September 1, 2015

Exemption No. 12688

Regulatory Docket No. FAA–2015–1303

Mr. Cameron Patterson

CC Patterson & Associates

13400 Highway 66

Ashland, OR 97520

Dear Mr. Patterson:

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 letters dated April 17, July 9, and July 21, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of CC Patterson & Associates (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial imagery acquisition for orthophoto and terrain modeling in support of 

geography information system modeling.

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 are the DJI Phantom 3 and 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 
2

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 

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, CC Patterson & 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.
3

Conditions and Limitations

In this grant of exemption, CC Patterson & 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 Phantom 3 and 

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, 
4

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.
5

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.
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 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.
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 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.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
17 April 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition of CC Patterson & Associates for Exemption Pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 For Small UAS Aerial Survey Operations

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, CC 

Patterson & Associates (CCPA), hereby applies for an exemption from Federal Aviation Regulations 

(FARs) identified below, to allow commercial operations of small unmanned aerial systems.

This exemption is in accordance with protocols outlined in this petition, the DJI UAS manufacturer's 

operations and/or instructions manual, DJI UAS User’s Manuals, DJI UAS Quick Start Guides, and any 

other requirements established by the FAA pursuant to Section 333.

This exemption would permit commercial operation of the DJI Phantom 3 and DJI Inspire 1 UASs by 

CCPA, to conduct airborne imagery acquisition for orthophoto and terrain modeling in support of 

geographic information system modeling of natural and cultural resources, hydrology, wetland 

delineation and restoration, forestry, habitat conservation, and other remote-sensing related activities

in which CCPA is normally engaged. CCPA is a small consulting firm specializing in the use of geographic 

information systems and airborne remote sensing data to support conservation ecology-related 

projects, primarily in Southern Oregon. This exemption is in support of CCPA’s projected shift to UAVbased data collection operations from sub-contracted manned aircraft operations, for low-altitude, 

high-resolution ortho-imagery and 3D point cloud generation with lidar, multispectral and thermal

sensors.

All UAV operations conducted under this exemption will be flown by a PIC certified by the FAA as a 

Private Pilot with ratings for Single Engine Land, Instrument Airplane; and with a current FAA Medical 

Certificate or valid US driver’s license.

The name and address of the Petitioner is:

Cameron Patterson

CC Patterson & Associates

13400 Hwy 66, Ashland, Oregon 97520

(541)488-1757

cam.patterson@cascadegeo.com

Regulations from which Exemption is requested:

14 CFR 21(H), 14 CFR 61.23(a) and (c), 61.113(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).

Appendix 1 to this petition summarizes the justification for each requested exemption.
Section 333 “Summary Grant” Eligibility:

This petition for exemption is similar in all significant characteristics to many existing Section 333 

exemptions granted for low altitude aerial UAS survey operations.

CCPA proposes to conduct commercial UAS operation entirely with aircraft manufactured by DCI, Inc. 

including the Phantom 3 and the Inspire 1, according to manufacturer recommendations for 

maintenance and safe operation, as limited by the Conditions and Limitations of this exemption, should 

it be granted.

Aircraft Registration

All UAS aircraft operated under the proposed exemption will be registered and identified with Nnumber markings in the largest size practicable in accordance with 14 CFR 45(c), 47.

PIC Certification

All UAS aircraft will be operated under the proposed exemption by a PIC holding an Airman Certificate 

from the FAA, and current medical or valid US Driver’s License.

Section 333 Safety Evaluation Supporting Information

Regarding the Unmanned Aircraft System and its Operation

1. UAS operational characteristics. The UAS’s proposed for operation under this exemption include 

the commercially available DJI Phantom and DJI Inspire 1. These systems have both been

previously approved by the FAA for Section 333 exemptions. They are both electric quad-copters 

weighing significantly less than 55 lbs , with IMU, GPS, and flight systems that are in extensive 

use for hobbies and recreational purposes; and their flight characteristics and specifications are 

available at the manufacturer’s web site, and summarized in Appendix 2.

