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U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room 

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..**J~**2-1

### t.W 1200 New JerseyAvenue, SE Washington, DC 20590 Subject: Section 333 Waiver Related to sUAVs 

# ;}Gl&,**-~3** WWW.PARALLAX.COM 

# I SALES@PARALL6.X.COM TEL: {916) 624-8333 SUPPORT@PARALLAX.COM FAX: (916) 624-8003

. _.! Parallax tn·c. is 

## a California corporation engaged in designing,-**developing~** testing, manufacturing and selling robots and small unmanned aerial vehicles {sUAVs) in programmable kit and finished form to educational and hobby users worldwide. As part of our development, testing and video deiT!onstrations of new and existing sUAV products, Parallax Inc. engineers and staff routinely have operated various configurations ofour sUAVs to validate and improve these designs priorto offering them for end use sales. · A review of 14 CFR Parts 1, 45, 47, 48, 91, and 325, addressing the use ofsUAVs as aircraft defined in 49 USC 44102(a)(6), appears to mandate that every "commercial user'' must possess both the appropriate airman certificate mandated in 14 CFR 61 and the associated medical certificate under 14 CFR 67 required for a Pilot in Command (PIC) with the final authority and responsibility for operation·and safety of.any sUAV flight within the National Airspace System (NAS). A simple registration of**eac~** sUAV by a corporate officer or employee, while effe9tive for private operation as an owner does not provide legal coverage for our commercial operations. While we have a staffof**ov~r**forty within our corporate headquarters**~nd** retain contracted outside consultants within the continental United States as well as abroad, a requirement.that each operator/engineer must hold PIC certificates to performtesting._:. and demonstration flights would be a crippling limitation to our continued development ofcurrent and future sUAV models. · Parallax Inc., on its own behalf, and for otherAmerican based sUAV manufacturers, seeks relieffrom tho mandate of registration for commercial operations that can only be performed by a certificated PIC. A certificated PIC process originally**in~ended** forthe

· safe operation of private and commercial passenger aircraft is burdensome and

conveys no improved safety for the public when applied to a designer and manufacturer of sUAVs. 

### V,le do noi belieye that ultralight aircraft requ!re PIC**certific~tion** compliance and those aircraft have a far greater capacity for damage to their operators and**t~ird** parties thandothese targeted versions ofsUAVs.

Parallax Inc. REACH Compliance and Exemption Oct9ber2015There is no obvious public benefit to be derived by shutting down a United States based commercial manufacturer ofsUAVs while leaving the field open only to our primary Asian competition. While there may be an issue as respects the authority ofthe Secretaryto waive'the requirements of PIC certification under Sectior:l 333, there should be some re!ief available 

### by defining what is "commercial operation" to exclude those who design, test, manufacture and demonstrate sUAVsfor sLibsequentforms of "commerdal operation" by the ultimate end user purchasers. Responsible-sUA V_development has always-demanded 

### a rigorous safe operational

.. envelope offlight control as a matter ofenlightened self protection for·a corporation such as Parallax Inc. We also carry a two million dollar policy qfspecific commerCial line insurance related solely to our ELEV-8 product line ofsUAVs as depicted on our - website.
In conclusion, relief could be best accomplished within the cu.rrent format ofthe regulations by ajudicious definition ofwhat constitutes "commercial operation" while excluding those parties who are engaged in the base development,·manufacturing,

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.testing and demonstration ofsUAVs meant for end use**operation~** by true commercial.

operators deriving financial value solely from the purchase and end use operation of those sUA Vs.
Respectfully submitted,
p.p.

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- William B. Bassett·**Corpora~e _Coun_~~-1** **f()r._P_~rallax In~.**