All	Terrain	Site	Services,	LLC

PO	Box	1363

Bremen,	GA	30110

1-800-586-1506

October	5th,	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,	All	Terrain	Site	Services,	LLC,	owner	and	operator	of	Small	Unmanned	Aircraft	

Systems	(UASs),	requests	to	be	exempted	from	the	Federal	Aviation	Regulations (FAR)	listed	

below	so	that	All	Terrain	Site	Services,	LLC	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	may	be	established	by	the	FAA	as	required	by	Section	333.	

All	Terrain	Site	Services,	LLC	(a	environmental	consulting	firm)	is	owned	by	Chris	Young,	a	

Georgia	resident,	with	a	Georgia	Drivers	license.	Mr.	Young	is	also an	experienced UAS and	RC	

hobbyist	and	will	be	the	PIC.	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	for	commercial	use	by	a	

experienced	UAS	and	RC	hobbyist	with	over	a	decade	of	experience	operating	aerial	RC	devices

thereby	enhancing	safety	and	fulfilling	the	Secretary	of	Transportation’s	(	the	FAA	

Administrator’s)	responsibility	to”	establish	requirements	for	safe	operation	of	such	aircraft	

systems	in	national	airspace	systems.”	Section	333(c),	of	the	Reform	Act.	

All	Terrain	Site	Services	UASs	(The	DJI	Phantom	3	and	Inspire1)	are	rotorcraft	weighing	less	than	

55	pounds	including	payload. They	operate	at	a	speed	less	than	50	knots	and	have	the	

capability	to	hover	and	move	in	the	vertical	and	horizontal	plane	simultaneously.	Both	have	an	

auto	return	to	launch	point	when	battery	power	is	under	25%.	The	UAS	will	operate	within	the	

line	of	sight	within	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.	

All	Terrain	Site	Services,	LLC	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).	 All	Terrain	Site	Services,	LLC	submits	this	application	in	accordance	with	the	
Reform	Act	,112	P.L.	95	331334,	seeking	relief	from	any	currently	applicable	FAR’S	operating	

to	prevent	All	Terrain	Site	Services,	LLC	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.	All	Terrain	Site	Services,	LLCs	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.	All	Terrain	Site	Services,	LLC	would	like	to	operate	its	

lightweight	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.	

All	Terrain	Site	Services,	LLC	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	All	Terrain	Site	

Services,	LLC,	Flights	will	only	occur	in	the	daylight	hours, Flights	will	be	operated	in	the	line	of	

sight	of	the	operator(PIC)	and	Observer,(VSO) Flights	will	be	terminated	at	any	time	weather	

and	wind	deteriorate	to	“unsafe	for	flight”	by	manufacturers	recommendations,	

The	UASs	will	weigh	less	that	55	lbs., Flights	will	be	operated	at	200	feet	AGL	or	less. Crew	will	

be	at	a	minimum	of	operator(PIC)	and	an	observer	and/or	camera	operator(VSO),	
Operator	and	crew	will	remain	in	contact	during	the	flight	operation, The	UASs	operator	will	

perform	a	check	of	the	flight	area	and	make	certain	of	the	safety	of	all	persons	in	the	

area, Consent	will	be	obtained	from	all	persons	within	the	video	capabilities	of	the	units	to	

further	reduce	the	chance	of	violating	anyone’s	privacy. All	required	FAA	clearances,	will	be	

obtained	and	distances	from	airports	strictly	observed.	 All	UASs	will	have	the	capability	to	

return	automatically	to	the	operator	in	a	safe	manner	with	the	auto	return	function	checked	

and	working. Flights	will	only	operate	in	VFR	conditions. UASs	have	a	function	on	the	control	

to	tell	operator	the	distance	away	from	the	operator	and	its	battery	power	remaining.	

Flight	team	will	communicate by	voice	and	the	use	of	two	way radios if	the	area	is	too	big	to	

hear	voice	from	all	team	members. UASs	will	be	used	to	video	and	visually	inspect	large	rural	

parcels	and	hard	to	navigate	terrain	for	potential	environmental	conditions	that	can	result	in	

potential	endangerment to	the	public	when	such	conditions	are	not	addressed	such	as	slope	

stabilization issues	and	potential	slope	failures.		Additionally,	UASs	will	be	used	to	inspect	BMPs	

(Best	Management	Practices)	and	system	operation	so	that	potential	failures	can	be

documented	and	address	in	a	timely	manner to	prevent	possible	catastrophic	failures of	such	

systems	and	reducing	both	the	impact	to	the	public	and	the	environment. 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	All	Terrain	Site	Services,	LLC

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.	West	Edge	Collective,	LLC	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	All	Terrain	Site	Services,	LLC	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	All	Terrain	Site	

Services,	LLC	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.	All	Terrain	Site	

Services,	LLC	will	only	operate	its	UASs	at	or	below	200AGL.	They	will	be	operated	on	a	will	

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	that	the	

owner	has	consented	and	all	persons	within	this	video	area	also	give	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	reduced	or	almost erased.

Granting	All	Terrain	Site	Services,	LLC	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.	 All Terrain Site Services,	LLC	respectfully	requests	the	FAA	grant	its	exception	without	

delay.	The	FAA	has	the	authority	to	issue	the	exemption sought	by	All	Terrain	Site	Services, LLC	

pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726	(1958)	as	amended	(the	ACT).	

Sincerely,

Chris	C.	Young,	CISEC

All	Terrain	Site	Services,	LLC

PO	Box	1363

90	Poseyville	Road

Bremen,	GA	30110

800-586-1506 Office

770-634-1586	Cell