2. Operational procedures will closely follow the manufacturer’s recommendations, with these 

additional conditions and limitations:

a. No closed set TV/Motion picture filming will be conducted

b. No UAS operations exceeding 87 kt groundspeed

c. No operations above 400 feet AGL, or within 500’ below or 2000’ horizontally from a 

cloud, or when visibility is less than 3 mi from PIC.

d. All operations conducted in daytime VFR conditions within PIC’s unaided VLOS

e. All operations will utilize a qualified Visual Observer (VO) in accordance with the 

proposed FAA rule for small UAS, with PIC-VO verbal communication maintained at all 

times.

f. Valid Sec.333 exemption operating documentation will be maintained during operations 

and made available to FAA upon request.

g. Safe functional test flights shall be conducted after maintenance procedures

h. Responsibility for safe operating condition of the UAS is the responsibility of the 

operator.

i. PIC will conduct a full safety pre-flight inspection prior to each operation. No operation 

of UAS without ensured condition for safe operation.

j. Operator will follow UAS manufacturer’s maintenance, overhaul, replacement, 

inspection and life limit recommendations for aircraft and components, and comply 

with all manufacturer’s safety bulletins.
Regarding the UAS PIC and Visual Observer

3. All UAS operations will be under the direct responsibility of Cameron Patterson, who holds an 

airman certification from the FAA as a Private Pilot with ratings for Airplane Single Engine Land 

and Instrument, with training and logbook conditions complete for Commercial certification. 

Total logged PIC flight time is 256 hrs, with endorsements for High-performance Complex single 

engine, and Tailwheel. All commercial operations will utilize a Visual Observer, who will receive 

sufficient training on a safe test range to assure safe and efficient operations and 

communications prior to deployment on a commercial project.

4. The PIC will maintain either a FAA medical certification or a valid US driver’s license for all UAS 

operations.

Regarding the Mission Protocols and Areas of Operation of the UAS

5. UAS operations covered under this exemption will generally take place over unpopulated or

sparsely populated rural areas.

6. Any operations that take place in proximity to persons or sensitive property will maintain a 500’

direct separation unless said persons are associated with and aware of the UAV operations, or 

have been notified and provided both consent and appropriate safety protocols (such as staying 

indoors).

7. In general, all operations will be conducted in accordance with the FAA’s March 23 2015 

“blanket” COA for operations under 200’ AGL. All prospective data collections falling outside the 

blanket COA parameters, such as operations within 5 NM of a tower controlled airport will be 

conducted under individual COA applications submitted through the FAA’s UAS Civil COA Portal.

8. Each UAS data collection mission will be conducted in accordance with an individualized plan of 

operation that, at a minimum, plans for flight-time, flight lines, altitudes, PIC and VO locations, 

LZs and lines of sight, obstacles, ground elevations, pre-operation site inspection, analysis of 

topographic obstacles, restricted areas, NAS designations, potential on-ground safety

considerations, loss of communication protocols, emergency procedures, and collision 

avoidance procedures for other manned and unmanned aircraft. All pre-operation planning will 

be done in a Geographic Information System that includes lidar or other existing elevation data, 

airspace horizontal and vertical boundaries, towers, transmission lines, trees and other 

obstructions, landing areas, and requirements for minimum weather and visibility conditions.

9. Each data collection operation will be logged with all details of the operation on a flight-by-flight 

basis.

10. All other conditions and limitations specified by the Section 333 Exemption, including UAS 

“return to base,” loss of communication protocols, and any other condition not described 

herein, will be complied with.
Appendix 1

FAR section Subject Justification

14 CFR 21(H) Airworthiness Certification Not applicable to small UAS

14 CFR 61.23 PIC Medical PIC will have EITHER current 

medical OR valid US driver’s 

license

14 CFR 61.113(a) Private Pilot PIC for 

compensation or hire

Private pilot certification 

demonstrates adequate NAS 

knowledge for non-passenger 

commercial operation

14 CFR § 91.7 (a) Airworthiness

requirement

Designed for manned

aircraft; not applicable to small

UAS

14 CFR § 91.119(c) Minimum safe altitudes Separation from manned 

aircraft by UAV dictates lower 

operating altitudes

14 CFR § 91.121 Altimeter settings Not applicable to small UAS

ops

14 CFR § 91.151(a) Fuel requirements Not applicable to small UAS

ops

14 CFR § 91.405 (a) Maintenance Not necessary to assure small 

UAS operation safety. PIC 

inspection substituted in 

operating procedures

14 CFR § 91.407(a1) Return to service Not applicable to small UAS

ops 14 CFR § 91.409(a1,2) Annual inspection Not necessary to assure small 

UAS operation safety. 

