June 29

, 2015

Exemption No. 11935 Regulatory Docket No. FAA

– 20 15

– 1356

Ms. Patricia A. Lines

Patricia A. L ines 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 p etitioned 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 ai rcraft system (UAS) to

conduct aerial filmmaking, photography, surveying, and inspections

.

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 3DR Solo

.

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

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

, C ertification procedures for products and parts, Subpart H

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

not necessa ry.

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 enhance d 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 pre sent; 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 an d 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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

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 manuf

acturer.

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 ab le 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 vi sual 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 ;

e lectronic messaging or t exting 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 exe mption 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 acce ssible 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,4

the conditions and limitations here in 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 an d 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 FA A’s UAS Integration Office (AFS− 80) may be contacted if questions a rise 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 determ ine 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 l imit 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 flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely opera te 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 cu rrency 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, 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

traini ng, proficiency, and experience

- buildin g 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 denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

man agement 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 le ss 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 iv ate 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

opera tions 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 attached COA

.6

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 ma de 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 th e 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 immedi ately 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 operatin g 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 con trol led

- 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 f light operation that transgresses the lateral or vertical boundaries of the operational 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 Transpo rtation Safety Board (NTSB) per instructions

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

.7

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 a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activitie s 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 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, co unty, 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 pro duction, 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 91.8

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

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosuresLINES 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

Docket Management System 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

Docket Management System 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

Docket Management System 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

Docket Management System 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