June 29, 2015

Exemption No. 11935

Regulatory Docket No. FAA–2015–1356

Ms. Patricia A. Lines

Patricia A. Lines and Associates, Inc.

P.O. Box 457

Avon, OH 44011

Dear Ms. Lines:

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 April 20, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Patricia A. Lines and Associates, Inc. (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial filmmaking, photography, surveying, and inspections.

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 3DR Solo.

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 
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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, Patricia A. Lines and Associates, Inc. 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, Patricia A. Lines and Associates, Inc. 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 3DR Solo 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, 
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the conditions and limitations herein take precedence and must be followed. 

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.
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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 

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 five 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 attached COA.
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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 

(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.
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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.

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.
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This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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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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:

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;
U. S. Department of Transportation 

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April 20, 2015

Page Three

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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Page Five

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