Patrick MacAllister Date: 12/30/15

DBA, Aerial Optics Exemption No. 11430 

P.O Box 26 Regulatory Docket No. FAA–2015–0170

Humarock MA 02047 

(781)588-3259 

Patrick@aerialoptics.net

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

To who it may concern, 

Patrick MacAllister DBA, Aerial Optics would like add Search and Rescue, SAR and to our existing 

exemption No. 11430.

For us to operate emergency Search and Rescue missions effectively Aerial Optics is requesting

relief from two provisions imposed on us under our existing COA and section 333 exemption.

1. The requirement to issue a NOTAM

 D. Notice to Airmen (NOTAM). A distant (D) NOTAM must be issued when unmanned 

aircraft operations are being conducted. This requirement may be accomplished: a. 

Through the operator’s local base operations or NOTAM issuing authority, or b. By 

contacting the NOTAM Flight Service Station at 1-877-4-US-NTMS (1-877-487- 6867) not 

more than 72 hours in advance, but not less than 24 hours prior to the operation, unless 

otherwise authorized as a special provision. The issuing agency will require the: (1) Name 

and address of the pilot filing the NOTAM request (2) Location, altitude, or operating area 

(3) Time and nature of the activity. 

The urgency of a SAR mission does not allow for a 24 hour wait time to issue a NOTAM.

Before the start of all search missions Aerial Optics will notify all airports in the vicinity of our

activities and monitor air traffic via handheld radio during the flight.

2. The 500’ Rule

 26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that 

sufficiently protect nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such protection and 

are within 500 feet of the UA, flight operations must cease immediately in a manner 

ensuring the safety of nonparticipating persons; and b. The owner/controller of any 

vessels, vehicles or structures has granted permission for operating closer to those objects 
and the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

The 500’ Rule is extremely difficult to adhere to especially with all of the parties involved in a 

Search and Rescue mission. We take great care of our sUAS and do everything we can to prevent 

incidents. At Aerial Optics safety is our main concern of every flight. Also unlike most sUAS Aerial 

Optics sUAS all carry a minimum of 1 Million dollars in liability insurance.

CONCLUSION 

By granting Patrick MacAllister DBA, Aerial Optics these additional exemptions, the FAA will help 

drive development of safe and successful commercial UAS operations and will advance the public 

knowledge base for such operations of sUAS. Aerial Optics is committed to promoting the UAS 

research efforts of policymakers by sharing data from its commercial UAS operations and serving 

as a resource for future UAS research operations. 

As pointed out in my original 333 application, all the sUASs which our company would use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of sight 

of the Pilot-in-Command (PIC), less than 400 feet above the ground and away from any airport or 

location with aviation activities, unless the air traffic control authorities (ATC) have been notified. 

Thank you, 

Patrick L MacAllister, D.B.A Aerial Optics