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 20, 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 Reform Act

Dear Sir or Madam:

We respectfully request exemption under 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. PAL 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 projects; aerial surveying; 

agricultural projects; educational and research projects; remote sensing projects, 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. 91.109
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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:

To 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 airspace. Upon 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. The use of sUASs on 

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

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

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

sUASs may reduce the reliance of helicopters or small aircraft to monitor said sites. This 

may improve safety as well as reduce environmental impact by reducing energy usage;

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 small aircraft may be eliminated;

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas 

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

safer and more energy efficient product;

4. Agricultural 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 information for

remote and inaccessible areas. This could promote worker safety as well as reduce the 

reliance on helicopters and aircraft;
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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. Aerial filmmaking, photography and real estate purposes. The use of sUASs may 

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

more cost effective, 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 search and rescue missions. SUASs may reach areas unattainable or viewable 

with helicopters and aircraft. SUASs may be implemented quicker as time is of the 

essence during search and rescue operations. 

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

provide a level of safety 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 the UAS will continuously monitor battery 

reserve and return to the ground station with at least 20% battery power reserved;

4. Flights will be operated at an altitude of 200 feet AGL. Flights will 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. 

Verbal/written consent will be required of all persons 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 required;

10. The sUAS operated will weigh less than 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 

operations; 

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; and
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15. Operations will not be conducted within five (5) NM of an airport 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; general and 45.29 Size of marks;

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: 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 equipment 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 inspections;

20. 14 C.F.R. 91.415 Changes to aircraft inspection 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 contracting. Receipt of the Exemption Pursuant to Section 333 of the FAA Reform 

Act would greatly assist PAL with private and government contracting. 
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Privileges of exemption outside the United States.

Patricia A. Lines and Associates, Inc. may 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 environment

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 available)

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