UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

Reg. Docket No.________________________

In the Matter of the Petition for Applicant

Alternatives Renewable Solutions, LLC

For an Exemption from the Requirements of the

Code of Federal Regulations Sections

Concerning Operations of Unmanned Aircraft Systems

Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012

Contact Information: Alternatives Renewable Solutions, LLC

Point of Contact: Dr. Daanen Strachan

Phone: 800-759-7813 x 202

Email: daanens@arsconsulting.net

Address: 1725 I Street, NW, Suite 300, WDC 20006

URL: www.arsconsulting.net
May 23, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., S.E.

Washington, D.C. 20590

RE: Exemption Request from Section 333 of the FAA Modernization and Reform Act of

2012, Parts 21, 27, 45, 61, 91, and 93 of Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Parts 21, 27,

45, 61, 91, and 93, Alternatives Renewable Solutions, LLC (“Petitioner”), a construction and engineering

firm, hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial

operations of both Micro Unmanned Aircraft Systems (mUAS) and Small Unmanned Aircraft Systems

(sUAS) for conducting aerial public safety inspections and photography of vacant/and or occupied

buildings, temporary tower crane assembly verification, construction activities for compliance

determination, and substructure bridge inspections, so long as such operations are conducted within and

under the conditions outlined here in or as may be established by the FAA as required by Section 333. We

seek an exemption from the following regulations:

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

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

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

Requirements

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

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

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

g) 14 C.F.R. §91.103: Preflight Action

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

i) 14 C.F.R. §91.119: Minimum Safe Altitudes

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

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

l) 14 C.F.R. §91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

m) 14 C.F.R. §§91.405(a); 407(a)(1); 409(a)(s); 417(a)(b): Maintenance Inspections

n) 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V-Washington, DC

Metropolitan Area Special Flight Rules, §93.333: Failure to Comply with this Subpart

o) 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V-Washington, DC

Metropolitan Area Special Flight Rules, §93.339 (a) through (e): Requirements for

Operating in the DC SFRA, including the DC FRZ

p) 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V-Washington, DC

Metropolitan Area Special Flight Rules, §93.341 (a);(c1) through (c5);(d): Aircraft

Operations in the DC FRZ

As shown in this petition and attached supporting documents, we request an exemption that would permit

the operations of both mUAS and sUAS under controlled conditions in the Class G airspace that is 1)
limited; 2) predetermined; 3) controlled as to access; 4) identified and monitored; and 5) we will provide

the necessary safety improvements and enhancements using industry practices for all operations.

Approving our petition would thereby enhance safety while fulfilling the Secretary of Transportation’s

responsibilities to “establish requirements for the safe operation of such aircraft systems in the national

airspace system” of Section 333(c) of the FAA Modernization and Reform Act of 2012.

If you have any questions, please feel free to contact me.

Sincerely,

William Jones

William Jones

General Counsel
TABLE OF CONTENTS

1 DESCRIPTION OF PETITIONER............................................................................................................................6

2 RELEVANT STATUTORY AUTHORITY TO PETITIONER’S EXEMPTION REQUEST ...................................................6

3 QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE FMRA..............................................................7

3.1 DJI PHANTOM 2 VISION PLUS, VERSION 3.0 MUAS ASSET.......................................................................................... 8

3.2 TALI CARBON H500 SUAS ASSET ......................................................................................................................... 10

4 DESCRIPTION OF PROPOSED OPERATIONS......................................................................................................11

4.1 STANDARD OPERATIONAL PROCEDURES FOR MUAS AND SUAS ASSETS........................................................................ 11

4.2 SPECIFIC OPERATIONAL PROCEDURES FOR AERIAL BUILDING PHOTOGRAPHY & INSPECTIONS ............................................ 13

4.3 SPECIFIC OPERATIONAL PROCEDURES FOR ILLEGAL AND LEGAL CONSTRUCTION INSPECTIONS ............................................ 14

4.4 SPECIFIC OPERATIONAL PROCEDURES FOR TEMPORARY TOWER CRANE ASSEMBLY VERIFICATION INSPECTIONS .................... 14

4.5 SPECIFIC OPERATIONAL PROCEDURES FOR SUBSTRUCTURE BRIDGE INSPECTIONS ............................................................ 16

4.6 SPECIFIC OPERATIONAL PROCEDURES FOR THE DC SPECIAL FLIGHT RULES AREA (DC SFRA), INCLUDING THE DC

METROPOLITAN AREA FLIGHT RESTRICTED ZONE (DC FRZ)..................................................................................................... 18

5 REGULATIONS FROM WHICH EXEMPTION RELIEF IS REQUESTED ....................................................................19

5.1 14 C.F.R. PART 21, SUBPART H- AIRWORTHINESS CERTIFICATES AND 14 C.F.R. § 91.203(A)(1).................................... 19

5.2 14 C.F.R. PART 27 AIRWORTHINESS STANDARDS: NORMAL CATEGORY ROTORCRAFT .................................................... 20

5.3 14 C.F.R. §§ 45.23(B), 45.27(A) AND 91.9(C): AIRCRAFT MARKING AND IDENTIFICATION REQUIREMENTS ..................... 20

5.4 14 C.F.R. § 61.113: PRIVATE PILOT PRIVILEGES AND LIMITATIONS ............................................................................ 20

5.5 14 C.F.R. §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS ............................................................................................. 21

5.6 14 C.F.R. §91.9(B)(2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT ................................................................. 22

5.7 14 C.F.R. §91.103: PREFLIGHT ACTION................................................................................................................ 22

5.8 14 C.F.R. §91.109(A): FLIGHT INSTRUCTION......................................................................................................... 22

5.9 14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES .................................................................................................... 23

5.10 14 C.F.R. §91.121: ALTIMETER SETTINGS............................................................................................................. 23

5.11 14 C.F.R. §91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS............................................................ 24

5.12 14 C.F.R. §91.203(A) AND (B): CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION....................................... 24

5.13 14 C.F.R. §§91.405(A); 407(A)(1); 409(A)(S); 417(A)(B): MAINTENANCE INSPECTIONS ............................................ 25

5.14 14 C.F.R. SUBCHAPTER F, PART 93-SPECIAL AIR TRAFFIC RULES, SUBPART V-WASHINGTON, DC METROPOLITAN AREA

SPECIAL FLIGHT RULES, §93.333: FAILURE TO COMPLY WITH THIS SUBPART .............................................................................. 25

5.15 14 C.F.R. SUBCHAPTER F, PART 93-SPECIAL AIR TRAFFIC RULES, SUBPART V-WASHINGTON, DC METROPOLITAN AREA

SPECIAL FLIGHT RULES, §93.339 (A) THROUGH (E): REQUIREMENTS FOR OPERATING IN THE DC SFRA, INCLUDING THE DC FRZ ........ 26

5.16 14 C.F.R. SUBCHAPTER F, PART 93-SPECIAL AIR TRAFFIC RULES, SUBPART V-WASHINGTON, DC METROPOLITAN AREA

SPECIAL FLIGHT RULES, §93.341 (A);(C1) THROUGH (C5);(D): AIRCRAFT OPERATIONS IN THE DC FRZ .......................................... 27

