February 29, 2016 

Department of Transportation Docket 

Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building 

Ground Floor Washington, DC 

20590-0001

Writer’s Direct Contact +1 

(805) 402-3159 

Chuck@AerialAlchemy.com

Re: Petition of Aerial Alchemy for an Exemption Pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 to Operate Unmanned

Aircraft Systems to Conduct Research & Development and Training

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 C.F.R. Part 11, Aerial Alchemy hereby applies for an exemption from the 

Federal Aviation Regulations identified below to allow for the commercial operation of

Aerial Alchemy multirotors, and fixed wing unmanned sUAS systems to conduct aerial

research, data collection and training.

Aerial Alchemy requests that the FAA review this petition pursuant to its “summary grant” 

process as the FAA has already granted exemptions similar in all material respects to this 

petition. See FAA Grant of Exception Nos. 11062, 11109, 11112, and 11213. The FAA

has specifically granted exemptions to operate UAS to conduct education and training. 

See FAA Grant of Exception No 11552.

STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act.

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the 

FAA Administrator is to permit operation of an unmanned aircraft system (“UAS”) where it

does not create a hazard to users of the national airspace system (“NAS”) or the public or

pose a threat to national security based on the following considerations:

(a) The size, weight, speed and operational capability;

(b) Operation in proximity to airports and populated areas; and

(c) Operation within visual line of sight of the operator.

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Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to

grant exemptions from the agency’s safety regulations and minimum standards when the

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§

106(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect

safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R.

§ 11.81.

REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Aerial Alchemy requests exemption from the following regulations:

(a) 14 C.F.R Part 21, Subpart H;

(b) 14 C.F.R Part 27;

• 14 C.F.R § 45.23(b);

• 14 C.F.R. § 45.27(a);

• 14 C.F.R § 61.113;

• 14 C.F.R § 91.7(a);

• 14 C.F.R § 91.9(b)(2);

• 14 C.F.R § 91.9(c);

• 14 C.F.R § 91.103;

• 14 C.F.R § 91.109(a);

• 14 C.F.R § 91.119;

• 14 C.F.R § 91.121;

• 14 C.F.R § 91.151(a) & (b)

• 14 C.F.R § 91.203 (a) & (b);

• 14 C.F.R § 91.405(a);

• 14 C.F.R § 91.407(a)(l);

• 14 C.F.R § 91.409(a)(2);

• 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the Aerial Alchemy Flight Operation

Manual, (“Manuals”).

DESCRIPTION OF AERIAL ALCHEMY AND ITS SERVICES

Aerial Alchemy was founded to innovate technology for UAS data collection, analysis and 

deployment. Additionally, Aerial Alchemy will provide data collection services for multiple 

purposes including mapping, surveying, inspection, analysis, public safety and general 

videography. Our mission is to enhance commercial UAS data collection and analysis 

capabilities to provide new insights for industry use. Additionally, digital imaging data 

gathering service will be conducted to explore the UAS market as well as provide clients with 

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high quality images and digital data. Aerial Alchemy will be performing research and 

development around UAS data collection as well as operational digital imaging.

Aerial Alchemy is also developing a training curriculum to apply UAS science, technology,

and real world application for first responders. The curriculum is grounded in applied

learning and application ensuring relevant and robust experience in the technical skills for the 

operation and support of a UAS program for emergency situational awareness. The necessity 

of this training course was identified based on findings from the Los Angeles City Fire 

Department.

One of our primary missions as a company is to ensure full compliance with all regulations 

that govern UAS, as such, our operations will be conducted within the acceptable FAA 

regulations with the exception of the herein requested exemptions. Further, the UAS operator 

and observers engaged in operations are expected to be responsible for operating within these 

regulatory parameters. 

DESCRIPTION OF PROPOSED OPERATIONS

Aerial Alchemy is requesting exemptions from applicable Federal Aviation Regulations 

(FARs) pursuant to Section 333 of the Reform Act to conduct research and development to 

create a much better understanding of the applications needed to provide a more direct linkage 

between analytical technologies and real world problems. We specialize in solutions that 

deploy remote sensors aboard a wide variety of both ground based and airborne platforms 

focusing on precision agriculture, public safety, industrial inspection and aerial imaging

Aerial Alchemy proposes to operate small UAS weighing less than 55 pounds, under 400 feet 

and within line of sight in VFR conditions in order to develop and improve UAS technology, 

augment ground based data, train and educate operators on the various use-case applications of 

UAS, provide for a hands-on experience including routine and preventative maintenance. Use 

of a UAS will reduce safety risks because the UAS will not carry flammable fuel or a pilot.

The UAS operations in this petition are similar in all material respects to relief previously 

granted by the FAA in Grant of Exception Nos. 11062, 11109, 11112, 11213, 11552 and 11493. 

