Pattillo	&	Associates

. 11007	Moonshine	Road,	Sebastopol,	CA	95472
john@pattilloassociates.com

707

- 827

- 3235
June	7,	2015

US	D epartment	Of	Transportation

Federal	Aviation	Administration
800	Independence	Ave	SW
Washington	DC 20591

Dear	Sir	or	M adam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012(the	reform act)	and	CFR	Part	11, Pattillo	&	Associates ,	owner	and	operator	of	Small	Un manned Aircraft	Systems	(UASs)	for	aerial	photography	and	video	for	the	real	estate	industry, agri culture	industry,	construction	industry ,	television	and	special	events request s to	be exempted	from	the	Federal	Aviation	Regulations	(FAR)	listed	below	so that Pattillo	&

Associates may	operate	UASs	commercially	in airspace	regulated	by	the	FAA as	long	as

suc h	operations	are	conducted	with in	and	under	the	conditions	outlined	herein	or	as maybe	established	by	the	FAA	as	required	by	Section 333.

An	exception	is	being	requested	because	P&A	can	provide a	lev el	of	safety	this	is	equal

to those	provided	by	exis ting	rules,	and	the	request	is	in	the	public	interest.		The	FAA’s authority	to	issue	exemptions	from	operating	rules,	and	the	Secretary’s	authority granted	by	Section	333	of	P.L.	112

- 95,	Special	Rules	for	Certain	Unmanned	Aircraft Systems,	provide	an oppor tunity to	authorize	certain	UAS operations in	the	National Airspace	System	(NAS)	prior	to	implementation	of	the	UAS	rule.		This	incremental	step
and opportunity will allow	P&A	to	safely	and	legally	enter	into	the	NAS. All	operations will	be	performed	with the	public’s	safety	and	right	to	privacy safeguarded at	all	times.

As	described	below,	the	requested	exception	would	permit	the	operation	of	light weight	(less	than	55	lbs.	total	takeoff	weight)	UASs	under	controlled	conditions in airspace	that is	limited,	predetermined,	subject	to controlled	access,	and would provide safety	enhancements to	the	already	safe	operation	of	those	aircraft	of	similar	size, weight,	speed	and	operating	capability	that	have	been	granted	entry	into	the	NAS	via
the	rules	i n	Academy	of	Model	Aeronautics	(AMA)	National	Safety	Code.

Pattillo	&	Associates UASs	are	rotorcraft	weighing	less	th an	55	pounds	including payload	specifically	the DJI Inspire	1 Quad	Copter s

. They operate at speed s less	than	50
knots	and have the	capabi lity	to	hover	and	move	in	the	vertical	and	horizontal	plane simultaneously. They	also	have an	auto	return	to	launch	point	when	battery	power	isunder	25%. The	UAS	will	operate	within	the	line	of	sight	with	in	a	protected	flight	area
as	described be low	and at	200	feet	AGL	or	less	with	an	observer	located	close	at	hand	as to	make	voice	communication	possible. These	operations	will	not	create	a	hazard	to users	of	the	nation	airspace,	public	nor	the	environment.

Pattillo	&	Associates respectfully	requests the	grant	of	an	exception	to	the	following specific	sections	of	the	Title	14	Code	of	Federal	regulations	allowing	it	to	operate lightweight	UASs	for	commercial	use,

14	CFR	21,	subpart	H,	14	CFR	45.23	(b)	14	CFR	91.7	(a),	91.9	(b)	(2)	91.103	(b)

, 9 1.109,	91.119,	91.121,91.151,(a),	91.203(a)	&(b),91.405(a),91.407(a)(1),	91.409(a)&(b).

Pattillo	&	Associates submits	this	application	in accordance	with	the	Reform	Act 112

P.L.	95	331

- 334,	seeking	relief	from	any	currently	applicable	FAR’S	operating	t o	prevent
Pattillo	&	Associates future	commercial	use	of	small UASs	to	operate	in	the	national airspace	system	as	described	below.		The	reform	Act	section	332	provides	for	such integration	of	civil	unmanned	aircraft	into	our	national	airspace	system	as	it is	in	the public’s	interest	to	do	so. Pattillo	&	Associate s	UASs	meet	the	definition	of	“small unmanned	aircraft”	as	defined	in	Section	331	and	therefor	the	integration	of	these	UASs are	expressly	contemplated	by	the	Reform	Act. Pattillo	&	Associates would like	to operate	its	light	weight	UASs	prior	to	the	time	period	by	which	the	Reform	Act	requires the	FAA	to	promulgate	rules	governing	such	aircraft.

