1 7 April 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washingt on, DC 20590

RE : Petition of CC Patterson & Associates for Exemption Pursuant to Section 333 of
the FAA Moder nization and Reform Act of 2012 For S m all UAS Aerial Survey Operations

To W hom it M ay C oncern:

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 o f small unmanned aerial system s

.

This exemption is in accordance with protocols outlined in this petition

, t he 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 e xemption would permit commercial operation of the DJI Phantom 3 and DJI Inspire 1 UAS s 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 re l a ted activit i es 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. T his exemption is in support of CCPA ’ s projected shift to UAV

based data collection operations from sub

- co ntracted 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 certifi e d b y the FAA as a

P r ivate Pilot with ratings for S ingle Engine Land , Instrument Airplane; and with a current FAA Medical
Certificate or valid US d river ’ s l icense.

The n ame a nd a ddress of the P etitioner is :

Cameron Patterson
CC Patterson & Associates 13400 Hwy 66 , Ashland

, Oregon 97520 (54 1)488

- 1757 cam.patterson@cascadegeo.com

R e gulations from which Exemption is requested:



### 14 CF R 21(H), 14 CFR 61.23(a) and (c), 61.113(a), 9 1.7(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 Gran t ” Eligibility :

This petiti on 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.
inclu ding the Phantom 3 and the Inspire 1, according to manufacturer recommendations for maintenance and safe operation, as limited by the C o ndition s and Limitations of this exemption, should it be granted.

Aircraft Registration All UAS aircraft operated unde r the proposed exemption will be registered and identified with N

number markings in the largest size p ractica ble in accordance with 14 CFR 45 (c ), 47.

PIC Certification
All UAS aircraft will be operated unde r 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 I n formation

Regarding the Unmanned Aircraft System and its O peration

1. UAS operational characteristics. T he UAS ’ s proposed for operation under this exemption include
the commercially available DJI Phantom and DJI Inspire 1. T hese systems have b oth been previously approved by the FAA f o r Section 333 exemptions

. T hey are both electric quad

- copters weighing significantly less than 55 lbs

, with IMU, GPS, and flight systems that are in extensive
use for ho bbies and recreational purposes; and their flight characteristics and specifications are
availab le 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 w ill be conducted
b. No UAS operations exceeding 87 kt groundspeed

c. No operations above 4 00 feet AGL , or within 500 ’ below or 2000 ’ horizontally from a
cloud

, or when v isibility is less than 3 m i 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

- V O verbal communication maintained at all

times.
f. V alid 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 wil l conduct a full safety pre

- flight inspection p rior to each operation . No operation of UAS without ensured condition for safe operation. j. Oper ator 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 S ingle E ngine Land and Instrument, with training and logbook conditions comple te for Commercial certification.

T otal logged PIC flight time is 256 hrs , with endorsements for High

- performance Complex single engine, and Tailwheel. A l l comm ercial operations will utilize a Vis u a l Observer , who will receive sufficient training on a safe test range to assure safe and efficient operation s 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 li cense for all UAS operations.

R e garding the Mission P r otocols and Area s of O peration of the UAS

5. UAS operations covered under this exemption will generally take place over unpopulated or sparsely populated rural areas.

6. Any oper ations that take place in proximity to persons or sensitive property will maintain a 5 00 ’
direct separation unless said persons are associated with and aware of the UAV operations, or have been notified and provided bo th 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 indi vidual COA applications submitted through the FAA ’ s UAS Civil COA Portal.

8. Each UAS data collection mission will be conducted in accordance with a n individualized plan of operation tha t , 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 plan ning will
be done in a G eographic I nformation S ystem 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 d escribed herein, will be complied with.Append i x 1

F A R s e c t i o n Sub j e c t Ju s t i f i c a t ion 

### 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 P r ivate pilot certification demonstrates adequate NAS knowledge for non

- passenger commercial operation

14 C F R § 91.7 ( a) A i r w ort h i ne s s

r equ i r ement D e s i g ned f o r m an n ed

a i r c r a f t ; not applicable to small

U A S

14 C F R § 91.119 (c ) M i n i m u m safe a l t i t u des S eparation from manned
aircraft by UAV dictates lower operating altitudes

14 C F R § 91.121 Al t i meter s e tt i ngs Not applicable to small UA S

ops

14 C F R § 91.151 ( a) F u el r equ i r ements Not applicable to small UA S

ops

14 C F R § 91. 405 ( a) Maintenance Not necessary to assure small

UA S operation safety . PIC inspection substituted in operatin g procedures

14 C F R § 91. 407 ( a1 ) Return to service Not applicable to small UA S

ops 14 C F R § 91. 40 9 ( a1 ,2 ) Annual in sp ection Not necessary to assure small

UA S operation safety

. I m plementing all m anufacturer
recommendations and operator responsibility substituted in operatin g procedures

14 C F R § 91. 4 17 ( a , b ) Maintenance records Not necessary to assure small UAV operation safety

. Mfg.

rec s and operator responsibility subst.Append i x 2

UAS Specification DJI Phantom 3 DJI Inspire 1


### Aircraft type Q uadcopter Q uadcopter

Weight 1.20 kg 2.93 kg



### S ize (diagonal width) 35 cm 58cm

Maximum Speed 1 6m/s (36 mph) 22 m/s (49 mph)

GNSS positioning GPS/ GLONASS ( a utonomous) GPS/ GLONASS ( a utonomous)

Payload 12mp digital camera and 3

- axis gim b al 12mp digital camera and 3

- axis gim b al

Remote control communications Frequency

range 2.400 Ghz

- 2.483Ghz 2.400 Ghz

- 2.483Ghz

5.725 Ghz

– 5. 825 Ghz

Max c ommun i cations range 2000m (u n obstructed line of sight ) 2000m (u n obstructed line of sight )

F l ight Battery Capacity/Max Flight Duration 4 480mAh/ 23 min ( approx ) 57 0 0mAh/ 18 min ( approx )