Implementing all manufacturer

recommendations and 

operator responsibility 

substituted in operating

procedures

14 CFR § 91.417(a,b) Maintenance records Not necessary to assure small 

UAV operation safety. Mfg. 

recs and operator 

responsibility subst.
Appendix 2

UAS Specification DJI Phantom 3 DJI Inspire 1

Aircraft type Quadcopter Quadcopter

Weight 1.20 kg 2.93 kg

Size (diagonal width) 35 cm 58cm

Maximum Speed 16m/s (36 mph) 22 m/s (49 mph)

GNSS positioning GPS/GLONASS (autonomous) GPS/GLONASS (autonomous)

Payload 12mp digital camera and 3-

axis gimbal

12mp digital camera and 3-axis 

gimbal

Remote control communications Frequency 

range

2.400Ghz - 2.483Ghz 2.400Ghz - 2.483Ghz

5.725Ghz – 5.825Ghz

Max communications range 2000m (unobstructed line of 

sight)

2000m (unobstructed line of 

sight)

Flight Battery Capacity/Max Flight Duration 4480mAh/ 23 min (approx) 5700mAh/ 18 min (approx)
7/17/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­1303­0003 1/2

Cameron C. Patterson - Additional Information

This Other document was issued by the Federal Aviation

Administration (FAA)

For related information, Open Docket Folder

Content

9 July 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Request for additional Information to Petition of CC

Patterson & Associates for Exemption Pursuant to Section 333

of the FAA Modernization and Reform Act of 2012 For Small

UAS Aerial Survey Operations

To Whom it May Concern:

This letter is to provide additional information relevant to the

petition request referenced above,

in response to the July 6, 2015 letter from the FAA (Brittany

Newton) regarding how this request would be in the

public interest, and to provide additional information to support

our request.

1. This exemption would benefit the public as a whole primarily

by significantly reducing both the expense

(primarily to public agency clients) and risk to manned aircraft

operators and people on the ground, associated with

collecting high resolution aerial mapping information for small

(generally less than 1000 acres) wetland and habitat

restoration sites, and other ecological conservation sites for

which CC Patterson & Associates normally is required

to contract with manned aircraft camera platform providers. We

expect to realize a 5­10 fold cost reduction for monitoring

the type of small restoration sites where we often work, and with

the availability of new 3D vision photogrammetric tools,

we also expect to replace some of the manned lidar data

acquisitions we currently have planned.

2. This exemption request is similar in all material respects to

relief previously requested in Grant of Exemptions

Nos. 11062, 11109, 11112, and 11213, as referenced in many of

Comments Not Accepted

ID: FAA­2015­1303­0003

Document Information

Date Posted:

Jul 16, 2015

Show More Details

Submitter Information

Submitter Name:

Cameron C. Patterson

Docket Information

This document is contained in

FAA­2015­1303

Related Dockets:

None

Related RINs:

None

Related Documents:

U.S. DOT/FAA ­ Request for

Additional Information

CC Patterson & Associates ­

Petition for Exemption
7/17/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­1303­0003 2/2

the Section 333 exemptions currently being granted

by the FAA for proposed aerial data collection activities similar in

all material respects to those we propose with this exemption

request.

Sincerely,

Cameron C. Patterson

Petitioner
21 July 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition of CC Patterson & Associates for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 For Small UAS Aerial Survey Operations

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, CC 

Patterson & Associates (CCPA), hereby applies for an exemption from Federal Aviation Regulations 

(FARs) identified below, to allow commercial operations of small unmanned aerial systems.

This exemption would permit commercial operation of the DJI Phantom 3 and DJI Inspire 1 UASs by 

CCPA, to conduct airborne imagery acquisition for orthophoto and terrain modeling in support of 

geographic information system modeling of natural and cultural resources, hydrology, wetland 

delineation and restoration, forestry, habitat conservation, and other remote-sensing related activities 

in which CCPA is normally engaged. CCPA is a small consulting firm specializing in the use of geographic 

information systems and airborne remote sensing data to support conservation ecology-related 

projects, primarily in Southern Oregon. This exemption is in support of CCPA’s projected shift to UAVbased data collection operations from sub-contracted manned aircraft operations, for low-altitude, 

high-resolution ortho-imagery and 3D point cloud generation with lidar, multispectral and thermal 

sensors.

All UAV operations conducted under this exemption will be flown by a PIC certified by the FAA as a 

Private Pilot with ratings for Single Engine Land, Instrument Airplane; and with a current FAA Medical 

Certificate or valid US driver’s license.

a) The name and address of the Petitioner is:

Cameron Patterson

CC Patterson & Associates

13400 Hwy 66, Ashland, Oregon 97520

(541)488-1757

cam.patterson@cascadegeo.com

b) Regulations from which Exemption is requested:

14 CFR 21(H), 14 CFR 43.7, 14 CFR 43.11, 14 CFR 45.11, 14 CFR 45.21, 14 CFR 45.23(b), 14 CFR

45.27, 14 CFR 45.29, 14 CFR 61.23(a) and (c), 61.113(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).

c) Extent of Relief Sought and Reasons for Request:

Attachment A below lists the regulations from which relief is sought, together with the reason why each 

regulation is not consistent with the safe commercial use of UAS to support our existing conservation 

mapping operations.
This petition for exemption is similar in all significant characteristics to many existing Section 333 

exemptions granted for low altitude aerial UAS survey operations.

