21 July 2015

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

RE: Petition of CC Patterson & Associates for Exemption Pursuant to Section 333 of the FAA
Modernization and Reform Act of 2012 For Small 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 & Associate s (CCPA) , hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system s

.

This exemption 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 c onservation, and other remote

- sensing related activities
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

p rojects, primarily in Southern Oregon. This exemption is in support of CCPA’s projected shift to UAV

based data collection operations from sub

- contracted manned aircraft operations, for low

- altitude, high

- resolution ortho

- imagery and 3D point cloud generat ion with lidar, multispectral and thermal

sensors.

All UAV operations conducted under this exemption will be flown by a PIC certified by the FAA as a Private Pilot with ratings for Single Engine Land, Instrument Airplane; and with a current FAA Medical

Ce rtificate or valid US driver’s license.

a) The name and address of the Petitioner is:

Cameron Patterson
CC Patterson & Associates 13400 Hwy 66, Ashland, Oregon 97520 (541)488

- 1757 cam.patterson@cascadegeo.com

b) Regulations from which Exemption is requested: 

### 14 CFR 21(H), 14 CFR 43.7, 14 CFR 43.11, 14 CFR 4 5 .11

, 14 CFR 4 5

. 2 1

, 14 CFR 4 5

. 23(b)

, 14 CFR

4 5

. 27

, 14 CFR 4 5

. 29

, 14 CFR 61.23(a) and (c), 61.113(a), 91.7(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).

c) Extent of Relief Sought and Reasons for Request : Attachment A below lists the regulations fro m which relief is sought , together with the re a son why each regulation is not consistent with the safe commer cial use of UAS t o support our existing conservation mapping operations.This petition for exemption is similar in all significant characteristics to many existing Section 333

exemptions granted for low altitude aeri al UAS survey operations.

CCPA proposes to conduct commercial UAS operation entirely with aircraft manufactured by DCI, Inc. including the Phantom 3 and the Inspire 1, according to manufacturer recommendations for maintenance and safe operation, as limite d by the Conditions and Limitations of this exemption, should it be granted.

d) Reasons why granting the request would be in the public interest This exemption would benefit the public as a whole primarily by significantly reducing both the ex pense (primarily to public agency clients) and risk to manned aircraft operators associated with collecting high resolution aerial mapping information for small (generally less than 1000 acres) wetland and habitat restoration sites, and other ecological co nservation sites for which CC Patterson & Associates normally is required to contract with manned aircraft camera platform providers. We expect to realize a 5

- 10 fold
cost red uction for monitoring the type of small restoration sites where we often work, a nd with the availability of new 3D vision photogrammetric tools, we also expect to replace some of the manned lidar acquisitions we currently have planned. These cost reductions will be passed through to our public sector clients through reduction in dat a acquisition costs and associat ed reduction in the overall cost of ecological mapping projects they undertake.

e) Reasons why Public Safety would be i mproved by granting the request

All airborne high

- resolution data acquisition operations conducted under the proposed Section 333 exemption by CCPA would replace current data collection methods requiring manned aircraft flying at relatively high

- risk low survey altit udes

. With the safety measures , operational limitation and procedures summar ized below , data collection operations by CCPA under a Section 333 exemption
would not adversely affect public safety, and would provide a level of safety equal to that provided by each rule from which an exemption is sought.

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

number markings in the largest size practicable in accordanc e with 14 CFR 45(c), 47.

 PIC Certification All UAS aircraft will be operated under the proposed exemption by a PIC holding an Airman Certificate from the FAA, and current medical or valid US Driver’s License.

