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 Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, CC 

Patterson & Associates (CCPA), hereby applies for an exemption from Federal Aviation Regulations 

(FARs) identified below, to allow commercial operations of small unmanned aerial systems.

This exemption would permit commercial operation of the DJI Phantom 3 and DJI Inspire 1 UASs 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 conservation, 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 

projects, primarily in Southern Oregon. This exemption is in support of CCPA’s projected shift to UAVbased data collection operations from sub-contracted manned aircraft operations, for low-altitude, 

high-resolution ortho-imagery and 3D point cloud generation 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 

Certificate 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 45.11, 14 CFR 45.21, 14 CFR 45.23(b), 14 CFR

45.27, 14 CFR 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).

c) Extent of Relief Sought and Reasons for Request:

Attachment A below lists the regulations from which relief is sought, together with the reason why each 

regulation is not consistent with the safe commercial use of UAS to 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 aerial 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 limited 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 expense 

(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 conservation 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 reduction for monitoring the type of small restoration sites where we often work, and 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 data acquisition costs and associated reduction in the overall cost of 

ecological mapping projects they undertake.

e) Reasons why Public Safety would be improved 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 altitudes. With the safety measures, operational limitation and

procedures summarized 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 Nnumber markings in the largest size practicable in accordance 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 

previously 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 characteristics 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 conducted
b. 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 VFR 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 documentation 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. PIC 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 recommendations 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 FAA 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 

engine, 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 maintain either a FAA medical certification or a valid US driver’s license for all UAS 

operations.

 Regarding the Mission Protocols and Areas of Operation 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 500’ 

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 the 

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 with an individualized plan of 

operation that, 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, restricted 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 Geographic Information System 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 Register

CC Patterson & Associates is an environmental consulting firm engaged in processing airborne remote 

sensing data for planning 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, 45.11, 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 nature to those currently being 

granted by the FAA 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

Display 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 UAS

ops

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

ops
14 CFR § 91.405 (a) Maintenance Not necessary to assure small 

UAS operation safety. PIC 

inspection substituted in 

operating procedures

14 CFR § 91.407(a1) Return to service Not applicable to small UAS

ops 14 CFR § 91.409(a1,2) Annual inspection Not necessary to assure small 

UAS operation safety. 

Implementing all manufacturer 

recommendations and 

operator responsibility 

substituted in operating 

procedures

14 CFR § 91.417(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 

gimbal
Remote 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)