6 PUBLIC INTEREST.............................................................................................................................................28

6.1 THE NEED FOR AERIAL BUILDING PHOTOGRAPHY & INSPECTIONS ................................................................................ 29

6.2 THE NEED FOR SUBSTRUCTURE BRIDGE INSPECTIONS ................................................................................................ 30

6.3 THE NEED FOR CONSTRUCTION INSPECTIONS........................................................................................................... 32

6.4 THE NEED FOR TEMPORARY TOWER CRANE ASSEMBLY VERIFICATION INSPECTIONS ........................................................ 33

7 DRUG FREE WORKPLACE .................................................................................................................................36

8 PRIVACY POLICY ..............................................................................................................................................37

9 FEDERAL REGISTRY SUMMARY........................................................................................................................38

10 CONCLUSION...................................................................................................................................................38

11 REFERENCES ....................................................................................................................................................40

12 SUPPORTING DOCUMENTS .............................................................................................................................41
U.S. Department of Transportation- Docket Management System

May 23, 2015

12.1 AERIAL INSPECTION FLIGHT SIGN........................................................................................................................... 41

12.2 DJI PHANTOM 2 VISION PLUS USER MANUAL ......................................................................................................... 41

12.3 DJI PILOT TRAINING GUIDE .................................................................................................................................. 41

12.4 DJI PROP GUARD ASSEMBLY GUIDE....................................................................................................................... 41

12.5 DJI BATTERY SAFETY GUIDE ................................................................................................................................. 41

12.6 DJI FLYING FLOWCHART ...................................................................................................................................... 41

12.7 DJI ADVANCED MANUAL..................................................................................................................................... 41

12.8 TALI H500 GOPRO MANUAL ............................................................................................................................... 41

12.9 TALI H500 BLUETOOTH DATALINK MANUAL ........................................................................................................... 41

12.10 TALI H500, QUICK START GUIDE...................................................................................................................... 41

12.11 TALI H500 ILOOK SETTINGS............................................................................................................................. 41

12.12 ARS FLIGHT SAFETY AND PROCEDURES MANUAL ................................................................................................. 41
U.S. Department of Transportation- Docket Management System

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Page 6 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

1 Description of Petitioner

Alternatives Renewable Solutions, LLC, a Disadvantage Business Enterprise (DBE) and

Certified Business Enterprise (CBE) formed in 2009, is a Washington-DC based consulting

company solving problems through innovative applications and solutions. We are addressing

customers’ needs in construction, engineering, and architecture using industry best practices. We

are involved in the planning, coordination of various projects including government, residential,

and commercial projects.

The Petitioner has launched its drone mapping and inspection service. Our quadcopter and

hexacopter assets are suitable for various private, industrial, and commercial applications. We

seek to provide aerial image-thermography, inspections of sites using high resolution video and

photo cameras, surveys, and 3D image mapping from a point cloud. Aerial technology using

unmanned aircraft systems (UAS) has been shown to significantly increase productivity and

reduce the inherent safety risks to property and personnel. The Petitioner has adopted UAS

technology to increase safety, accuracy, value, construction management, rapid turnaround of

data, versatility, and its speed as opposed to traditional survey methods.

Additionally, the Petitioner is staffed with personnel who have UAS operational and

maintenance experience. This natural transition to the infrastructure and public safety inspection

market, along with our engineering inspection experience, reduces the overall risk to the public,

while conducting inspection operations. Therefore, the Petitioner seeks the requested exemptions

and a Certificate of Authorization to permit it to offer consulting services for the public and

private sectors to conduct UAS operations for a host of industries and applications. These

include:  Aerial building photography and inspections;  Aerial surveying and inspections;  Substructure bridge inspections;  Temporary tower crane assembly verification inspections;  Construction activities for compliance determination; and

 Aerial inspections in the DC Metropolitan Area

2 Relevant Statutory Authority to Petitioner’s Exemption Request

The Federal Aviation Administration (FAA)’s mission is to provide the safest airspace system

globally. Since the National Airspace System (NAS) isn’t static and will constantly be changing,

it must adapt to new technologies and applications, as evidence by the proliferation of unmanned

aircraft systems (UAS). Because UAS are inherently different from manned aircraft, introducing

UAS into the NAS will be challenging. Under Section 333 of the FAA Modernization and

Reform Act of 2012 (FMRA), the Secretary of Transportation has the authority to grant case-by- case authorization for certain unmanned aircraft to perform commercial operations prior to the
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Page 7 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

finalization of the small UAS Rule, which will be the primary method for authorizing small UAS

operations once it is complete (Section 333, 2015). The Section 333 Exemption process provides operators who wish to pursue safe and legal entry

into the NAS a competitive advantage in the UAS marketplace, thus discouraging operations

which are noncompliant with the implementing regulations and which improves safety.

Therefore, this Petition is being submitted in accordance with Sections 333 (a) to (c) of the

FMRA. In this Act, Congress directed the FAA “to safely accelerate the integration of civil

UASs in the national airspace system”, and under Section 333, the FAA Administrator is to

permit UASs to operate in the NAS where it is safe and does not create a hazard or pose a threat

to national security to do so based on the following:  The UAS size, weight, speed, and operational capability;  Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line-of-sight of the operator.1

In addition, the FAA Administrator has the general authority to grant exemptions from FAA

safety regulations and minimum standards when the Administrator decides a requested

exemption is in the public interest.2 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.3

The Petitioner will use multirotor UAS vehicles, weighing 6 or fewer lbs. including payload and

operate under normal conditions at a speed of no more than 8.23 meters/sec or 16 knots for aerial

public safety inspections. Each UAS will have the capability to hover, and move in the vertical

and horizontal plane simultaneously. In addition, the UASs will operate only in the pilot’s visual

line of sight at all times. As a result, the Petitioner will demonstrate how the proposed UAS

aerial public safety inspections will benefit the public and that the proposed operations will not

adversely affect safety of the public and to those operating in the National Airspace System.

3 Qualifications for Approval under Section 333 of the FMRA

The proposed operations in this petition for exemption, qualify for expedited approval under

Section 333 of the FMRA. Each of the statutory criteria and other potential relevant factors are

satisfied. The Petitioner’s planned operations would permit the use of small and relatively

inexpensive UAS under controlled conditions in the Class G airspace that is: (a) limited; (b)

predetermined; (c) controlled as to access; and (d) would pose an increased level of safety beyond

what exists when building inspectors, infrastructure inspectors, fixed or rotor wing aircraft are

used to accomplish the same purpose for inspection of buildings, bridge substructures,

compliance determinations at construction sites, and crane assembly verifications.