CCPA proposes to conduct commercial UAS operation entirely with aircraft manufactured by DCI, Inc. 

including the Phantom 3 and the Inspire 1, according to manufacturer recommendations for 

maintenance and safe operation, as limited by the Conditions and Limitations of this exemption, should 

it be granted.

d) Reasons why granting the request would be in the public interest

This exemption would benefit the public as a whole primarily by significantly reducing both the expense 

(primarily to public agency clients) and risk to manned aircraft operators associated with collecting high 

resolution aerial mapping information for small (generally less than 1000 acres) wetland and habitat 

restoration sites, and other ecological conservation sites for which CC Patterson & Associates normally is 

required to contract with manned aircraft camera platform providers. We expect to realize a 5-10 fold 

cost reduction for monitoring the type of small restoration sites where we often work, and with the 

availability of new 3D vision photogrammetric tools, we also expect to replace some of the manned lidar 

acquisitions we currently have planned. These cost reductions will be passed through to our public 

sector clients through reduction in data acquisition costs and associated reduction in the overall cost of 

ecological mapping projects they undertake.

e) Reasons why Public Safety would be improved by granting the request

All airborne high-resolution data acquisition operations conducted under the proposed Section 333 

exemption by CCPA would replace current data collection methods requiring manned aircraft flying at 

relatively high-risk low survey altitudes. With the safety measures, operational limitation and

procedures summarized below, data collection operations by CCPA under a Section 333 exemption 

would not adversely affect public safety, and would provide a level of safety equal to that provided by 

each rule from which an exemption is sought.

 Aircraft Registration

All UAS aircraft operated under the proposed exemption will be registered and identified with Nnumber markings in the largest size practicable in accordance with 14 CFR 45(c), 47. 

 PIC Certification

All UAS aircraft will be operated under the proposed exemption by a PIC holding an Airman Certificate 

from the FAA, and current medical or valid US Driver’s License.

 Regarding the Unmanned Aircraft System and its Operation

1. UAS operational characteristics. The UAS’s proposed for operation under this exemption include 

the commercially available DJI Phantom and DJI Inspire 1. These systems have both been 

previously approved by the FAA for Section 333 exemptions. They are both electric quad-copters 

weighing significantly less than 55 lbs , with IMU, GPS, and flight systems that are in extensive 

use for hobbies and recreational purposes; and their flight characteristics and specifications are 

available at the manufacturer’s web site, and summarized in Appendix 2.

2. Operational procedures will closely follow the manufacturer’s recommendations, with these 

additional conditions and limitations:

a. No closed set TV/Motion picture filming will be conducted
b. No UAS operations exceeding 87 kt groundspeed

c. No operations above 400 feet AGL, or within 500’ below or 2000’ horizontally from a 

cloud, or when visibility is less than 3 mi from PIC.

d. All operations conducted in daytime VFR conditions within PIC’s unaided VLOS

e. All operations will utilize a qualified Visual Observer (VO) in accordance with the 

proposed FAA rule for small UAS, with PIC-VO verbal communication maintained at all 

times.

f. Valid Sec.333 exemption operating documentation will be maintained during operations 

and made available to FAA upon request.

g. Safe functional test flights shall be conducted after maintenance procedures

h. Responsibility for safe operating condition of the UAS is the responsibility of the 

operator.

i. PIC will conduct a full safety pre-flight inspection prior to each operation. No operation 

of UAS without ensured condition for safe operation.

j. Operator will follow UAS manufacturer’s maintenance, overhaul, replacement, 

inspection and life limit recommendations for aircraft and components, and comply 

with all manufacturer’s safety bulletins.

 Regarding the UAS PIC and Visual Observer

3. All UAS operations will be under the direct responsibility of Cameron Patterson, who holds an 

airman certification from the FAA as a Private Pilot with ratings for Airplane Single Engine Land 

and Instrument, with training and logbook conditions complete for Commercial certification. 

Total logged PIC flight time is 256 hrs, with endorsements for High-performance Complex single 

engine, and Tailwheel. All commercial operations will utilize a Visual Observer, who will receive 

sufficient training on a safe test range to assure safe and efficient operations and 

communications prior to deployment on a commercial project.