The	Reform	Act	directs	the	Secretary	of	Transportation	to	consider	whether	certain
unmanned	aircraft	s ystems	may	operate	safely	in	national airspace	before completion of	the	rule	making	required	under	Section	332 of	the	reform	Act.	In	making	this determination,	the	Secretary	of	Transportation	is	required to determine	which	UASs	do
create	a	hazard	to	users of	the	national	airspace	system	or	the	public	or	pose	a	threat	to national	security	in	light	of	the	following:

The	UASs	size,	speed,	weight	and	operational	capability

Operation	of	the	UASs	in	close	proximity	to	airports	and	populated	areas

Operation	of	the	UASs	within	visual	line	of	sight	of	the	operator

Reform	Act	333(a).	If	the	secretary	determines	that	such	vehicles	“may	operate	safely in	National	Airspace	System,	the	secretary	shall	establish	requirements	for	the	safe operation	i n	national	airspace.

Pattillo	&	Associates UASs	are rotorcraft	weighing	less than	55 lbs. and	the y operate	at speeds	less	than	50	knots	and	have	the	capability	to	operate	in	the	vertical	and horizontal	plane	simultaneously.	The	UASs	will	operate	only within	the	lin e	of	sight	of the	operator	with in	a	protected flight	area	and	at	200	feet	AGL	or	less. These	will	not present	a	hazard	to	the	national	airspace	nor	the	public.The	very	small	nature	of	these	UASs	combined	with	the	safe	guards	presented	b elow, will	allow	for	the	safe	operation	greater	than	that	envisioned	by	Congress	for	the	FAA	to establish	and	by	exemption	allow	commercial	operations	of	UASs	to	commence immediately.	Also	due	to	the	size	of	UASs	and	the	areas	and	altitudes	they	will	opera te approval	of	this	exception	presents	no	national	security	issues	and	absolutely	minimal safety	concerns	which	have	been	mitigated	through	our	rigorous	risk	management process.	Given	the	clear	direction	given	in	Section	333	of	the	Reform	Act,	the	authorit y contained	in	the	Federal	Aviation	Act,	as	amended,	the	strong	equivalent	level	of enhanced	safety,	reduced	emissions	utilizing UASs verse s traditional	aircraft	as	well	a s the	economic	impact	of	greatly	reducing	the	cost	of	aerial	photography	thereby
bene fiting	the	greater	public’s	interest.	Accordingly,	the	applicant	requests	that	the	FAA grant	the	requested	exemption	without	delay.

The	following	will	be	considered	as	the	binding	limitation	on	operations	of Pattillo	&

Associates

,

1. Flights	will	only occur	in	the	day	time	hours,

2. Flights	will	be	operated	in	th e	line	of	sight	of	the	operator ( PIC ) and	Observer, (VSO)

3. Flights	will	be	terminated	at	any	time	weather	and	wind	deteriorate	to	“unsafe	for flight”	by	manufacturers	recommendations,

4. The	UASs will weigh	less	that	55	lbs.,

5. Flights	will	be	operated	at	200	feet AGL	or	less.

6. Crew	w ill	be	at	a	minimum	of	operator (PIC) and	an observer	and/or	camera
operator (VSO)

, 7. Operator	and	crew	will	remain	in	contact	during	the	flight	operation,

8. The	UASs	operator	w ill	perform	a	check	of	the	flight	area	and	make	certain	of	the safety	of	all	persons	in	the	area,

9. Consent	will	be	obtained	from	all	persons	with	in	the	video	capabilities	of	the	units	to further	reduce	the	chance	of	violating	anyone’s	privacy.

10. All	requir ed	FAA	clearances,	will	be	obtained	and	distances	from	airports	strictly
observed.

11. All	UASs	will	have	the	capability	to	return	automatically	to	the	operator	in	a	safe manner	with	the	auto	return	function	checked	and	working.

12. Flights	will	only	operate	in VFR	conditions.

13. UASs	have	a	function	on	the	control	to	tell	operator	the	distance	away	from	the operator	and	its	battery	power	remaining.

14. Flight	team	will	communicate	by	voice	and	the	use	of	two

- way	radio	if	the	area	is	too big	to	hear	voice	from	all	team members.

15. UASs	will	be	used	to	video	private	outings and	functions

, boating,	kayaking and sporting	e vents	f rom	a	safe	distance.