1 §333(b)(1) of FAA Modernization and Reform ACT 2012. 2 49 U.S.C. §44701(f) (authorizing the grant of exemptions from a requirement of regulations prescribed pursuant to Section

44701(a)-(b) and Sections 44702-44716). 3 14 C.F.R. §11.81, Petition for Exemptions.
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Page 8 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

The Petitioner’s sUASs will operate in visual line-of-sight (VLOS) and in specific safe zone

areas described in Section 5, Proposed Operations outlined in this Petition. Also, the Petitioner’s

fleet includes both a micro UAS (mUAS, weighing 2.75 lbs.) quadcopter and a small UAS

(sUAS) hexacopter, weighing less than 6 pounds, including payload. They will operate under

normal weather conditions, at speeds not to exceed 16 knots and have the capability to hover,

and move in both vertical and horizontal positions. The proposed operations will be conducted

with sUAS and or mUAS of a size and weight that will ensure a superior level of safety over

conducting the same operations with conventional fixed wing, manned aircraft, and reduce the

inherent safety risks to property and personnel. Given the size of the mUAS and sUAS involved and the restricted safety zones in which they

will operate, this Petition for exemption falls within the zone of safety, in which Congress4

intended for the FAA to permit commercial UAS operations by exemption, pending completion

of their formal ruling. Moreover, the authority granted to the FAA by Congress via Section 333

of the FMRA, provides the equivalent level of safety surrounding the proposed operations, and

the significant benefit to the public, which the grant of the requested exemption is warranted and

is in the public interest. Therefore, the Petitioner respectfully requests that the FAA grant the

requested exemption without delay, because such operations will insure that both the mUAS and

sUAS will not create a hazard to users of the NAS or the public.

3.1 DJI Phantom 2 Vision Plus, Version 3.0 mUAS Asset

The Petitioner will deploy the DJI Phantom 2 Vision + (NT0050029), version 3.0 for inspection

of vacant or occupied buildings, compliance activities at construction sites, substructure bridge

inspections, crane assembly verification inspection, and for general aerial surveys. The Petitioner

shall use images captured from the DJI Phantom 2 Vision Plus. These images will be taken

automatically and are geo-tagged by the Phantom 2 Vision Plus and then the rendering software

will convert images to maps and 3D models.

A copy of the DJI Phantom 2 Vision Plus User Manual, Pilot Training Guide, Prop Guard

Assembly Guide, Battery Safety Guide, and the ARS Flight Safety and Procedures Manual are

submitted as supporting documents with this Petition.

The DJI Phantom 2 Vision+ represents the company’s flagship consumer model, improving on

the Phantom 2 Vision by adding a Zenmuse H3-3D gimbal camera system. The Phantom 2

Vision is only outfitted with a jello-slaying rubber platform to ward off minimal gyration shake,

while the new Phantom 2 Vision+ corrects for vertical, horizontal, and angular shake. With this

new system, the onboard camera can be tilted up or down, greatly maximizing the range of the

lens. DJI also offers the Phantom 2, which comes without a camera or gimbal. The Vision+ can

transmit video and flight data to a smart phone thru Wi-Fi with almost no latency, the operator

can actually “Fly” the UAS base on the video screen with First Person View (FPV) experience,

Wi-Fi range is about 500-700m (Perlman, 2014). The Phantom 2 Vision Plus 3.0 or mUAS weighs 2.75 pounds including battery and camera.

Incorporated into the programming of the mUAS is an automatic return home feature that

4

Id at § 333(b)(1)
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Page 9 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

automatically directs the Phantom back to the point of take-off (Home location) should the unit

lose communications with the transmitter. Also, the mUAS has a crusing speed of 15 knots and

a maximum speed of 29 knots. Maximum flight time is 25 minutes and has a gross weight of

2.75 pounds.

As for the remote controller, it features a sliding power button, left and right joysticks, S2 and

S1 switches, and a chrome eyelet to mount a neck strap to. There is a movable antenna at the top

of the controller that can be angled upward, which is recommended by DJI for attaining the best

signal. The WiFi extender has two LED lights that indicate connection status, as well as the

power level health. In terms of actually piloting the drone, both the S2 and S1 switches need to

be flipped up and the WiFi extender needs to be powered on. The S1 switch places the drone in

calibration mode by flipping it back and forth several times, and the S2 switch will change the

drone’s Home location. The left joystick powers the drone up, down, and turns it left and right.

The right joystick moves the drone forward, backward, sideways to the left, and sideways to the

right (Perlman, 2014). In addition, the Phantom has an additional communication link between

the camera and the mUAS’s on a different radio frequency for a smart phone connection.

Allowing the operator or Pilot in Command (PIC) to monitor battery level, altitude (AGL),

distance from PIC, camera imagery, and control camera angle.

The PIC can use the mUAS’s internal software to set maximum altitude AGL for each flight,

allowing for customization of flights to no higher than 100 feet, 200 feet, 300 feet are some

examples. The 400 feet maximum AGL can be programmed into the UAVs software pre-flight

to insure compliance with FAA standards. Also, DJI has internal software that regulates the

height of the mUAS with No-Fly-Zones. These zones include airports worldwide and have been

divided into two types, A and B. Also, DJI has a flight limitation system that will prevent the

mUAS from flying in restricted airspace. For example, if the mUAS is within 1.5 miles of an

airport’s restricted zone, the vehicle will not fly.

Finally, the mUAS has an altitude and radar monitoring function that allows the PIC better

determination of height, direction of flight and distance from the PIC. Also, the PIC can monitor

GPS lock status while in flight with green lights on mUAS and has the ability to anticipate loss

of GPS locking so the PIC can land the UAS as a precaution.
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Page 10 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

3.2 Tali Carbon H500 sUAS Asset

Also, the Petitioner will deploy the Tali Carbon H500 Devo F12 E (N554QW) for inspecting

the substructure of bridges and for general aerial surveys. A copy of the Tali H500 DEVO Quick

Start Guide, Settings Guide, Bluetooth Datalink Manual, GoPro Manual, and the ARS Flight

Safety and Procedures Manual are submitted as supporting documents with the Petition.

The Tali H500 is considered by many to be the best drone in its class in the world. With its

cutting edge technology combined with reliability and ease of use, the Tali H500 delivers

excellent performance. It comes with the HD i-Look Plus camera and the mount accepts all

GoPro cameras. It has first person view meaning that whatever the camera sees will be

transmitted live to the controller. With a 25-minute flight time and the 10 waypoint GPS function,

the PIC can tackle substructure bridge inspections. The retractable landing gear and 3D gimbal

ensure that the camera shots are 100% unobstructed.

The Tali H500 weighs 4.45 pounds including battery and iLook camera. Incorporated into the

programming of the sUAS is a “One Key Go Home” feature that returns the sUAS to the home

location automatically. The Tali’s failsafe return to home mode, an advanced return-to-home

(RTH) protects the aircraft, in case of loss of control signal; whereby the H500 will automatically

attempt to return to its starting position for a safe landing. With its’ new Hyper I Intelligent

Orientation Control (IOC) function that includes new advanced IOC systems, the H500 can start

and fly in any orientation completely solving pilot loss of orientation problems. Also, the sUAS

has a crusing speed of 25 knots and a maximum speed of 47.7 knots. Maximum flight time is

25 minutes and has a gross weight of 4.6 pounds.