 Regarding the Unmanned Aircraft System and its Operation

1. UAS operational characteristics. The UAS’s proposed for operation under this exemption include
the commercially available DJI Phantom and DJI Inspire 1. These systems have both been

prev iously approved by the FAA for Section 333 exemptions. They are both electric quad

- copters weighing significantly less than 55 lbs , with IMU, GPS, and flight systems that are in extensive use for hobbies and recreational purposes; and their flight charact eristics and specifications are
available 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 will be conductedb. No UAS operations exceeding 87 kt groundspeed

c. No operations above 400 feet AGL , or within 500’ below or 2000’ horizontally from a cloud, or when visibility is less than 3 mi from PIC.
d. All operations conducted in daytime V FR 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

- VO verbal communication maintained at all

times.
f. Valid Sec.333 exemption operating documen tation 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. P IC will conduct a full safety pre

- flight inspection prior to each operation. No operation of UAS without ensured condition for safe operation. j. Operator will follow UAS manufacturer’s maintenance, overhaul, replacement, inspection and life limit recommendat ions 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 F AA as a Private Pilot with ratings for Airplane Single Engine Land and Instrument, with training and logbook conditions complete for Commercial certification. Total logged PIC flight time is 256 hrs , with endorsements for High

- performance Complex single

en gine, and Tailwheel. All commercial operations will utilize a Visual Observer, who will receive sufficient training on a safe test range to assure safe and efficient operations and communications prior to deployment on a commercial project.

4. The PIC will m aintain either a FAA medical certification or a valid US driver’s license for all UAS operations.

 Regarding the Mission Protocols 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 operations 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 both 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 t he blanket COA parameters, such as operations within 5 NM of a tower controlled airport will be conducted under individual COA applications submitted through the FAA’s UAS Civil COA Portal.

8. Each UAS data collection mission will be conducted in accordance w ith 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 , restri cted 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 planning will
be done in a G eograph ic 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 described herein, will be complied with.

f) Summary for publication in the Federal Re gister

CC Patt erson & Associates is an enviro nmental consu l ting firm engaged in processing airborne remote

sens ing data for plan ning and monitoring habitat restoration and other conservation projects . In our petition, we request that an exemption be granted from certain regulations defined in 

### 14 CFR 21(H),

14 CFR 43 .7, 43.11, 4 5

. 1 1, 45 .23(b), 45.27, and 45 .29; 14 CFR 61.23(a) and (c), 61.113(a), 91.7(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). These exemptions are similar or identical in na ture to those currently being

gran ted by the FA A under Section 333 for similar survey and mapping operations by other small
businesses.

Appendix 1

FAR section Subject Justification 

### 14 CFR 21(H) Airworthiness Certification Not applicable to small UAS

.

14 CFR 43.7, 43.11, 45.11

, 45.21 , 45.23(b) 45.27, 45.29 D isplay of placards, records and markings on aircraft Not applicable to UAS due to
small size.

14 CFR § 91.119 (c) Minimum safe altitudes Separation from manned aircraft by UAV dictates lower operating altitudes

14 CFR § 91.121 Altimeter settings Not applicable to small UA S

ops

14 CFR § 91.151(a) Fuel requirements Not applicable to small UA S

ops14 CFR § 91. 405 (a) Maintenance Not necessary to assure small

UA S operation safety . PIC inspection substituted in operating procedures

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

ops 14 CFR § 91. 409 ( a1,2 ) Annual inspection Not necessary to assure small

UA S operation safety. Implementing all m anufacturer
recommendations and operator responsibility substituted in operating procedures

14 CFR § 91.4 17 (a, b ) Maintenance records Not necessary to assure small UAV operation safety. Mfg. recs and operator responsibility subst.

Appendix 2

UAS Specification DJI Phantom 3 DJI Inspire 1 

### Aircraft type Quadcopter Quadcopter

Weight 1.20 kg 2.93 kg



### Size (diagonal width) 35 cm 58cm

Maximum Speed 16m/s (36 mph) 22 m/s (49 mph)

GNSS positioning GPS/GLONASS (autonomous) GPS/GLONASS (autonomous)

Payload 12mp digital camera and 3

- axis gimbal 12mp digital camera and 3

- axis gimbalRemote control communications Frequency

range 2.400Ghz

- 2.483Ghz 2.400Ghz

- 2.483Ghz
5.725Ghz

– 5.825Ghz

Max communications range 2000m (unobstructed line of sight) 2000m (unobstructed line of sight)

Flight Battery Capacity/Max Flight Duration 4480mAh/ 23 min (approx) 5700mAh/ 18 min (approx)