16. When	operating over	or	near	water	the	UASs	will	be	equipped	with	flotation	devices so	that	recovery	can	be	made	as	to	prevent	lit hium	battery	exposure	to	the	water
table.14	CFR	part	21	Subpart	H:	Airworthiness Certificate 14	CFR	91.7(a),	91.203(a)(1)

Subpart	H, entitled	Airworthiness	Certificates,	sets	forth	requirements	for	procurement of	necessary	certificates	in	relation	to FAR	91.203(a)(1).	The	size,	weight	and	defined area	of	operations	for Pattillo	&	Associates UASs	flights	permits	exception	from	Part	21 because	they	meet	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform
Act.	The	FAA	is	authorized	to	exe mpt	aircraft	from	the	airworthiness	certificate requirement	under	both	the	Act	(49	USC	4470(f)	and	Section	333	of	the	Reform	Act. Both	pieces	of	legislation	permit	the	FAA to	exempt	UASs	from	airworthiness	certificates in	consideration	of	weight,	size,	spe ed,	maneuverability	and	proximity	to	areas	such	as airports	and	dense	populations. Pattillo	&	Associates meets	or	exceeds	each	of	these
elements

As	of	March	23,	2015	the	FAA has	stated	that	it will	automatically	grant	a	“blanket”	COA

for	flights	at	or	unde r	200	AGL	to	any	UASs	operator	with	a	section	333	exemption.

14	CFR	91.203(a&b)	provides	for	carrying	of	civil	aircraft	certifications	and registrations.	These	are	inapplicable	for	the	same	reasons	stated	above.	The	equivalent level	of	safety	will	be achieved	by	maintaining	such	certifications	and	registrations	at
Pattillo	&	Associates operations	center.

14CFR91.7	(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness certificate.	As	no	such	certificate	will	be	applicable	in	the	form contemplated	by	FAR’s this	regulation	is	inapplicable.

14	CFR	91.9(b)(2)	Civil	Aircraft	Flight	Manual	in	Aircraft

14	CFR	91.9(b)(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	A s there	are	no pilots	or	passengers,	and	given	the	size	of	the	U ASs	this	regulation	is	inapplicable. An equivalent level	of	safety	will	be	achieved	by	maintaining	such	certifications	and registrations	at Pattillo	&	Associates operations	center.

The	FAA	has	previously	issued	exemptions	to	this	regulation	in	Exemptions	N o’s 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700	and	32827.

14	CFR	91.119	Minimum	safe	altitudes,	prescribes	safe	altitudes	for	operation	of	civil aircraft.	It	allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.

Pat tillo	&	Associates will	only	operate	its	UASs	at	or	below	200AGL .		They	will	be	operated

on	a well

- defined AOR	that	has	been	carefully	reviewed	for	hazards	and	minimizes	the presence	of	any	persons	not	essential	for	these	operations.	Flights	will	only	be	o ver private	property with	the	owner’s	permission and with all	persons	with in	this	video	area also	giving	their consent	for	this	filming.	Compared to	flight operations	of	conventional and	traditional	aircraft	or	rotorcraft	weighing	far	more	than	50 lbs. ,	op erating	below	500
AGL	with	flammable	fuel

, UASs	operations	present	a	far	smaller	risk	to	the	public.Approval	of these 333	Exemption s allowing	commercial	operations	of	small	UASs	in	the service	of	aerial	photography	will	greatly	enhance	safety	by	re ducing	the	overall	risk associated	with	traditional	aircraft.	Traditional	aerial	photography	requires	large	aircraft with	flammable	fuel	to	fly	in	close	proximity	of	populated	areas	and	people in	general.
With	the	use	of	sma ll	UASs	of 55	lbs. or	less,	batt ery	operated	and	fling	below	200	feet AGL	the	risk	of	injury	of	people	on	the	ground	or	the	crew	has	been greatly reduced and
almost eliminated

.

Granting Pattillo	&	Associates the	above	exemption	will	allow	for	the	expansion	of	UAS systems	into	the	future for	the	safe	conduct	of	free	enterprise and	the	enjoyment	of	the

masses.

Pattillo	&	Associates respectfully	requests	the	FAA	grant	its	exception	without	delay.	The FAA	has	the	authority	to	issue	the	exemption	sought	by Pattillo	&	Associates pursuant	to th e	Federal	Aviation	Act,	85	P.L.	726	(1958)	as	amended	(the	ACT).

Sincerely

John	Pattillo
Pattillo	&	Associates,	Inc.

11007	Moonshine	Road
Sebastopol,	CA	95472
john@pattilloassociates.com