Alpine UAS Corporation, Eagle River AK - Section 333 

Exemption Petition 

March 26, 2015 

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a);

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam, 

I, Nicholas Morrison, am writing pursuant to the FAA Modernization and Reform 

Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, 

Nicholas Morrison, an owner and operator of small unmanned aircraft (N9147T), 

be exempted from the Federal Aviation Regulations (“FARs”) listed below so that 

I, Nicholas Morrison, may operate my small ultra light weight unmanned aircraft 

system (N9147T) or (“UAS”) commercially in airspace regulated by the Federal 

Aviation Administration (“FAA”). 

As described herein I, Nicholas Morrison, have added a professional grade quadcopter UAS (DJI Inspire Pro) to my inventory equipped with a DJI Zenmuse X5 

camera with intent for aerial videography/cinematography and aerial data 

collection to enhance academic community awareness for those individuals and 

companies unfamiliar with the geographical layout of the Anchorage area, and 

pursue implementation of emergency use UAS systems with public entities,

following exemption and approval by the FAA. This will allow for enhancement of 

the academic research experience for the Anchorage area. 

I have flown small RC aircraft for over fourteen (14) years without incident. I 

currently hold a private pilot certificate as well as an instrument rating. I am 

committed to safety with each flight. My, Nicholas Morrison's, exemption request 

would permit operation of ultra light weight, unmanned (piloted by remote control) 

and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. 

Predetermined in areas away from general public, airports, heliports and 

vehicular traffic for community videos, and within property boundaries for 

individual homeowner real estate listing videos/photos. Currently, lightweight

remote controlled UAS's are legally operated by unmonitored amateur hobbyists 

with no safety plan or controls in place to prevent catastrophe. I, Nicholas 

Morrison, have personally instilled safety protocols, sterile cockpit rule and 

checklists prior to operation. This will act to further safety protocols exclusive to 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

lightweight UAS's specific to real estate video and photography usage as I, 

Nicholas Morrison, record flight 

data and other information gained through permitted flight operations to share 

with the FAA through any required FAA reports to assist with future protocol and 

safety regulation. 

Granting my, Nicholas Morrison's, request comports with the Secretary of 

Transportation’s (FAA Administrator’s) responsibilities and authority to not only 

integrate UAS's into the national airspace system, but to “...establish 

requirements for the safe operation of such aircraft systems [UAS's] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for Aerial Surveying and Search and Rescue Systems. 

Further I, Nicholas Morrison, will conduct my operations in compliance with the 

protocols described herein or as otherwise established by the FAA. 

For the reasons stated below I, Nicholas Morrison, respectfully request the grant 

of an exemption allowing me to operate ultra light weight, remote controlled 

UAS’s for academic community awareness to benefit/stimulate attraction to the 

Anchorage area and to enhance real estate listing videos for homeowners who 

cannot afford expensive manned aircraft for the same purpose. Both of which will 

promote local economic growth through increased employment and increased 

tax base. Both with public safety in mind by keeping heavier manned aircraft 

containing combustible fuel that that poses potential public hazard. 

I. Contact Information: 

Nicholas Morrison, Alpine UAS Corporation

10021 Lee Street Eagle River, AK 99577 Office: (907)-952-0230

Email: akmorrison.nick@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations 

From Which Nicholas Morrison Requests Exemption are:

14 CFR 21; 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 

III. The Extent of relief Nicholas Morrison seeks and the Reason He Seeks 

Such Relief: 

I, Nicholas Morrison, submit this application in accordance with the 

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable 

FARs operating to prevent me, Nicholas Morrison, from commercial cinematic, 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

academic and other flight operations within the national airspace system. The 

Reform Act in Section 332 provides for such integration of civil unmanned aircraft 

systems into our national airspace system as it is in the public’s interest to do so. 

My, Nicholas Morrison’s, ultra light weight UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of my 

ultra light weight UAS is expressly contemplated by the Reform Act. I would like 

to operate my ultra light weight UAS prior to the time period by which the Reform 

Act requires the FAA to promulgate rules governing such craft. Thereby, 

providing direct experience and valuable information for formal regulation that 

can be administered uniformly to all real estate related UAS aerial video and 

photography. The Reform Act guides the Secretary in determining the types of 

UAS's that may operate safely in our national airspace system. Considerations 

include: The weight, size, speed and overall capabilities of the UAS's; Whether 

the UAS will be operated near airports or heavily populated areas; and, Whether 

the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these 

items reflect in favor of an exemption for me, Nicholas Morrison. My UAS utilizes 

four (4) counter-rotating propellers for balance, control and stability. My UAS is 

equipped with GPS and auto return safety technology. Additionally, my UAS 

weighs less than eight (8) pounds (far below the maximum 55 pound limit);

including camera with gimbal. 

I, Nicholas Morrison, consider safety foremost with each flight. My small, 

unmanned aircraft is designed to hover in place via GPS and operate in less than 

a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly 

in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode 

that allows my UAS to hover in place when radio controls are released.

