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U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room V .. J~ 2-1 t.W 

1200 New Jersey Avenue, 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 of our sUAVs to validate and improve these designs prior to offering them 

for end use sales. · 

A review of 14 CFR Parts 1, 45, 47, 48, 91, and 325, addressing the use of sUAVs 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 staff of 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 perform testing._:. 

and demonstration flights would be a crippling limitation to our continued development 

of current and future sUAV models. · 

Parallax Inc., on its own behalf, and for other American based sUAV manufacturers, 

seeks relief from tho mandate of registration for commercial operations that can only be 

performed by a certificated PIC. A certificated PIC process originally in~ended for the 

· 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 than do these targeted versions of sUAVs. 

Parallax Inc. REACH Compliance and Exemption Oct9ber 2015 
There is no obvious public benefit to be derived by shutting down a United States based 

commercial manufacturer of sUAVs while leaving the field open only to our primary 

Asian competition. While there may be an issue as respects the authority of the 

Secretary to 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 of flight control as a matter of enlightened self protection for ·a corporation 

such as Parallax Inc. We also carry a two million dollar policy qf specific commerCial line 

insurance related solely to our ELEV-8 product line of sUAVs as depicted on our -

website. 

In conclusion, relief could be best accomplished within the cu.rrent format of the 

regulations by a judicious definition of what constitutes "commercial operation" while 

excluding those parties who are engaged in the base development, ·manufacturing, -

. testing and demonstration of sUAVs 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. f~ · ? ... u.J1ivo 0 - William B. Bassett· 

Corpora~e _Coun_~~-1 f()r._P_~rallax In~.