4. The PIC will maintain either a FAA medical certification or a valid US driver’s license for all UAS 

operations.

 Regarding the Mission Protocols and Areas of Operation of the UAS

5. UAS operations covered under this exemption will generally take place over unpopulated or 

sparsely populated rural areas.

6. Any operations that take place in proximity to persons or sensitive property will maintain a 500’ 

direct separation unless said persons are associated with and aware of the UAV operations, or 

have been notified and provided both consent and appropriate safety protocols (such as staying 

indoors).

7. In general, all operations will be conducted in accordance with the FAA’s March 23 2015 

“blanket” COA for operations under 200’ AGL. All prospective data collections falling outside the 

blanket COA parameters, such as operations within 5 NM of a tower controlled airport will be 

conducted under individual COA applications submitted through the FAA’s UAS Civil COA Portal.

8. Each UAS data collection mission will be conducted in accordance with an individualized plan of 

operation that, at a minimum, plans for flight-time, flight lines, altitudes, PIC and VO locations, 

LZs and lines of sight, obstacles, ground elevations, pre-operation site inspection, analysis of 

topographic obstacles, restricted areas, NAS designations, potential on-ground safety 

considerations, loss of communication protocols, emergency procedures, and collision 

avoidance procedures for other manned and unmanned aircraft. All pre-operation planning will 

be done in a Geographic Information System that includes lidar or other existing elevation data, 
airspace horizontal and vertical boundaries, towers, transmission lines, trees and other 

obstructions, landing areas, and requirements for minimum weather and visibility conditions.

9. Each data collection operation will be logged with all details of the operation on a flight-by-flight 

basis.

10. All other conditions and limitations specified by the Section 333 Exemption, including UAS 

“return to base,” loss of communication protocols, and any other condition not described 

herein, will be complied with.

f) Summary for publication in the Federal Register

CC Patterson & Associates is an environmental consulting firm engaged in processing airborne remote 

sensing data for planning and monitoring habitat restoration and other conservation projects. In our 

petition, we request that an exemption be granted from certain regulations defined in 14 CFR 21(H), 

14 CFR 43.7, 43.11, 45.11, 45.23(b), 45.27, and 45.29; 14 CFR 61.23(a) and (c), 61.113(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). These exemptions are similar or identical in nature to those currently being 

granted by the FAA under Section 333 for similar survey and mapping operations by other small 

businesses.

Appendix 1

FAR section Subject Justification

14 CFR 21(H) Airworthiness Certification Not applicable to small UAS. 

14 CFR 43.7, 43.11, 45.11 , 45.21, 45.23(b)

45.27, 45.29

Display of placards, records 

and markings on aircraft

Not applicable to UAS due to 

small size.

14 CFR § 91.119(c) Minimum safe altitudes Separation from manned 

aircraft by UAV dictates lower 

operating altitudes

14 CFR § 91.121 Altimeter settings Not applicable to small UAS

ops

14 CFR § 91.151(a) Fuel requirements Not applicable to small UAS

ops
14 CFR § 91.405 (a) Maintenance Not necessary to assure small 

UAS operation safety. PIC 

inspection substituted in 

operating procedures

14 CFR § 91.407(a1) Return to service Not applicable to small UAS

ops 14 CFR § 91.409(a1,2) Annual inspection Not necessary to assure small 

UAS operation safety. 

Implementing all manufacturer 

recommendations and 

operator responsibility 

substituted in operating 

procedures

14 CFR § 91.417(a,b) Maintenance records Not necessary to assure small 

UAV operation safety. Mfg. 

recs and operator 

responsibility subst.

Appendix 2

UAS Specification DJI Phantom 3 DJI Inspire 1

Aircraft type Quadcopter Quadcopter

Weight 1.20 kg 2.93 kg

Size (diagonal width) 35 cm 58cm

Maximum Speed 16m/s (36 mph) 22 m/s (49 mph)

GNSS positioning GPS/GLONASS (autonomous) GPS/GLONASS (autonomous)

Payload 12mp digital camera and 3-

axis gimbal

12mp digital camera and 3-axis 

gimbal
Remote control communications Frequency 

range

2.400Ghz - 2.483Ghz 2.400Ghz - 2.483Ghz

5.725Ghz – 5.825Ghz

Max communications range 2000m (unobstructed line of 

sight)

2000m (unobstructed line of 

sight)

Flight Battery Capacity/Max Flight Duration 4480mAh/ 23 min (approx) 5700mAh/ 18 min (approx)