Smart Mode for aerial videography/photography. This is the safest, most reliable 

and stable mode to prevent accident and hazard. When pilot communication is 

lost the UAS is designed to slowly descend to the known point of takeoff or the 

last point at which radio communication was received. I do not operate my UAS 

near airports, Hospitals nor Police heliports, and do not operate near areas 

where general public is within fifty to one hundred (50-100) yards depending on 

location, conditions and weather. I am constantly on alert for any manned aircraft 

(Police/Medical helicopters, etc.) and prepared to land/abort immediately to the 

nearest and safest ground point should a manned aircraft approach my location 

or I suspect manned aircraft may approach near my location. I call in to local Air 

Traffic Control to alert of my flight plan and operations as well as calling back 

when operations are complete. My UAS is capable of vertical and horizontal 

operations, and is flown only within my line of sight of me, as the remote control 

pilot. Utilizing battery power rather than combustible fuels, flights generally last 

between twelve (12) to seventeen (17) minutes, with an altitude under one 

hundred fifty (150) feet. 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

I, Nicholas Morrison, utilize a fresh fully charged smart battery with each flight as 

a safety precaution; full flight time limit for each battery is eighteen (18) to twenty 

(20) minutes as tested. I do not operate my UAS at or below manufacture

recommend minimum charge levels for operation or exceed temperature ratings 

as per manufactures request; preferring to remain well within a safe operating 

range to insure adequate communication between radio control and UAS to 

eliminate potential for crash, loss of control or hazard. Reserve batteries are at 

hand with each exercise to insure replacement for sufficient safe level of 

operation. I do not believe in taking risk that may cause a crash that could create 

hazard to the public/property/manned aircraft, and have no desire to lose an 

investment. I have clocked numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use to gain familiarization with 

the characteristics of this specific UAS's performance under different temperature 

and weather conditions. I also practice computerized simulated flights to maintain 

adequate skills and response time. 

I, Nicholas Morrison, am extremely cautious when operating of my UAS/ultra light 

weight unmanned aircraft and will not “create a hazard to users of the national 

airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and 

weight of my UAS it falls well within Congress’s contemplated safety zone when 

it promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. Nicholas Morrison’s UAS, used in hobby flight, 

has a demonstrable safety record and does not pose any threat to the general 

public or national security. 

IV. How Nicholas Morrison Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters. 

For small budget production companies and average homeowners the expense 

of such aerial videography is cost prohibitive. Only large companies and high end 

film companies can afford to absorb such expense. Which is where the option of 

less expensive unmanned systems becomes affordable to anyone. Manned 

aircraft pose a threat to the public through potential catastrophic crashes that 

Alaska has come to expect every year. Anchorage area is a very busy airspace, 

which is why I am pursuing a 333 Exemption to lead the way for other 

businesses and or enthusiast. My main goal is to prove to public that my UAS 

can be used in Fire, Police or natural disaster relief. My, Nicholas Morrison's, 

UAS pose no such threat since size and lack of combustible fuel alleviates any 

potential threat to the public. 

Congress has already proclaimed that it is in the public’s interest to integrate 

commercially flown UAS's into the national airspace system, hence the passing 

of the Reform Act. Granting my, Nicholas Morrison’s, exemption request furthers 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

the public interest through academic/visual awareness of the geographical 

benefits in and around the Anchorage area. My ultra light weight UAS is battery 

powered and creates no emissions that can harm the environment. The 

consequence of my ultra light weight UAS crashing is far less than a full size 

helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and 

contain enough kinetic energy that a failure can cause catastrophic devastation 

to the public. 

The public’s interest is furthered by minimizing public threat by permitting aerial 

video/photo capture through my battery operated ultra light weight UAS's. 

Permitting me, Nicholas Morrison, to immediately fly within national air space 

furthers economic growth. Granting my exemption request substantially furthers 

the economic impact for the Anchorage community for companies looking to 

relocate or build in the Anchorage area as well as individuals looking to relocate 

for career advancement through academic and geographical awareness. Both of 

which serve as a stimulus to the community. 

V. Reasons Why Nicholas Morrison's Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal 

To Existing Rule: 

My, Nicholas Morrison’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, Nicholas Morrison, to log more 

flight time in FAA controlled airspace, with communication with the FAA, will 

allow me to contribute to the innovation and implementation of new and novel, as 

of yet undiscovered safety protocols. 

I, Nicholas Morrison, submit the following representations of enhancements to 

current aerial videography, photography and aerial surveying aspects: 

 My UAS (DJI Inspire Pro) weighs less than 8 pounds complete with a 

small ultra light weight high quality DJI Zenmuse X5 camera. 

 I only operate my UAS below 200 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012.) 

 My UAS only operates for 12-20 minutes per flight. 

 I land my UAS prior to manufacturer recommended minimum level of 

battery power. 

 I pilot my UAS through remote control only by line of sight. 

