719 2ND AVENUE, SUITE 200 | SEATTLE, WA 98104 | P 206.394.3700

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May 5, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Avenue SE 

Washington, DC 20590

Re: Petition for Exemption Request of Parametrix, Inc., under Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113 (a) & 

(b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 

C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203 (a) & (b); 14 C.F.R. 91.405 (a); 14 C.F.R. 91.407 (a) 

(1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.417 (a) & (b).

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. 

Part 11, Parametrix, Inc. (Parametrix), an operator of small Unmanned Aircraft Systems (“UASs”) hereby 

applies for an exemption from the before mentioned Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its UASs. Parametrix will conduct its operations within and under the conditions of 

this petition or as established by the FAA in granting a Section 333 exemption to Parametrix.

The name and address of the applicant is: 

Parametrix, Inc.

Attn: Steven K Aisaka

719 Second Avenue, Suite 200

Seattle, WA 98104

Ph.: 253-501-5206

Email: saisaka@parametrix.com

 

Specific Sections of 14 CFR from which Parametrix seeks an exemption: 

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)
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14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

From offices throughout the western United States, Parametrix provides multidisciplinary engineering,

planning and environmental science services in transportation, environmental planning and compliance, 

water resources, and community building. As a 100-percent employee-owned firm, our staff have a vested 

interest in strong performance and exceptional client service. Individually, and as a team, we are committed 

to providing high quality, cost-effective solutions that enable our clients to make informed decisions.

Parametrix seeks an exemption to be able to provide the following services to our public and private clients:

 Construction site observation and monitoring.

 Aerial surveying and photogrammetry.

 Photography and videography.

 Inspection of structures.

The requested exemptions would permit Parametrix to operate small, unmanned UASs under conditions 

that are 1) limited, 2) controlled, 3) economical, and 4) would provide safety enhancements over 

conventional aircraft. Approval of this exemption would thereby enhance safety to the public and fulfill the 

FAA’S responsibilities to establish requirements for the safe operation of such aircraft systems in the 

national airspace system.

Parametrix proposes to operate the DJI Phantom 2, and the senceFly eBee. The relevant user manuals of 

the UASs are attached. Parametrix’s UASs weigh 55 or fewer pounds including payload. The UASs will be 

operated, under normal conditions, at a speed of no more than 100 mph and have the capability to move in 

the vertical and horizontal plane simultaneously. The UASs will be operated only in line of sight and only 

within a controlled area. These operations will insure that the UAS will not create a hazard to users of the 

national airspace system or the public.

Given the small size of the UASs involved and the restricted controlled environment which the UASs will 

operate, Parametrix falls within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA, by exemption, allow commercial operations of UASs to operate. Also, due to the 

size of the UASs and the controlled areas in which the UASs will operate, approval of the application 

presents no national security issue. Under Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, the equivalent level of safety surrounding the proposed operations, and the public 

benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions 

associated with allowing UASs, the grant of the requested exemptions is in the public’s interest.

Parametrix proposes that the exemption requested apply to civil aircraft that have the characteristics and 

that operate with the limitations listed. These limitations provide for at least an equivalent or even higher 
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level of safety to operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the existing safe operations conducted with conventional aircraft. These 

limitations and conditions to which Parametrix agrees to be bound when conducting commercial operations 

under an FAA issued exemption include:

1. The UAS will weigh less than 55 pounds (25 kg).

2. The UAS will be operated at a speed of no more than 100 mph.

3. Only visual line-of-sight (“VLOS”) operations will be allowed; the UAS must remain within VLOS of 

the operator or a visual observer (“VO”).

4. UAS operations will occur during daylight hours only.

5. No person may act as an operator or VO for more than one unmanned aircraft operation at one 

time.

6. Minimum crew for each operation will consist of the UAS Operator and a Visual Observer.

7. The UAS Operator will be Pilot in Command (PIC) who shall have completed the required FAA 

training, along with training from the manufacturer or distributor of the UAS.

8. The PIC will be vetted by the TSA and have a TSA Known Traveler Number, and have a valid 

driver’s license from the State of the PIC’s domicile.

9. The UAS will only operate within a confined controlled area of the flight operations area.

10. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 20% battery power reserve, should that occur prior to the 30-minute limit.

11. A briefing will be conducted in regard to the planned UAS operations prior to each day’s 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing.