As for the Devo F12e transmitter, manufactured by Walkera, the unit has 4 slider controls for

controlling gains, gimbal, pitch, yaw and roll. Also, it has a built-in 5-in-1 video monitor,

capable of displaying both video and telemetry data from the Tali H500. The F12e controller

has 5.8 Ghz antenna and can display live data from the built-in screen. Data options include

temperature, battery power, GPS position, speed, altitude, and distance from starting point. One

great feature is the low power warning; the radio starts buzzing and vibrating when there is 2

minutes or less of flight time left on the H500 battery. The battery is a 6S 5400mah Li-Po 22.2V

battery with built-in charge status monitoring and promoting safe and convenient flight

operations.

Phantom

Vision +

Supported Battery 5200mAh LiPo Battery

Weight (battery & Propellers) 1242g or 2.75 pounds

Hover Accuracy Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular velocity 200 Degrees/second

Max Tiltable Angle 35 Degrees

Max. Ascent/Descent Speed Ascent: 6 m/s; Descent 2 m/s

Max. Flight Speed 15 m/s

Diagonal Motor-Motor Distance 350mm
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Page 11 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

4 Description of Proposed Operations

To assist the FAA in its safety assessment of the Petitioner’s proposed mUAS and sUAS

operations, standard and industry specific procedures have been created. Below is a summary

of operational limitations and conditions, which ensure an equivalent, or higher level of safety

to operations conducted under regulatory guidelines.

4.1 Standard Operational Procedures for mUAS and sUAS Assets

1. For all flight operations, no person shall act as an operator or visual camera observer for

more than one UAS operation at a time.

2. The Petitioner will operate both the Phantom 2 Vision Plus (mUAS) and the TALI H500

(sUAS).

3. All pilots of the mUAS and sUAS will conduct a preflight inspection prior to flight

mission.

4. Prior to any flight mission, the operator and visual camera observer will conduct a preflight

inspection, to include specific aircraft and control station systems checks to ensure both the

mUAS and sUAS are safe for operations.

Tali H500

Supported Battery 22V, 5200mAh LiPo Battery

Weight (battery & Propellers) 2020g or 4.45 pounds

Hover Accuracy Vertical: 0.8m; Horizontal: 2.5m

Main Rotor Diameter 233mm

Brushless ESC WST-15AH (R/G)

Max. Flight Speed 24.58 m/s

Stabilized 6 axis FLCS DEVO-H
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Page 12 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

5. The mUAS weigh less than 2.75 pounds, including payload.

6. The sUAS weigh less than 6 pounds, including payload.

7. Flights will be operated within visual line-of-sight (VLOS) of a pilot and visual camera

observer.

8. Maximum total flight time of each operational flight will be 25 minutes. Both the mUAS

and sUAS calculates battery reserve in real time, and will return to its ground station with

at least 20% battery power reserve should that occur prior to 25 minutes limit.

9. At all times, both the mUAS and sUAS will remain close enough to operator for the

operator to be capable of seeing the aircraft with vision unaided by any device other than

corrective lenses.

10. Both the mUAS and sUAS will not operate over any persons not directly involved in the

operation.

11. Flights for both the mUAS and sUAS will occur during daylight-only operations.

12. During flight operations, both the mUAS and sUAS will yield right-of-way to other

aircraft, manned or unmanned.

13. All flight operations will be in Class G Airspace.

14. mUAS flights will be operated at an altitude of no more than 400 feet above ground level

(AGL) or no more than 100 feet above a structure being inspected, if that structure exceeds

400 feet.

15. sUAS flights will be operated at an altitude of no more than 500 feet above ground level

(AGL) or no more than 100 feet above a structure being inspected, if that structure exceeds

500 feet.

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

structure or vehicle unless permission has been granted by the owner or controller of the

property in advance of the flight. Flights will not be conducted within 500 feet of any

person who is not essential for the conduct of the flight unless that person is in a position

where they are shielded from the aircraft and any possible debris resulting from an aircraft

failure. Flight will be terminated if a person/s breaches safety zone. 17. At a minimum, the crew for each operation will consist of the Pilot, Visual Camera

Observer, Engineer Inspector, and one or more State or local government inspector.

18. The mUAS pilot will be an FAA licensed airman with a private pilot’s certificate with

rotorcraft experience, along with 100 hours of training.

19. The sUAS pilot will be an FAA licensed airman with a private pilot’s certificate with

rotorcraft experience along with 100 hours of training.

20. All Pilots will be vetted by the Transportation Security Administration.

21. The mUAS Pilot will be trained in flight, operations, and safety procedures in accordance

with the ARS Flight Safety and Procedures Manual.

22. Both the mUAS and sUAS Pilots will be Pilot in Command (PIC). If a pilot certificate

holder other than the UAS Pilot, who possesses the necessary PIC qualifications, is also

present, that person can be designated as PIC.

23. The mUAS shall not operate in wind gusts greater than 10 mph.

24. The sUAS shall not operate in wind gusts greater than 18 mph.
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Page 13 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

25. Both the mUAS and sUAS will only operate within a confined “Sterile Area”. A sterile

area is defined as a safety zone surrounding the subject property that has been cleared of all

individuals or animals that aren’t part of the inspection. In addition, the Petitioner shall

establish a security perimeter for the flight operations area.

26. A briefing will be conducted in regard to the planned mUAS and sUAS operations prior to

each day’s missions. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

27. The Pilot, Visual Camera Observer, and Inspection Engineer will have been trained in

operations of UAS generally and will have experience in flying the particular UAS used for

any operations.

28. The Pilot, Visual Camera Observer, Inspection Engineer and State or local inspector will at

all times be able to communicate by voice or text via cellular or similar device.

29. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental

agencies.

30. The Petitioner will make available to the FAA, upon request, both the mUAS and/or sUAS

for inspection or testing, and any associated documents/records required to be kept under

the proposed rule.

31. Report an accident to the FAA within 10 days of any operation that results injury or

property damage.

32. If both the mUAS or sUAS loses communications or loses its GPS signal, both assets will

have the capability to return to a pre-determined location within the operational area and

land.

33. All flight operations will only operate in optimal weather conditions with visibility of at

least 3 miles from control station.

34. Both the mUAS and sUAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies. The Pilot will then safely terminate mission and gain control of

UAS and return to a pre-determine location.

35. The Petitioner will use a blanket 200-foot Certificate of Waiver or Authorization (COA) for

all flights anywhere in the country except in restricted airspace and other areas such as

major cities, where the FAA prohibits UAS operations. Moreover, the Petitioner will obtain

an Air Traffic Organization (ATO) issued COA for flights above 200 feet prior to

conducting any operation under this petition of exemption.

4.2 Specific Operational Procedures for Aerial Building Photography & Inspections

1. Ten days before flight operations, the operator will contact the State & local government

inspection agency that aerial inspection of vacant or occupied buildings will be occurring.

2. The operator will enforce a safety zone covering 500 feet outside the perimeter of the

subject building during flight operations. The safety zone will be established by the

operator by using yellow safety tape and the posting of aerial inspection signs (see

Supporting Documents). 3. mUAS flights will be operated at an altitude of no more than 200 feet above ground level

(AGL).
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4. Report an accident to the OSHA and the State & local government agency requesting the

inspection within 10 days of any operation that results injury or property damage.