The reasons stated by the FAA in granting the exemptions listed above also apply to this 

petition, and the grant of this petition is in the public interest. The public will also benefit by 

virtue of additional employment, safer methods of data gathering, and potentially new 

technologies available to industry.

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AIRCRAFT TO BE OPERATED

A.

B.

C. 

4
D. 

E 

5
A - Fixed Wing

B - Hybrid/VTOL

C - Quadcopter

D - Hexacopter

E - Hexacopter Y6

F - Redundant Quad/X8 

AERIAL ALCHEMY’S PROPOSED OPERATIONS DEMONSTRATE AN 

EQUIVALENT LEVEL OF SAFETY

Aerial Alchemy proposes to operate within the limitations and performance specifications 

listed in the application and in the Aerial Alchemy Flight Manuals. These limitations provide 

for at least an equivalent, or higher, level of safety for operations under the current regulatory 

structure because the proposed operations are safer than conventional operations using 

helicopters or fixed wing aircraft which carry an operator and flammable fuel. The proposed 

flight operations are similar in all material respects to operations already approved by the FAA 

and are therefore subject to the FAA’s “summary grant” process.

The proposed operations do not create any hazard to users of the national airspace system or 

pose a threat to national security. The aircraft are battery operated with a maximum flight time 

of less than 50 minutes. The vehicles weigh less than 55 pounds. The vehicles will be 

operated at or below 400 feet AGL within the visual line of sight of the pilot in command.

Aerial Alchemy’s operations will be over private or controlled access property with the 

permission of the owner/controller or authorized agent.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

proposed UAS carry no fuel, and therefore the risk of fire following an incident or accident 

due to fuel spillage is eliminated. Compared to manned aircraft, the UAS being operated by 

the petitioner reduces the risk to participating persons in close proximity to the aircraft due to 

the limited size, weight, operating conditions, and design safety features.

The petitioner’s aircraft have the capability to operate safely after experiencing certain inflight failures, as specified in the Manuals. The aircraft are also able to respond to a lost-link 

event with a pre-coordinated, predictable, automated flight maneuver.

SPECIFIC LIMITATIONS ON PROPOSED FLIGHT OPERATIONS

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, Aerial Alchemy’s proposed 

operations using Aerial Alchemy UAS’s would “not create a hazard to users of the national 

airspace system or the public or pose a threat to national security.” Reform Act Section 333(b)

(1).

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1. The aircraft weigh less than 55 pounds.

2. Each aircraft will be identified by serial number, registered with the FAA, and have 

identification (N-Number) markings as large as practicable.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC.

5. The PIC will ensure that before each flight, there is enough available power for the 

UAS to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power recommended by the manufacturer if greater.

6. The aircraft will be operated during daylight and in VFR conditions.

7. Flights will not exceed 400 feet AGL.

8. Flights will be operated at a lateral distance of at least 500 feet from any persons or 

property not associated with the operation who have not given prior permission.

9. Flights will be limited to a groundspeed of 100 mph.

10. Minimum crew for each flight will consist of a PIC and an Observer.

11. The PIC will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state or the Federal 

Government. The PIC will also meet the flight review requirements specified in 14 

CFR § 61.56.

12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the 

flight as well as contact information for the PIC.

13. The flight operations will yield the right of way to other manned aircraft 

operations.

14. All persons who are not involved with Aerial Alchemy’s operations will be 

required to be at least 500 feet from flight operations.

15. The aircraft will only operate over private or controlled access property with the 

permission of the owner/controller or authorized representative.

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16. The UAS will not operate within 5 nautical miles of an airport unless a letter of 

agreement is obtained.

17. All required permissions and permits will be obtained from territory, state, county 

or city jurisdictions prior to flight.

18. Prior to commencing operations, Aerial Alchemy will obtain a Certificate of 

Waiver or Authorization (COA) from the FAA.

19. If the aircraft loses communications, it will have the capability to return to a predetermined location within the operational area and land.

20. If the aircraft loses its GPS signal it will have the capability of being flown 

manually to a predetermined location within the operational area and land.

21. The flight will be aborted in case of unpredicted obstacles or emergencies.

22. UAS operations will be conducted within the parameters of the Manuals.

FLIGHT RECOVERY, LOST COMMUNICATIONS, AND LOST GPS PROCEDURES

The flight recovery, lost communications, and lost GPS procedures are more fully documented 

in the attached UAS Manual.

SPECIFIC FAR EXEMPTIONS REQUESTED

Aerial Alchemy seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 

45, 61, and 91 for purposes of conducting the requested operations using Aerial Alchemy 

UAS’s. Listed below are (1) the specific FAR sections for which exemption is sought, and (2) 

the operating procedures and safeguards that Aerial Alchemy has established which will ensure 

a level of safety better than or equal to the rules from which exemption is sought. See 14 

C.F.R. § 11.81 (e).