12. The operator will obtain the consent of all persons involved and ensure that only consenting 

persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 

30 feet based upon an equivalent level of safety determination.

13. UAS operations may not occur over any persons not directly involved in the operation.

14. PIC and VO will at all times be able to communicate by voice.

15. PIC will conduct preflight inspections to ensure the UAS is safe for operation.

16. The UAS will be required to yield right-of-way to all other aircraft, manned or unmanned.

17. Flights will be operated at an altitude of no more than 200 feet AGL.

18. The UAS will only operate in Class G airspace.

19. The UAS will stay certain distances away from airports or heliports:

a. Five (5) nautical miles (NM) from an airport having an operational control tower; or

b. Three (3) NM from an airport with a published instrument flight procedure, but not an 

operational tower; or

c. Two (2) NM from an airport without a published instrument flight procedure or an 

operational tower; or

d. Two (2) NM from a heliport with a published instrument flight procedure.

20. UAS operations will be permitted to occur only when conditions allow minimum weather 

visibility of 3 miles from the control station.

21. Written permission from the relevant property owners will be obtained.
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22. All required permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

23. If the UAS loses communication or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land.

24. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

Accordingly, Parametrix respectfully requests that the FAA grant the requested exemption.

The extent of relief you seek, and the reason you seek the relief: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1). 

Part 21 Subpart H, entitled Airworthiness Certificates, sets forth the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. 91.203 (a) (1). Given the limited size, weight,

and operating area associated with the UAS to be utilized by Parametrix, an exemption from Part 21, 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act and Section 333 of the Reform Act authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. 

The UASs operated by Parametrix is less than 55 pounds fully loaded, carries no pilot or passenger, carries 

no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Operations 

under this exemption will be controlled and monitored by the operator and in compliance with the 

conditions of this document and also in compliance with any local public safety requirements. The FAA will 

have advance notice of all operations through a COA or more likely be operated under the “blanket” 200-

foot COA.

In this case, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

14 C.F.R. 45.23 (b). Marking of the Aircraft.

14 C.F.R. 45.23 prescribes that when marks include only the Roman capital letter “N” and the registration 

number is displayed on limited, restricted, or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,”

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will 

have no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. 

Given the size of the UAV, 2-inch lettering will not be possible. An equivalent level of safety will be the word 

“Experimental,” at a size that is as large as practicable, will be placed on the fuselage in compliance with 

Section 45.29 (f). Additionally, Parametrix will mark its UASs with its company name and contact 

information.
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14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent 

level of safety of current operations by requiring the PIC operating the aircraft to have successfully 

completed, at a minimum, FAA sport pilot ground instruction and passed the FAA Sport Pilot written 

examination or other FAA recognized equivalent training. The PIC will have also completed a manufacturer’s 

training program for the model the PIC will be operating. Additionally, the PIC will have been vetted by the 

TSA by obtaining a Known Traveler Number which comes along with TSA Pre status, and possess a valid 

driver’s license from the state of the PIC’s domicile.

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no 

living thing on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance. The level of safety provided by these requirements will be at least as safe, or safer, 

than that provided by a single individual holding a commercial pilot’s certificate operating a conventional 

aircraft. The risks associated with the operation of the UASs are diminished from the level of risk associated 

with commercial operations contemplated by Part 61, when drafted, that allowing operations of the UAS as 

requested with FAA ground instruction and manufacturer’s training exceeds the present level of safety 

achieved by 14 C.F.R. 61.113 (a) & (b).

14 C.F.R. 91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

As there will be no airworthiness certificate issued for the UAS, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness of the UASs operated by Parametrix. Given the 

size of the aircraft and the requirements contained in the manufacturer’s manual for maintenance and use 

of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides that no person may operate a U.S.-registered civil aircraft . . . . (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by Section 21.5 of this chapter, unless there is available 

in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof. 

The Parametrix UAS, given its size and configuration, has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry

such an item on the aircraft. The equivalent level of safety will be maintained by keeping the UAS flight 

manual at the ground control point where the PIC operating the UAS will have immediate access to it. 
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14 C.F.R. 91.103: Preflight action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. 

Because FAA-approved UAS flight manuals will not be provided for the aircraft, an exemption will be 

needed. An exemption is requested from this requirement as the PIC will take separate preflight actions, 

including checking the condition of the UAS, checking flight battery requirements, weather conditions, 

checking takeoff and landing distances, and all other actions in the User Guide and safety checklists. These 

actions will provide an equivalent level of safety.