4.3 Specific Operational Procedures for Illegal and Legal Construction Inspections

1. Ten days before flight operations, the operator will contact the State & local government

inspection agency that aerial inspection of the construction site will be occurring.

2. The operator will enforce a safety zone covering 500 feet outside the perimeter of the

construction site during flight operations. The safety zone will be controlled by the general

contractor with flaggers and other staff and the posting of aerial inspection flight signs (see

Supporting Documents).

3. sUAS flights will be operated at an altitude of no more than 300 feet above ground level

(AGL).

4. Report an accident to the OSHA and the State & local government agency requesting the

inspection within 10 days of any operation that results injury or property damage.

4.4 Specific Operational Procedures for Temporary Tower Crane Assembly Verification

Inspections

Cranes are carefully designed, tested, and manufactured for safe operation. When used properly

they can provide safe reliable service to lift or move loads. Because cranes have the ability to

lift heavy loads to great heights, they also have an increased potential for catastrophic accidents,

if safe operating practices are not followed (Culver, 1994). Due to significant advances, safety

professionals, and OSHA compliance officers need to keep abreast of modern crane technology

and changes in operating procedures to help them recognize problems before potentially unsafe

conditions lead to accidents that result in injuries and/or fatalities, as well as damage to

equipment.

Keeping these factors in mind, the need for a better understanding of crane operations and the

implementation of appropriate maintenance schedules is evident in preventing accidents. A

recent study by Don Dickie, a recognized crane authority with the Construction Safety

Association of Ontario, indicated that although mechanical failures represents only 11 percent

of the causes of crane accidents, they usually result in major accidents. Studies and analyses of

crane accidents involving mechanical failure show they are frequently due to a lack of

preventive maintenance or adequate training and/or experience on the part of the personnel

involved. Finally, cranes and associated rigging equipment must be inspected regularly to

identify and existing or potentially unsafe conditions. This preventive maintenance must be

performed as required by the crane manufacturer and/or the supplier to ensure safe crane

operation. Below is a detailed summary of operational limitations and conditions, which ensure

an equivalent or higher level of safety to operations conducted under regulatory guidelines for

proposed tower crane assembly verification inspections (see Figure 1).
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Figure 1: Temporary Tower Crane Inspection Map

1. The operator will file a FAA form 7711-1, or its equivalent with the local Flight Standards

District Office (FSDO). 2. At least five days before schedule inspections, the operator of both the mUAS and sUAS

affected by this exemption must submit a written Scope of Work Activities to the local

FSDO with jurisdiction over the area of proposed infrastructure inspection. The 5-day

notification may be waived with the concurrence of the FSDO. The Scope of Work

includes the following, but not limited to:

a. Dates and times of flights.

b. Name and phone number of the operator for the UAS inspections conducted under

this petition of exemption.

c. Name, phone number, and certificate number of the PIC.

d. Make, model, and N-number of UAS asset used in operation.

e. A statement that the operator has obtained permission from property owners and/or

local officials to conduct the infrastructure inspection event; the list of those who

gave permission must be made available to the inspector upon request.

f. A description of the flight mission, including maps or diagrams of any area, city,

town, county, and/or state over which infrastructure inspection will be conducted

and the altitudes essential to accomplish the operation.
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3. Ten days before flight operations, the operator will contact the State & local government

inspection agency that aerial inspection of the tower crane will be occurring on a

construction site.

5. The operator will enforce a safety zone covering 500 feet outside the perimeter of the

construction site during flight operations. The safety zone will be controlled by the general

contractor with flaggers and the operator will impose a non-fly zone and post aerial

inspection in progress signs (see Supporting Documents).

4. Both mUAS and sUAS flights will be operated at an altitude of no more than 400 feet

above ground level (AGL).

5. Prior to inspection, the general contractor will be required to move the hook (#2) and

jib/trolley (#3) in a lock position that provides the best and safe flight path without any

obstruction of buildings, people or roadways.

6. The flight operations will be restricted to a spherical flight path surrounding the tower

crane starting with the concrete footing (#11), continuing up the mast (#10 -#7), then

moving then horizontally to the counter-jib ballast (#1), the counter-jib block (#4), the

hoisting drum (#5), continuing past the cabin (#6) and jib-trolley (#3) and finally to the

hook (#2). Then the operator will repeat the flight path backwards in the following order:

#2, #3, #6, #5, #4, #1, #7-#10, #11, and then land the UAS (see Figure 1). 7. Report an accident to the OSHA and the State & local government agency requesting the

inspection within 10 days of any operation that results injury or property damage.

4.5 Specific Operational Procedures for Substructure Bridge Inspections

The operator will conduct a systematic method to inspect the substructure of the bridge. The

proposed operations includes inspection of bridge substructures over waterways. The

substructure supports the superstructure and transmits loads from the superstructure to the

ground. The substructure generally consists of pier caps, columns and piles. The substructure

may be constructed of timber, concrete or steel. Timber members are inspected for wood rot,

crushing, splitting and cracking. Concrete members are inspected for cracking, spalling, and

hollow areas. Steel members are inspected for paint peeling, corrosion and cracking. In addition,

the substructure is inspected for evidence of settlement or scour. Settlement is elements of the

substructure moving downward due to soil conditions. Scour is the undermining of a structure

due to water flow removing soil, which supports the structure (see Figure 2). Below is a detailed

summary of operational limitations and conditions, which ensure an equivalent or higher level

of safety to operations conducted under regulatory guidelines.
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Figure 2: Bridge Inspection Map

1. The operator will file a FAA form 7711-1, or its equivalent with the local Flight Standards

District Office.

2. Ten days before flight operations, the operator will contact the United States Coast Guard

to notify all boaters, military and commercial ship operators that UAS operations are being

conducted and to request a Coast Guard Patrol or State/Local Environmental Fishery Unit

with boat(s) in the water to monitor the safety zone. 3. The operator will conduct only bridge over waterway substructure inspections. 4. A no-fly zone will be established over bridge.

5. UAS flights will be operated underneath the bridge.

6. The operator will conduct a minimum of two missions, all over water, to inspect the bridge

substructures using both the mUAS and sUAS assets.

7. Report an accident to the United States Coast Guard within 10 days of any operation that

results injury or property damage.

8. At least five days before scheduled inspections, the operator of both the mUAS and sUAS

affected by this exemption must submit a written Scope of Work Activities to the local

FSDO with jurisdiction over the area of proposed infrastructure inspection. The 5-day

notification may be waived with the concurrence of the FSDO. The Scope of Work

includes the following, but not limited to:

a. Dates and times of flights.
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b. Name and phone number of the operator for the UAS inspections conducted under

this petition of exemption.

c. Name, phone number, and certificate number of the PIC.

d. Make, model, and N-number of UAS asset used in operation.

e. A statement that the operator has obtained permission from property owners and/or

local officials to conduct the infrastructure inspection event; the list of those who

gave permission must be made available to the inspector upon request.

f. A description of the flight mission, including maps or diagrams of any area, city,

town, county, and/or state over which infrastructure inspection will be conducted

and the altitudes essential to accomplish the operation.

