December 29, 2015

Paul R Bissaillon, Consultant

857 Oxford Street S

Auburn, MA 01501

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 

14 CFR Part 11, Paul R. Bissaillon, operator of Unmanned Aircraft Systems (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its 

UAS, so 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.

Commercial operation of UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner:

 Aerial photography and/or video for public and/or private use including training, oil spill 

surveillance, oil spill equipment deployment training, incident management operations, 

sporting/marching band events, and home inspections.

 Live video feed capability to assist with oil spill cleanup operations and incident management 

operations.

 Aerial photography/video or providing live video feed to assist with incident management 

operations associated with natural disaster only when the local authorities or government has 

requested it by contract or donation.

Paul R Bissaillon hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113, 

91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

Paul R Bissaillon plans to operate three UAS, the DJI Phantom 2, DJI Phantom 3 and the DJI Inspire I. All 

three are comprised of an unmanned aircraft and a transportable ground station.

1. The DJI Phantom 2 is referred to as a quad-copter with a maximum gross weight of about 1.3 

kilograms (2.8 lbs). It is equipped with four rotors that are driven by electric motors powered by 

a battery. The UA has a maximum airspeed of 15 m/s (50 ft/s). The quad has a built in high 

definition camera.

2. The DJI Phantom 3 is referred to as a quad-copter with a maximum gross weight of about 1.23 

kilograms (2.7 lbs). It is equipped with four rotors that are driven by electric motors powered by 

a battery. The UA has a maximum airspeed of 16 m/s (52.5 ft/s). The quad has a built in high 

definition camera.

3. The Inspire 1 is referred to as a quad-copter with a maximum gross weight of about 3 kilograms

(6.6 lbs). It is equipped with four rotors that are driven by electric motors powered by a battery. 

The UA has a maximum airspeed of 22 m/s (72 ft/s). The quad has a built in high definition 

camera.

Paul R Bissaillon is a consultant that provides emergency response pre-planning, training and support to 

private and public organizations throughout the United States during all-risks/all-hazards type exercises 

and real incidents.
Paul R Bissaillon plans to operate the UAs throughout the United States to provide unique and 

compelling perspectives for clients during training, exercises and real incidents during incident 

management operations.

I state that given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and

(b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95

(Section 333).

I request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin,

cockpit or pilot station on which to mark certain words or phrases. Furthermore, I state that two-inch

lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering

requirement. Regardless of this, I state that I will mark his UAS as required by law with future marking 

requirements so that I or anyone assisting me as a spotter will see the markings.

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b)

Maintenance inspections may be required and should be granted since they only apply to aircraft with

an airworthiness certificate. However, I state that as a safety precaution I will perform a preflight

inspection of the UAS before each flight as outlined in the operating documents.

UAS Pilot in Command (PIC)

I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry any pilots or passengers. Further, I state that, while helpful, a private pilot license will not ensure 

remote control piloting skills. I further indicate that the risks of operating a UAS are far less than the risk 

levels inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus I request an 

exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.

Regarding UAS operational training, I state I have flown numerous practice flights (over 100 hours) in 

remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the 

characteristics of the UAs’ performance under different temperature and weather conditions. I am a 

retired United States Coast Guard officer with over 25 years of incident management experience and 

currently hold a valid Transportation Workers Identification Credential vetted through the 

Transportation Security Administration. This documentation should identify that I am not a threat to 

security.

Equivalent Level of Safety

The safe operation to the NAS and/or persons and/or property will be kept to a minimum by always 

completing a pre-flight inspection of the UAS and transmitter as per the manufacturer’s 

recommendations.

I will abide by the following additional UAS operating conditions under this exemption:

 operate my UAS below 400 feet;

 operate the UAS for 20-25 minutes per flight;

 land my UAS prior to the manufacturer’s recommended minimum level of battery power;

 operate my UAS only within visual line of sight (VLOS);
 use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then 

slowly lands autonomously at a pre-designated location if communication with the remote 

control pilot is lost;

 contact respective airports if operations will be within 5 miles to advise them of my estimated 

flight time, flight duration, elevation of flight and other pertinent information;

 always obtain all necessary permissions prior to operation; and

 have procedures in place to abort flights in the event of safety breaches or potential danger.

I state that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert

that since there is currently no certificate applicable to my operation, this regulation is inapplicable.

I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no

pilots or passengers on board his aircraft and given its size, this regulation is inapplicable.

I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS that 

displays the altitude.

Public Interest

I state that aerial videography and photography for incidents and events have been around for a long 

time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. Granting this exemption to Paul R Bissaillon would provide this service at a much 

lower cost. Further, I would like to indicate my small UAS will pose no threat to the public given its small 

size and lack of combustible fuel when compared to larger manned aircraft. I would also like to state 

that the operation of my UAS will minimize ecological damage and promote economic growth by 

providing situational awareness to incident management teams responding to oil spills or natural 

disasters.

(end of petition)

I would like to conclude my petition by sincerely thanking the FAA for their consideration and for taking 

the time to look at this petition for Paul R Bissaillon. I am always looking to stay on the forefront of new 

response technology and believe there is a wonderful opportunity with these safe, reliable UAs that will 

only allow us to further provide situational awareness and training to clients. Thank you again and I look 

forward to hearing from you in the near future.

Respectfully,

Paul R Bissaillon, Senior Consultant

857 Oxford Street S

Auburn, MA 01501

pbissaillon@gmail.com

832.493.1966