14 C.F.R. 91.109: Flight instruction.

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. 

UASs, by their design, do not have fully functional dual controls. Flight control is accomplished through the 

use of a controls that communicate with the aircraft via radio communications. The equivalent level of 

safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size 

and speed of the aircraft.

14 C.F.R. 91.119: Minimum safe altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c) limits aircraft flying 

over areas other than congested areas to 500 AGL. Over sparsely populated areas, aircraft cannot be 

operated closer than 500 feet of any person, vessel, or structure. 

This exemption is requested for minimum safe altitudes as Parametrix proposes to operate its UASs below 

200 AGL. As set forth herein, the UAS will never operate at higher than 200 AGL. An equivalent level of 

safety will be achieved given the size, weight, and speed of the UAS, as well as the location where it is 

operated. Additionally, no flight operations will be made without the permission of the property owner or 

local officials. 

14 C.F.R. 91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set to the elevation of the departure airport or an appropriate altimeter setting available 

before departure. 

Because the UAS will not have a barometric altimeter, but instead a GPS altitude read-out, an exemption is 

requested. An equivalent level of safety will be achieved by confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight.

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions.

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 
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landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes.”

The intent of this requirement is to provide enough fuel or energy reserve in the event of delays due to 

congestion or weather at an airport. The typical battery powering a UAS provides approximately 40 minutes 

of powered flight. To meet the 30-minute reserve requirement in 14 CFR 91.151, Parametrix’s UAS flights 

would be limited to approximately 10 minutes in length. Given that the limitations of an UAS proposed 

flight will be operated with visual line of sight and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight VFR conditions is reasonable. Parametrix 

believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 20% of battery 

power, whichever happens first. This exemption would be more than adequate to return the UAS to the 

landing zone from anywhere in its limited operating area.

14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration.

The regulation provides in pertinent part:

(a) Except as provided in Section 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under Section 91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew.

The UAS has no cabin or cockpit, there is no ability or place to carry certification and registration documents 

or to display these documents on the UAS. As with 14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Manual in the 

Aircraft, an equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the PIC operating the UAS will have immediate access to the documents, to the extent needed 

and applicable to the UAS. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed 

in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in Part 43 of this chapter...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43.

Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to Parametrix. The operator following the manufacturer’s product and operating manual will 

accomplish maintenance. An equivalent level of safety will be achieved because Parametrix’s UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. 

If mechanical issues arise, the UAS can immediately land and will be operating from no higher than 200 feet 

AGL. As provided in the manufacturer’s manual, the operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. 
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Summary: 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: Applicant seeks an exemption from the following rules:

14 C.F.R. 21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. 61.113( a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2);

14 C.F.R. 91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 

91.203(a) and (b); 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.409 (a) (2); and 

14 C.F.R. 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 pounds or less).

Approval of exemptions allowing commercial operations of UASs will enhance safety by reducing risk. 

Conventional operations, using jet or piston-power aircraft, operate at low altitudes just feet from the 

subjects being photographed and in close proximity to people and structures and present the risks 

associated with vehicles that weigh in the neighborhood of 4,000 pounds and carrying large amounts of 

aviation fuel. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates almost 

all of that risk given the reduced weight and lack of combustible fuel carried on board. The UAS will carry no 

passengers or crew and, therefore, will not expose anyone to the risks associated with manned aircraft 

flights.

The operation of UASs, weighting less than 55 pounds, conducted in the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters operating in close 

proximity to the ground and people.

Additional Information: 

Privacy 

All flights will occur over private or public controlled access property with the property owner’s prior 

consent and knowledge. Photography will be of people who have also consented to being filmed or 

otherwise have agreed to be in the area where filming will take place. The grant of this exemption request 

will provide improved safety in both day and night operations. Satisfaction of the criteria provided in 

Section 333 of the Reform Act of 2012, size, weight, speed, operating capabilities, proximity to airports and 

populated areas, and operation within visual line of sight and national security provide more than adequate 

justification for granting the requested exemptions allowing commercial operations.

Regards,

Steven K. Aisaka, PE, SE, JD

Director of Risk Management

Parametrix, Inc.
ATTACHMENT A – OPERATIONS MANUALS