4.6 Specific Operational Procedures for the DC Special Flight Rules Area (DC SFRA),

including the DC Metropolitan Area Flight Restricted Zone (DC FRZ)

1. Airspace surrounding the Whitehouse, the U.S. Treasury Building, the Mall, and the U.S.

Capitol building and grounds are prohibited from flight operations.

2. The operator will notify the U.S. Capitol Police of all flight operations.

3. The operator shall review all Notice-To-Airmen (NOTAMs) and file a DC SFRA Flight

Plan with the Washington Flight Standards Office.

4. The PIC shall communicate with the Washington Flight Standards Office by cell phone

stating the current flight operation, location, altitude, and operational timeframe when

conducting operations within the DC SFRA, including the DC FRZ.

5. The PIC shall provide battery level, altitude, and distance from PIC and location for all

flight operations to the Washington Flight Standards Office.

6. All flight operations in the District of Columbia will be 350 feet or below.

7. During flight operations, both the mUAS and sUAS will yield right-of-way to all military, manned or unmanned aircraft. 8. At least five days before schedule inspections, the operator of both the mUAS and sUAS

affected by this exemption must submit a written Scope of Work Activities to the

Washington FSDO with jurisdiction over the area of proposed infrastructure inspection.

The 5-day notification may be waived with the concurrence of the FSDO. The Scope of

Work includes the following, but not limited to:

a. Dates and times of flights. b. Name and phone number of the operator for the UAS inspections conducted under

this petition of exemption. c. Name, phone number, and certificate number of the PIC. d. Make, model, and N-number of UAS asset used in operation. e. A statement that the operator has obtained permission from property owners and/or

local officials to conduct the infrastructure inspection event; the list of those who

gave permission must be made available to the inspector upon request. f. A description of the flight mission, including maps or diagrams of any area, city,

town, county, and/or state over which infrastructure inspection will be conducted

and the altitudes essential to accomplish the operation.
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5 Regulations from Which Exemption Relief is Requested

The Petitioner requests an exemption from several interrelated provisions of 14 C.F.R. Parts 21,

27, 45, 61, 91, and 93 for purposes of conducting the requested operations using both a mUAS

and sUAS. Listed below are: (1) the specific sections of 14 C.F.R. for which an exemption is

sought: and (2) the operating procedures and safeguards that the Petitioner has established, which

will ensure a level of safety equal to or better than the rules from which exemption is sought.5

5.1 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

The Petitioner seeks an exemption from this provision, which establishes the procedural

requirements for the issuance of airworthiness certificates as required by §91.203(a)(1). Under

both the Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the FMRA, both

authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the particular UAS. Moreover, given the size and limited operating area

associated with both the mUAS (4.4 pounds, including payload) and sUAS (6 pounds, including

payload) to be utilized by the Petitioner, an exemption from Part 2, Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the FMRA. Finally, in all cases, an analysis of these criteria demonstrates that both the mUAS and sUAS

operated without an airworthiness certificate, in the restricted environment and under the

conditions proposed, will be at least as safe as, or safer than, a conventional craft operating with

an airworthiness certificate without the restrictions and conditions of the proposed UAS

operations.

The mUAS, weighing 2.75 pounds and the sUAS weighing less than 6 pounds including payload,

carry neither a pilot nor passenger and carry no explosive materials or flammable liquid fuels,

and operate exclusively within a secured and sterile area. Unlike other civil aircraft, the proposed

operations will be controlled and monitored by the pilot, visual camera observer, and inspection

engineer, pursuant to procedures in Section 4. Moreover, the FAA will have advance notice of

all operations conducted under this exemption.

These safety enhancements, which already apply to civil aircraft operated in connection with

existing inspection operations, provide a greater degree of safety to the Petitioner’s staff and

contractors, the public, and property owners than conventional operations conducted with

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Moreover, application of

these same criteria demonstrates that there is no credible threat to national security posed by both

the mUAS and sUAS, due to its size, speed of operation, lack of explosive materials or

flammable liquid fuels, and inability to carry a substantial external load.

5 See 14 C.F.R. § 11.81(c) which requires a petition for exemption to include: “the reasons why granting the exemption would not

adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which

you seek exemption.”
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5.2 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

The procedural requirements for airworthiness certification of normal category rotorcraft is set

forth in 14 C.F.R. Part 27. To the extent that both the Petitioner’s mUAS and sUAS would

otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27’s

airworthiness standards for the same reasons identified in the exemption request from 14 C.F.R.

Part 21, Subpart H.

5.3 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification

Requirements

This Petitioner seeks an exemption from the aircraft marking and identification requirements of

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

Section 45.23(b), Markings of the Aircraft, states that 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 the aircraft near each entrance to the cabin, cockpit, or pilot station, letters

not less than 2 inches nor more than 6 inches high, the worlds “limited,” “restricted,” “light- sport,” “experimental,” or “provisional,” as applicable.

Section 45.27(a), Rotorcraft, states 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.

Section 91.9(c), Civil Aircraft Flight Manual, Marking, and Placard Requirements, states

that no person may operate a U.S. registered civil aircraft unless the aircraft is identified in

accordance with Part 45 of this Chapter.

The request of an exemption from §45.23(b) is warranted because both the mUAS and sUAS

have no entrance to the cabin, cockpit, or pilot station on which the registration number can be

placed. Moreover, given the size of the UASs, two-inch lettering would be impossible. However,

the aircraft registration, or “N Number” will be placed on the fuselage in compliance with

§45.29(f). Moreover, given the nature of the specific relief sought by this exemption request,

the Petitioner requires relief from the associated marking and identification requirements of

§45.27(a) and §91.9(c), which would require compliance with §45.23(b).

The level of safety for exemptions to the aircraft marking and identification requirements of 14

C.F.R. §§45.23(b), 45.27(a), and 91.9(c) will be provided by having both mUAS and sUAS

marked on its fuselage as required by §45.29(f) where the Pilot, Visual Camera Observer, and

Inspection Engineer and others working with the UASs will see the “N Number” identification

on the aircraft. Additionally, the Petitioner will ensure compliance with any requests of UASs’

marking by the FAA. The FAA has issued the following exemptions to the aircraft marking

requirements of §45.23(b): Exemption Nos. 0692, 0816, 8738, 10700, 10167 and 10167A.

5.4 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

The Petitioner seeks an exemption from the private pilot privileges and limitations of 14 C.F.R.

§61.113 (a) and (b), which states that:
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(a) Except as provided in paragraphs (b) through (h) of this section, no person who

holds a private pilot certificate may act as pilot in command of an aircraft that is

carrying passengers or property for compensation or hire; nor may that person, for

compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft

in connection with any business or employment if: (1) the flight is only incidental to

that business or employment; and (2) the aircraft does not carry passengers or property

for compensation or hire.

