July 13, 2015

U. S. Department of Transportation Docket Management 

System 1200 New Jersey Ave SE 

Washington, DC 20590

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, Alaska Aerial Services, operator of Small Unmanned Aircraft Systems 

(“sUASs”) equipped to offer on-demand commercial UAS operations for a host of industries and 

applications, hereby applies for an exemption from the Federal Aviation Regulations, stated 

later, in the operation/mission:

• Aerial Data Collection

Alaska Aerial Services requests to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA in the future in the Federal Aviation Regulations or official guidelines for 

operators at large, should those be less restrictive.

AIRCRAFT

The aircraft requested for operation have been approved by other exemption holders and are 

as follows:

Aircraft Previously Approved Exemption Number

F450 11287

F550 11397

S800, S1000 11401

S900 11256

X8, AERO-M (aka Skywalker 1900) 11379

Alaska Aerial Services’ sUAS are rotorcraft and fixed wing aircraft, weighting 55 or fewer lbs. 

including payload, and flown well under 100mph. Such operating conditions ensure that the 

sUAS will "not create a hazard to users of the national airspace system or the public.”
The DJI F450, F550, S800, S900 and S1000 are from a family of multirotor frames manufactured 

by DJI and frequently used by both hobbyists and professionals for use in aerial filming, 

mapping, and surveying applications. The aircraft are electric propulsion and capable of manual 

and autonomous flight. 

The Aero-M is a modified version of the SkyWalker 1900 outfitted and sold by 3DR Robotics. It 

is a fixed wing aircraft with 45 minute endurance made of foam with an extremely low impact 

energy and flying speed. All aircraft in this request have been included in other successful 

Section 333 exemption requests and have been staple aircraft around the world for years. 

All our aircraft are outfitted with the APM or Pixhawk autopilots-- intelligent and well-tested 

pieces of control hardware that are in use in numerous other aircraft flying under previously 

granted exemptions.

These autopilots allow for return to home functionality in the event of a loss of communication 

link between the aircraft and PIC and also allow a geofence to be set up that will not allow the 

PIC or autopilot to accidentally fly out of the pre-determined safe flight area. Both of these 

features are very useful to help the flight crew ensure that safety and privacy concerns are met.

Especially in the case of the Pixhawk autopilot, there are dual independent sensor sets for both 

IMU suite, barometer, and compass. The autopilot also supports dual GPS, RTK GPS, laser 

altimeter, and sonar. Safety in further increased by redundant power supplies, independent 

attitude, navigation, and communication software loops, and a completely independent second 

processor for manual control and communication in the unlikely case of total system failure in 

flight. 

SPECIFIC EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Alaska Aerial Services requests an exemption from the following FAR’s:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. The

FAA and drone industry continue to develop airworthiness standards for Unmanned Aerial 

Systems. Until then we request an exemption from this FAR be issued for the aircraft requested 

in this petition on the basis they meet the “statutory criteria provided in Section 333 of Public 

Law 112−95 in reference to 49 U.S.C. § 44704, and in consideraon of the size, weight, speed, 

and limited operating area” associated with the proposed uses will fulfill an equivalent level of 

safety to 14 CFR Part 21. All aircraft we are requesting be included in our Section 333 

exemption for have been approved by the FAA for this use case in other applications.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations require that each aircraft must display an "N" number in letters at least 3 

inches high. sUAS may not be large enough to meet the size requirements stated. We propose 

to affix the aircraft’s “N” number “as large as practicable” to the aircraft as per the FAA’s 

guideline in bullet point #22 in typical Section 333 exemptions.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in

Command of an aircraft for compensation or hire. We propose an equivalent level of safety by 

observing the FAA’s guideline in bullet point #13 in typical Section 333 exemptions where a PIC 

of an sUAS must hold least a Sport Pilot certificate and, for medical testing, at least a Driver’s 

License and the PIC will maintain currency in their type and category of manned aircraft.