 My UAS has GPS a flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost. 

 I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols. 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

 I only operate in reasonably safe environment that are strictly controlled, 

are away from power lines, elevated lights, airports and actively populated 

areas. 

 I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance. 

 I always obtain all necessary permissions prior to operation. 

 I have procedures in place to abort flights in the event of safety breaches 

or potential danger. 

My, Nicholas Morrison’s, safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into our national airspace system, helicopters are the primary 

means of aerial video and photography for community awareness and real 

estate. While the safety record of such helicopters is remarkable, it is far safer to 

operate a battery powered ultra light weight UAS. 

 First, the potential loss of life is diminished because UAS's carry no people 

on board and I only operate my UAS in specific areas away from mass 

populations. 

 Second, there is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished. 

 Third, the small size and extreme maneuverability of my UAS allow me to 

remotely pilot away from and avoid hazards quickly and safely. 

 Lastly, given its small size and weight, even when close enough to capture 

amazing images, my UAS need not be so close to the objects they are 

focused on through the technology and use of post editing software 

allowing pan and zoom. 

Accordingly, my UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above 

current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The 

Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, 

Nicholas Morrison’s, UAS permits exemption from Part 21 because my 

UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 

of the Reform Act. The FAA is authorized to exempt aircraft from the 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of 

the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. My, Nicholas Morrison’s, current and projected UAS's 

meet or exceed each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual delineating areas of where safety can be 

defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS 

utilizes electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining 

any such required certifications and registrations by me, Nicholas Morrison. 

2. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant 

to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non--

commercial operations. I, Nicholas Morrison, can achieve an equivalent 

level of safety as achieved by current Regulations because my UAS does 

not carry any pilots or passengers. Further, while helpful, a pilot license 

will not ensure remote control piloting skills. The risks attended to the 

operation of my UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing 

me, Nicholas Morrison, to operate my UAS meet and exceed current 

safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

3. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil 

aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. My UAS will never operate at an altitude greater than 200 feet 

AGL; safely below the standard of 400 AGL. I, Nicholas Morrison, will 

however operate my UAS in safe areas away from public and traffic, 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

providing a level of safety at least equivalent to or below those in relation 

to minimum safe altitudes. Given the size, weight, maneuverability and 

speed of my UAS, an equivalent or higher level of safety will be achieved. 

4. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. 

The above-cited Regulations require, amongst other things, aircraft 

owners and operators to “have [the] aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...”

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my, Nicholas Morrison's, UAS. However, as a safety 

precaution I inspect my UAS before and after each flight. 

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 

14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed operational area of my UAS permits 

exemption from Part 21 because my, Nicholas Morrison’s, UAS meets an 

equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under 

both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. 

My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the 

operation of an aircraft without an airworthiness certificate. As no such certificate 

will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the 

aircraft. As there are no pilots or passengers, and given the size of the UAS's, 

this Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a manual. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, maintenance program that involves regular software updates and curative 

measures for any damaged hardware. Therefore, an equivalent level of safety 

will be achieved. 
Alpine UAS Corporation, Eagle River AK - Section 333 Exemption Petition 

In summary, Nicholas Morrison seeks an exemption from the following 

Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 

C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 

91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 

14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. §§ 91.417 (a) & 

(b) to commercially operate my, Nicholas Morrison’s, small unmanned 

vehicle/lightweight unmanned aircraft vehicle in community awareness and real 

estate operations, aerial data collection, videography/cinematography, and to 

develop economic platforms for real estate to enhance the experience of those 

seeking to relocate to the Anchorage area. Currently, area awareness and real 

estate aerial videography/photography relies primarily on the use of larger aircraft 

running on combustible fuel. Posing potential risk to the public. Granting my, 

Nicholas Morrison’s, request for exemption will reduce current risk levels and 

thereby enhance safety. My UAS craft does not contain potentially explosive fuel, 

is smaller, lighter and more maneuverable than conventional real estate video 

and photographic aircraft with much less flight time. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and 

from established airfields. I, Nicholas Morrison, have been informally analyzing 

flight information and will compile safety protocols and the implementation of a 

flight operations manual for usage that exceeds currently accepted means and 

methods for safe flight. Formal collection of information shared with the FAA will 

enhance the FAA's internal efforts to establish protocols for complying with the 

FAA Modernization and Reform Act of 2012. There are no personnel on board 

my, Nicholas Morrison’s, UAS and therefore the likelihood of death or serious 

bodily injury is significantly diminished. My, Nicholas Morrison’s, operation of my 

UAS, weighing less than 8 pounds and traveling at lower speeds within limited 

areas will provide an equivalent level of safety as that achieved under current 

FARs. Accordingly I, Nicholas Morrison, respectfully request that the FAA grant 

my exemption request and am willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large. 

Respectfully, 

Nicholas Morrison, Owner / Manager Alpine UAS Corporation

10021 Lee Street, Eagle River AK 99577