Pattillo	&	Associates.

11007	Moonshine	Road,	Sebastopol,	CA	95472

john@pattilloassociates.com

707-827-3235

June	7,	2015

US	Department	Of	Transportation

Federal	Aviation	Administration

800	Independence	Ave	SW

Washington	DC 20591

Dear	Sir	or	Madam:

						 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	Unmanned	

Aircraft	Systems	(UASs)	for	aerial	photography	and	video	for	the	real	estate	industry,	

agriculture	industry,	construction	industry,	television	and	special	events	requests 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	

such	operations	are	conducted	within	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	level	of	safety	this	is	equal	

to those	provided	by	existing	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	opportunity 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	in	Academy	of	Model	Aeronautics	(AMA)	National	Safety	Code.

		Pattillo	&	Associates UASs	are	rotorcraft	weighing	less	than	55	pounds	including	

payload	specifically	the	DJI	Inspire	1 Quad	Copters. They operate at speeds less	than	50	

knots	and	have the	capability	to	hover	and	move	in	the	vertical	and	horizontal	plane	

simultaneously. They	also	have an	auto	return	to	launch	point	when	battery	power	is	
under	25%. The	UAS	will	operate	within	the	line	of	sight	with	in	a	protected	flight	area	

as	described	below	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),	

91.109,	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	to	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	&	Associates	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	systems	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	in	national	airspace.

						Pattillo	&	Associates UASs	are rotorcraft	weighing	less than	55	lbs. and	they 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	line	of	sight	of	

the	operator	within	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	below,	

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	operate	

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	authority	

contained	in	the	Federal	Aviation	Act,	as	amended,	the	strong	equivalent	level	of	

enhanced	safety,	reduced	emissions	utilizing	UASs	verses traditional	aircraft	as	well	as	

the	economic	impact	of	greatly	reducing	the	cost	of	aerial	photography	thereby	

benefiting	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	the	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	will	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	will	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	required	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	events	from	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	lithium	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	exempt	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,	speed,	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	under	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.	As there	are	no	

pilots	or	passengers,	and	given	the	size	of	the	UASs	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	No’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.	

Pattillo	&	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	over	

private	property	with	the	owner’s	permission and	with	all	persons	within	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.,	operating	below	500	

AGL	with	flammable	fuel, UASs	operations	present	a	far	smaller	risk	to	the	public.
					Approval	of	these 333	Exemptions allowing	commercial	operations	of	small	UASs	in	the	

service	of	aerial	photography	will	greatly	enhance	safety	by	reducing	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	small	UASs	of	55	lbs. or	less,	battery	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	

the	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