14 CFR 91.7 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 and we defer to the reasoning stated above in respect to 14 CFR 45.23.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved

flight manual is in the aircraft. As no persons are in the aircraft to benefit from reading the 

manual and the aircraft is unlikely to be large enough to carry a manual, we propose an 

equivalent level of safety by ensuring an operating manual provided by the manufacturer, and 

including supplemental material generated by Alaska Aerial Services’ chief pilot and engineers, 

be included at the ground station accessible by the PIC and VO as per the FAA’s guideline in 

bullet point #7 in typical Section 333 exemptions.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls.” In the case of sUAS dual 

controls are not possible in the same way as in typical training manned aircraft. Additionally, 

sUAS are typically “flown” by an autopilot and manual manipulation of flight controls is an 

unusual flight condition allowed as a backup if the autopilot malfunctions. Given the nature of 

unmanned aircraft operations we propose an equivalent level of safety by the rules and 

procedures required in the FAA’s guideline in bullet point #7 in typical Section 333 exemptions.

91.119 Minimum safe altitudes:

This regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the maximum height allowed by 

a Section 333 Exemption’s blanket COA is 400ft this is not possible. In order to maintain an 

equivalent level of safety we propose to adhere to the 500ft separation from non-participating 

people, property, and structures as per the FAA’s guideline in bullet point #26 in typical Section 

333 exemptions.

CFR 91.121 Altimeter settings.

This regulation requires that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400

feet AGL and will not need to maintain VFR or IFR cruising altitudes. Since the aircraft will 

always be flying in reference to AGL altitudes, and uses both a GPS and dual Barometers that 
automatically set a new “zero altitude” at power up, the aircraft’s local altitude setting is of 

more than sufficient accuracy to maintain 400ft AGL altitudes and would not require local 

pressure altitude data for cruising altitude traffic separation purposes.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. The intention of this regulation is to provide adequate fuel reserve 

for handling unforeseen difficulties during landing. Since sUAS only fly within line of sight of the 

operator and only a few a minutes at a time the reserve amount of fuel required to deal with 

unforeseen difficulties is much less than manned aircraft. In order to maintain an equivalent 

level of safety we propose to adhere to a 5 minute reserve flight time upon landing as per the 

FAA’s guideline in bullet point #20 in typical Section 333 exemptions.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned

to the aircraft and a registration certificate must be aboard the aircraft. Since this is not 

possible on an sUAS we propose to achieve an equivalent level of safety and meet the intent of 

91.203 by providing the certification and registration materials required for this aircraft with 

the crew at the ground control station and available for inspection upon request as per the 

FAA’s guideline in bullet point #23 in typical Section 333 exemptions.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation compels that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance

and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in

addition conduct detailed inspections after every flight. We believe this, along with the FAA’s 

guidelines in bullet points #8-#12 in typical Section 333 exemptions, provide for an equivalent 

level of safety.

PUBLIC BENEFIT

Approval of this request would benefit the public by allowing Alaska Aerial Services to provide 

aerial data collection in a safe and professional manner under FAA guidelines. 

Alaska Aerial Services plans to work closely with the local FAA test site located within the 

University of Alaska, Fairbanks to help conduct research into UAS integration and safe UAS 

practices. 

Additionally, many of the aerial data collection use cases for sUAS our company has received

requests for such as fish counting, forest surveys, wildlife surveys, and aerial filming are 

conducted by manned aircraft. These operations require very low and slow flight for adequate 
surveys to be done which presents a great hazard to the pilots, scientific passengers, and 

people on the ground. There have been deaths in recent years in Alaska both in fish counting 

and wildlife surveys where stall/spin situations were encountered at only a few hundred feet. 

These are the types of low and slow operations where unmanned aircraft are likely to save 

lives, collect better data, and benefit the public as a whole.

ADDITIONAL INFORMATION

Alaska Aerial Services is comprised of engineers, manned aircraft pilots, remote control aircraft 

pilots, and experienced UAV operators. We have at various times been engineers and operators 

for, and still work closely with, the FAA test site at the University of Alaska, Fairbanks, and have 

years of experience in each of the preciously stated competencies.

Alaska Aerial Services believes that good cause exists for not publishing a summary of this 

petition in the Federal Register because the requested exemption would not set a precedent, 

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

The name and address of the applicant is:

Alaska Aerial Services 

3875 Geist Rd Ste E #210

Fairbanks, AK 99709 

info@alaskaaerialservices.com

Expeditious processing of this request is greatly appreciated.

Sincerely,

Carl France

Alaska Aerial Services