14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met with this petition, and 

therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 

2014-0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of 

Aerial Alchemy UAS’s that fail to meet the requirements of the Reform Act, an exemption is 

requested.

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Equivalent Level of Safety: Aerial Alchemy UAS’s are safe when taking into account their 

size, weight, speed, and operational capability. They weigh less than 55 pounds and will be 

flown at speeds less than 100 miles per hour, and in visual line of sight of the operator. The 

UASs do not carry pilots, passengers, explosive materials, or flammable liquid fuels. The 

UASs will be operated within the parameters of their respective Manuals.

The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or 

fixed wing aircraft operating with an airworthiness certificate without the restrictions and 

conditions proposed here.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that Aerial Alchemy UAS’s would otherwise require 

certification under Part 27, Aerial Alchemy seeks an exemption from Part 27’s airworthiness 

standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, 

Subpart H.

14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and 

Identification Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport, “experimental,” or “provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft “have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as 

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practicable.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.

Equivalent Level of Safety: Aerial Alchemy will mark UAS’s with their N-Number in a 

prominent spot on the fuselage with markings that are as large as practicable.

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

Aerial Alchemy seeks exemption from 14 CFR § 61.113, which restricts private pilots from 

flying aircraft for compensation or hire and would also require a second class medical 

certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if 

the pilot is carrying passengers or cargo for hire.

While the UAS will be operated as part of a commercial operation, they carry neither 

passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the 

FAA determined that the unique characteristics of UAS operation outside of controlled 

airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to 

have a commercial pilot certificate and a class II medical certificate. The FAA has also 

determined that the required knowledge for a commercial pilot covers the same fundamental 

principles as a private pilot.

The FAA has also granted exemptions allowing operations by people who hold an airline 

transport, commercial, private, recreational, or sport pilot certificate with a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state or the Federal 

Government. The PIC must also meet the flight review requirements specified in 14 CFR §

61.56. See FAA Exemption No. 11374.

Aerial Alchemy will ensure the PIC will meet the requirements listed in the above paragraph. 

Aerial Alchemy will also ensure the PIC will have completed the manufacturers’ training 

guidelines outlined in the Manuals.

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the 

airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make 

and model experience, culminating in verification through testing.” See Exemption No.

11062, Docket No. FAA 2014-0352, at p. 18. The proposed operations can achieve an 

equivalent level of safety by requiring the knowledge and experience in Aerial Alchemy 

UAS’s operations described above.

The restrictions Aerial Alchemy has placed on its UAS operations meet or exceed the 

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restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352 and 

those listed in the FAA’s “summary grant” process.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Aerial Alchemy seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, Aerial Alchemy requests that the requirements for Section 91.7 be treated in 

accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft -

 ...

(2) For which an Airplane or Rotorcraft Flight Manual is required by §

21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

• Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

• An appropriate and current airworthiness certificate...

• No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under § 

91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew.

Aerial Alchemy does not request an exemption from this section but instead notifies the FAA 

that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the 

UAS flight manual, registration certificate and other documentation will be kept at the control 

station with the PIC during flight. The Chief Counsel’s Office has held that for all UAS 

operations, this alternate method constitutes full compliance with the regulations. See also 

Grant of Exemption No. 11062, pp. 19-20, and Grant of Exemption No. 8607.

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14 C.F.R. § 91.103: Preflight Action

Aerial Alchemy seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual 

on board. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. Under these circumstances, the FAA has stated that no exemption is required. See Grant 

of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAAapproved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The Manuals will be kept at the ground station with the operator at all times.

14 C.F.R. § 91.109(a): Flight Instruction

Aerial Alchemy seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of the Ground Control Station (GCS) that communicates with 

the aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on board 

the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no 

safety hazard. Given the size and speed of the UAS, an equivalent level of safe training can 

still be achieved without dual controls because no pilot or passengers are aboard the aircraft, 

and all persons will be a safe distance away in the event that the aircraft experiences any 

difficulties during flight instruction. In addition, Aerial Alchemy will conduct flight training at 

a remote facility away from population centers. These training flights will comply with the 

provisions in the Manuals. Accordingly, Aerial Alchemy’s proposed method of operation 

provides superior levels of safety.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

Aerial Alchemy requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. The Manuals provide for Aerial 

Alchemy operations at least 500 feet from persons and structures not involved in the 

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operations. The FAA has already determined that relief from Section 91.119(c) is warranted for 

UAS operations in uncongested areas with similar flight restrictions as those imposed by 

Aerial Alchemy. See Grant of Exemption No. 11062, p. 20-21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft or fixed wing 

aircraft weighing far more than the maximum weights proposed herein, and given the lack of 

flammable fuel, any risk associated with these operations is far less than those that presently 

exist with conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS, as well as the locations where it is operated . In order to avoid 

any risk to aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft 

are already prohibited from operating closer than 500 from structures where Aerial Alchemy 

proses to operate. This is airspace where other aircraft do not normally operate. As set forth in 

the Manuals and herein, the UAS will be operated in the remote sites, away from persons or 

structures not involved in the operation. All persons who are not involved with Aerial 

Alchemy’s operations will be required to be at least 500 feet from flight operations. This will 

pose no risk to the public because other aircraft are not operating in these areas.