The purpose of Part 61 is to ensure that the skill and competency of any pilot matches the airspace

in which he or she will be operating, as well as requiring certifications if the private pilot is

carrying passengers or cargo for hire. In this case, while both the mUAS and sUAS will be

operated as part of a commercial operation, they carry neither passengers nor cargo. Accordingly,

the Petitioner seeks an exemption from 14 C.F.R. §61.113 (a) and (b), commercial limitation

requirement that the flight be incidental to the business to benefit from the exception. As set forth in the ARS Flight Safety and Procedures Manual, to ensure an equivalent level of

safety, any person acting as a pilot in command, must be knowledgeable in the airspace and

communication issues pertaining to all aircraft operations, but also in the unique aspects of both

mUAS and sUAS flights. Unlike a conventional aircraft that carries the pilot and passengers,

both mUAS and sUAS, are remotely controlled with no living thing or cargo on board.

The area of operation is controlled and restricted, and all flights are planned and coordinated in

advance as set forth in Section 4 of this Petition. Furthermore, while helpful, a pilot license will

not ensure remote control piloting skills, though the Petitioner’s pilot vetting and training

program will ensure the PIC has substantial experience on either the mUAS and/or the sUAS.

Moreover, private pilot certificate holders will operate either the mUAS or sUAS with the same

skill level. The risk to the operations of both the mUAS and sUAS are far less than the risks

levels inherent in the commercial activities within Part 61. As a result, allowing the Petitioner to

operate its UASs with a private pilot certificates as the PIC will exceed current safety levels in

relations to 14 C.F.R. §61.113 (a) and (b). The Petitioner believes that this system will provide

a high-level of competency and proficiency for its pilots that ensures a level of safety equal to or

greater than the rules from which this exemption is requested.

5.5 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

The Petitioner seeks an exemption from 14 C.F.R. §91.7(a), which requires that a civil aircraft

be in airworthy condition to be operated. As there will be no airworthiness certificate issued for

the both the mUAS and sUAS, should this exemption be granted, no FAA regulatory standard

will exist for determining airworthiness.

The level of safety is maintained and operated in accordance with all specifications and

requirements identified by the manufacturer. The Petitioner will only operate UASs that have a

proven track record of reliability and safety. In addition, given that both mUAS and sUAS will

be operated by the Petitioner under 6 pounds, and no UAS will be flown unless it has been
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maintained and prepared for flight in accordance with the manufacturer’s requirements, and

equivalent level of safety will be provided.

5.6 14 C.F.R. §91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

The Petitioner seeks an exemption from 14 C.F.R. §91.9(b)(2), which requires that:

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

(2) For which an Airplane or Rotorcraft Flight Manual is not 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.

The UASs, given their size and configuration has no ability or place to carry such a flight manual

on the aircraft, not only because there is no pilot on board, but also because there is no room or

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground

station or ground control point where the Pilot flying either UAS will have immediate access to

it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737,

8738, 9299, 9565, 10167, 10602, 32827, and 10700.

5.7 14 C.F.R. §91.103: Preflight Action

The Petitioner 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. In as such, as the FAA approved flight

manual will not be provided for both the mUAS and sUAS, an exemption is requested.

An equivalent level of safety will be provided by following the ARS Safety & Procedures

Manual and flight manual provided by the manufacturer. The PIC will take all required preflight

actions-including reviewing weather, flight battery requirements, landing and takeoff distance,

and aircraft performance data, prior to flight. Both the Manufacturer Flight Manual and ARS

Flight Safety & Procedures Manual will be located at the ground station with the pilot at all

times.

5.8 14 C.F.R. §91.109(a): Flight Instruction

The Petitioner seeks an exemption from 14 C.F.R. §91.109(a), which provides that:

“No person may operate a civil aircraft (except a manned free balloon) that is being

used from flight instruction unless that aircraft has fully functioning dual controls.”

Both the mUAS and sUAS piloted aircraft, by their design, do not have functional dual

controls. Instead, flight control is accomplished through the use of a box that

communicates with the aircraft via radio communications.

As a result of the size and speed of both the mUAS and sUAS, an equivalent level of safe training

can still be performed without dual controls because no pilot or passengers are aboard the UASs,
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and all persons will be a safe distance away in the event that the UASs experiences an difficulties

during flight instruction. The FAA has approved exemptions from flight training without fully

functional dual controls for a number of aircraft and for flight instruction for exemptions

numbers 5778K and 9862A.

5.9 14 C.F.R. §91.119: Minimum Safe Altitudes

The Petitioner requests an exemption from the minimum safe altitude requirements of 14

C.F.R. §91.119, which prescribes that:

The minimum safe altitudes under which aircraft may not operate, including 500 feet

above the surface and away from any person, vessel, vehicle, or structure in non- congested areas6

. Section 91.119(d) allows for a:

Helicopter to operate at less than those minimum altitudes when it can be operated

“without hazard to persons or property on the surface,” provided that “each person

operating the helicopter complies with any routes or altitudes specifically prescribed

for helicopters by the FAA.”

As previously stated in Section 5.1, the mUAS flights will be operated at an altitude of no more

than 400 feet above ground level (AGL) or no more than 100 feet above a structure being

inspected, if that structure exceeds 400 feet. Also, the sUAS flights will be operated at an altitude

of no more than 500 feet above ground level (AGL) or no more than 100 feet above a structure

being inspected, if that structure exceeds 500 feet. Flights will operated at a lateral distance of

at least 500 feet from any structure or structure or vehicle unless permission has been granted by

the owner or controller of the property in advance of the flight. Flights will not be conducted

within 500 feet of any person who is not essential for the conduct of the flight unless that person

is in a position where they are shielded from the aircraft and any possible debris resulting from

an aircraft failure. Flight will be terminated if a person breaches the safety zone.

Moreover, as compared to flight operations with aircraft or rotorcraft, weighing far more than 6

pounds proposed herein and carrying flammable fuel, any risk associated with our operations is

far less than those presently presented with helicopters and other conventional aircraft operating

at or below 500 feet AGL. An equivalent level of safety will be achieved given the size, weight,

and speed of both the mUAS and sUAS, as well as the location where it is operated. Furthermore,

by operating at such lower altitudes; both the mUAS and sUAS will not interfere with other

aircraft that are subject to the minimum safe altitude regulations.

5.10 14 C.F.R. §91.121: Altimeter Settings

The Petitioner seeks an exemption from 14 C.F.R. §91.121, which requires that:

A person operating an aircraft to maintain crusing altitude or flight level by reference to an

altimeter that is set to the elevation of the departure airport or barometric pressure. An

6 See 14 C.F.R. §91.119(c)
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exemption is required to the extent that both the mUAS and sUAS do not have a barometric

altimeter, but rather a GPS altitude read out.

An equivalent level of safety will be achieved by following the procedures set forth in the ARS

Flight Safety & Procedure Manual. Moreover, as stated in the manual, the operator will confirm

the altitude of the launch site shown on the GPS altitude indicator before flight. Finally, the PIC

will use the GPS altitude indicator to constantly monitor either the mUAS or the sUAS height,

thus ensuring operation at safe altitudes.

5.11 14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions

The Petitioner seeks an exemption from 14 C.F.R. §91.151(a), which requires that:

(a) 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 crusing speed.

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

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

The battery powering both the mUAS and sUAS provides approximately 25 minutes of powered

flight. An exemption from the 30 minute reserve requirement in 14 C.F.R. §91.151 is therefore

required.

