45.29 Siz e of marks;

3. 14 C.F.R. 61.113 Private p ilot privileges and l imitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations;

4. 14 C.F.R. 91.7 Civil aircraft airworthiness;

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements;

6. 14 C.F.R. 91. 109 Flight instruction; Simulated instrument flight and certain flight tests;

7. 14 C.F.R. 91.119 Minimum safe altitudes: general;

8. 14 C.F.R. 91.121 Altimeter settings;

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions;

10. 14 C.F.R. 91. 203 Civil aircraft: Certifications required;

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness

certificates: Instrument and equipment requirements ;

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipme nt and use;

13. 14 C.F.R. 91.401 Applicability;

14. 14 C.F.R. 91.403 General;

15. 14 C.F.R. 91.405 Maintenance required;

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or

alteration;

17. 14 C.F.R. 91.409 Inspections;

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and

inspections;

19. 14 C.F.R. 91.413 ATC transponder tests and inspection s;

20. 14 C.F.R. 91.415 Changes to aircraft inspec tion programs; and

21. 14 C.F.R. 91.417 Maintenance records

.

Additional Information:

Patricia A. Lines and Associates, Inc. is a Small Business Administration 8(a) certified business

. The 8(a) program is essential for helping socially and economically disadvantaged entrepreneurs

gain access to the economic mainstream of American society. This program also assists with

government con tracting

. Receipt of the Exemption Pursuant to Section 333 of the FAA Reform

Act would greatly assist PAL with private and government contracting.U. S. Department of Transportation

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April 20 , 2015

Page Five

Privileges of exemption outside the United States.

Patricia A. Lines and Associates, Inc. ma y wish to exercise the privileges of this exemption

outside the United States should a contract with a governmental office require same. All

required rules and regulations will be followed should this occur.

Equipment and Specifications

.

3DR SOLO KIT

~ 3DR solo

, 3DR Solo Gimbal

, 3DR Solo Controller

, 3DR Solo Propeller Set

–

Black

, 3DR Solo Battery Charger

, 3DR Solo Controller Charger

Specifications:

Up to 26 minutes of flight time (20 with camera and Solo Gimbal)

, HD video streaming to mobile

Top speed: 55 mph

Max Altitude: 400ft, per FAA rules

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro

Wifi range: up to a half a mile, depending on environmen t

Controller with color screen and live flight data

Pixhawk 2 flight controller software

Customizable color LEDs for orientation

Solo Battery: 14.8 V LiPo (5200mAh)

Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery availa ble)

10x4.5 self tightening props

880 kV motors

Plug and play with 3

- axis Solo Gimbal from 3DR

Please feel free to contact our office should you have any additional questions or comments.

Thank you for your cooperation with this matter.

Sincerely,

PATRICIA A. LINES AND ASSOCIATES, INC.

Patricia A. Lines