14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating 

an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to 

the elevation of the departure airport. The UASs proposed here use both barometric pressure 

sensors and GPS to determine altitude but do not have the ability to set in a current altimeter 

setting. An exemption is required to the extent that the UAS does not have a barometric 

altimeter setting. The altitude of the UAS is monitored by the PIC on the ground control 

station and by the visual observer.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-ofsight in addition to GPS based altitude information relayed in real time to the operator. See 

Grant of Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the UAS will be 

operated at or below 400 feet AGL and otherwise comply with the limitations in the Grant of 

Exemption No. 11062.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Aerial Alchemy requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for 

flight in VFR conditions. Section 91.151 states:

• No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed -

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• During the day, to fly after that for at least 30 minutes; or

• At night, to fly after that for at least 45 minutes.

Here, the technological limitations on the UAS battery power means that no meaningful flight 

operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery 

powered with a maximum flight time of approximately 50 minutes for the FIXED WING, 20 

Minutes for the MULTIROTORS and 25 minutes for the VTOL. The PIC will ensure that 

before each flight, there is enough available power for the UAS to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided 

if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and 

terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 

11062, p. 21-22. The FAA’s “summary grant” process provides that the PIC is prohibited from 

beginning a flight unless there is enough available power to conduct the intended operation 

and to operate after that for at least five minutes or with the reserve power recommended by 

the manufacturer if greater. See FAA Exemption No. 11374 (FAA Docket No. 2015-0091 at p. 

5). The limitations here provide that the PIC will ensure that before each flight, there is enough 

available power for the UAS to conduct the intended operation and to operate after that for at 

least five minutes or with the reserve power recommended by the manufacturer if greater.

14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) 

and (b): Maintenance Inspections

Aerial Alchemy seeks an exemption from the maintenance inspection requirements contained 

in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations 

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 

C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections ... have 

discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these 

regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS proposed here will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the Manuals. This includes 

maintenance, overhaul, replacement, and preflight inspection requirements. See Exemption 

No. 11062 (FAA Docket No. 2014-0352, at p. 14-15) and Exemption No. 11374 (FAA Docket 

No. 2015-0091, at p. 4).

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Aerial Alchemy will follow the UAS manufacturer’s maintenance requirements. Flights will 

not be conducted unless a flight operations checklist is performed that includes all of the 

aircraft’s components.

PUBLIC INTEREST

Granting Aerial Alchemy’s petition for exemption furthers the public interest. National policy 

set by Congress favors early integration of UAS into the NAS in controlled, safe working 

environments such as proposed in this petition. By granting this petition, the FAA will fulfill 

Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rule 

making required under Section 332 of the Reform Act.

Moreover, use of UAS will promote science and technology education for high school and 

middle school students. The use of the UAS propped here will also decrease safety-related 

incidents involving traditional aircraft. The public has an interest in promoting science and 

technology education and in reducing the hazards and emissions associated with alternate use 

of helicopters and small airplanes to conduct similar operations.

PRIVACY

All flights will occur over private property either owned by Aerial Alchemy or with the 

owner’s consent. All flights will be conducted in accordance with any federal, state or local 

laws regarding privacy.

SUMMARY FOR FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Aerial Alchemy seeks an exemption from the following rules for aeronautical and UAS 

training and education of middle and high school students: 14 C.F.R Part 21, Subpart H; 14 

C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 

91.7(a); 14

C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R §

91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14

C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a)

& (b).

The exemption will promote science and technology education and training while enhancing 

safety by reducing risk to the operator, the general public and property owners from the 

substantial hazards associated with performing equivalent training and education using 

traditional conventional aircraft and rotorcraft.

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Aerial Alchemy requests that the FAA grant this petition using the “summary grant” process 

such that publication in the Federal Register is not required. This petition would not set a 

precedent, and any delay in acting on this petition would be detrimental to the petitioner.

ATTACHMENTS

Attachment 1: Aerial Alchemy Flight Operation Manuals 

If you have any questions or require any additional information, please do not hesitate to 

contact the undersigned attorneys for Aerial Alchemy Corp.

CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line 

of sight, and national security considerations - provides more than adequate justification for 

the grant of the requested exemptions to permit Aerial Alchemy to operate the UASs proposed 

here. Furthermore, this petition warrants review by the FAA under the “summary grant” 

process for immediate approval.

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