All	Terrain	Site	Services,	LLC

PO	Box	1363 Bremen,	GA	30110

1

- 800

- 586

- 1506

October	5th ,	2015

US	Department	o f	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
be low	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 a n	experienced UAS and	RC hobbyist and	will	be	the	PIC.	All	operations	w ill	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	c ommercial	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	syste ms.”	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	an d	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	les s	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	except ion	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	theReform	Act	,112	P.L.	95	331 334,	seeking	relief	from	any	currently	applicable	FAR’S	operati ng 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

inter es t	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	operat e	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

air space	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	visua l	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	Terra in	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	withi n	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	th an	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	amende d,	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	op erations	of	All	Terrain	Site

Services ,	LLC,	Flights	will	only	occur	in	the	daylight	hours, Flights	will	be	operate d	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	airp orts	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 radio s 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	t he	public	when	such	conditions	are	not	addressed	such	as	slope
stabilization issues	and	potential	slope	failure s .		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	operatio ns	for	All	Terrain Site	Services,	LLC UASs	flights	p ermits	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,	LL C	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	regis trations	at	All	Terrain	Site	Services ,	LLC	operations

cent er. 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	A ircraft 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	certific ations	and	regis trations	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	alt itudes,	prescribes	safe	altitudes	for	operation	of	civil	aircraft.	It allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	c onditions.	All	Terrain	Site Services, LLC	will	only	operate	its	UASs	at	or	below	200AGL.	They	will	be	operated	on	a	will
defin ed	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	conse nt	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	the se	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	f lammable	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 sou ght	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