An equivalent level of safety can be achieved by limiting flights to 18 minutes, or enough battery

reserve to ensure that the both the mUAS and sUAS land at the ground station with at least 25%

of battery power (as determined by the onboard monitoring system and pilot), whichever happens

first. This restriction would be more than adequate to return both the mUAS and sUAS to its

planned landing zone from anywhere within its limited operating area.

5.12 14 C.F.R. §91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

The Petitioner seeks an exemption from 14 C.F.R. §91.203 (a) and (b) which requires that:

(b) Except as provided in §91.715, no person may operate a civil aircraft unless it

has within it the following: (1) An appropriate and current airworthiness certificate.

(c) 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.

The Petitioner’s UASs, fully loaded weigh no more than 6 pounds and are operated without an

onboard pilot. Therefore, there is no ability or place to carry certification and registration

documents or to display them on both the mUAS and sUAS.

The equivalent level of safety will be achieved and sustained by keeping these documents at the

ground station or flight control point where the pilot flying the UAS will have immediate access
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Page 25 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

to them at the ground station or control point. The FAA has issued the following exemptions to

this regulation: Exemption Nos. 9565, 9665, 9789A, 9797, 9797A, 9816A, and 10700.

5.13 14 C.F.R. §§91.405(a); 407(a)(1); 409(a)(s); 417(a)(b): Maintenance Inspections

The Petitioner seeks an exemption from the maintenance inspection requirements of 14 C.F.R.

§§91.405(a); 407(a)(1); 409(a)(s); 417(a) and (b). These regulations specify that the:

Maintenance and inspection standards in reference to 14 C.F.R. Part 43. As a result,

an exemption to these regulations is needed because Part 43 and the stated sections

apply only to aircraft with an airworthiness certificate, which both the mUAS and sUAS

will not have.

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the UAS Manufacturer Manuals, shown in the Supporting

Documents Section. Also, the Pilot will ensure that the mUAS or sUAS are in working order

prior to initiating flight, perform the required maintenance, and keep a log of any maintenance

performed. The Pilot is the person most familiar with the aircraft and best suited to maintain the

aircraft in an airworthy condition to provide the equivalent level of safety.

Also, given that both the mUAS and sUAS are very limited in size and will carry a small payload

and operate only in restricted or sterile areas for limited periods of time during daylight hours,

creates less risk than that associated with conventional rotorcraft performing the same operation. 5.14 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V-Washington,

DC Metropolitan Area Special Flight Rules, §93.333: Failure to Comply with this

Subpart

The Petitioner seeks an exemption from knowingly violating 14 C.F.R. §93.333(b). This

regulation states that:

The DC FRZ and DC SFRA were established for reasons of national security under the

provisions of 49 U.S.C. 40103(b)(3). Areas established by the FAA under that authority

constitute “national defense airspace” as that term is used in 49 U.S.C. 46307. In

addition to being subject to the provisions of paragraph (a) of this section, persons who

knowingly or willfully violate national defense airspace established pursuant to 49

U.S.C. 40103(b)(3) may be subject to criminal prosecution.

The Petitioner’s PIC will operate its UASs with a private pilot certificate only in the Class G

airspace. The Petitioner believes that operating in the Class G airspace and providing the

Washington Flight Standards District Office with an equivalent level of means to identify, track

(locate), and communicate with the operator during flight operations provides the necessary

approval to knowingly operating in the DC FRZ and DC SFRA. Moreover, given the nature of

the specific relief sought by this exemption request, the Petitioner requires relief from 14 C.F.R.

§93.333(b).
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5.15 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V-Washington,

DC Metropolitan Area Special Flight Rules, §93.339 (a) through (e): Requirements

for Operating in the DC SFRA, including the DC FRZ

The Petitioner seeks an exemption from 14 C.F.R. §93.339 (a) through (e) which states that:

(a) Except as provided in paragraphs (b) and (c) of this section and in §93.345, or

unless authorized by Air Traffic Control, no pilot may operate an aircraft,

including an ultralight vehicle or any civil aircraft or public aircraft, in the DC

SFRA, including the DC FRZ, unless—

1) The aircraft is equipped with an operable two-way radio capable of

communicating with Air Traffic Control on appropriate radio frequencies;

2) Before operating an aircraft in the DC SFRA, including the DC FRZ, the

pilot establishes two-way radio communications with the appropriate Air

Traffic Control facility and maintains such communications while

operating the aircraft in the DC SFRA, including the DC FRZ;

3) The aircraft is equipped with an operating automatic altitude reporting

transponder;

4) Before operating an aircraft in the DC SFRA, including the DC FRZ, the

pilot obtains and transmits a discrete transponder code from Air Traffic

Control, and the aircraft’s transponder continues to transmit the assigned

code while operating within the DC SFRA;

5) For VFR operations, the pilot must file and activate a DC FRZ or DC

SFRA flight plan by obtaining a discrete transponder code. The flight

plan is closed upon landing at an airport within the DC SFRA or when the

aircraft exits the DC SFRA;

(b) Paragraph (a)(5) of this section does not apply to operators of Department of

Defense aircraft, law enforcement operations, or lifeguard or air ambulance

operations under an FAA/TSA airspace authorization, if the flight crew is in

contract with Air Traffic Control and is transmitting an Air Traffic Control- assigned discrete transponder code.

(c) When operating an aircraft in the VFR traffic pattern at an airport within the DC

SFRA (but not within the DC FRZ) that does not have an airport traffic control

tower, a pilot must—

1) File a DC SFRA flight plan for traffic pattern work;

2) Communicate traffic pattern position via the published Common Traffic

Advisory Frequency (CRAF);

3) Monitor VHF frequency 121.5 or UFH frequency 243.0, if the aircraft is

suitably equipped;

4) Obtain and transmit the Air Traffic Control-assigned discrete transponder

code; and

5) When exiting the VFR traffic pattern, comply with paragraphs (a)(1)

through (a)(7) of this section.

(d) When operating an aircraft in the VFR traffic pattern at an airport within the DC

SFRA (but not within the DC FRZ) that has an operating airport traffic control

tower, a pilot must:
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1) Before departure or before entering the traffic pattern, request to remain

in the traffic pattern;

2) Remain in two-way radio communications with the tower. If the aircraft is

suitably equipped, the pilot must also monitor VHF frequency 121.5 or

UHF frequency 243.0;

3) Continuously operate the aircraft transponder on code 1234 unless Air

Traffic Control assigns a different code; and

4) Before exiting the traffic pattern, comply with paragraphs (a)(1) through

(a)(7) of this section

(e) Pilots must transit the assigned transponder code. No pilot may use transponder

code 1200 while in the DC SFRA.

As a result of the size of both the mUAS and sUAS, neither asset has the ability to carry two- way communications and a transponder on-board to track and communicate with the ATC.

However, the Petitioner shall engage and maintain communications with the Washington Flight

Standards Office by cell phone stating its current flight operation, location, altitude, and

operational timeframe when conducting operations within the DC SFRA, including the DC FRZ.

The PIC shall obtain readings from the communication link between the controller and UAS to

include battery level, altitude, distance from PIC, and location for all flight operations. As part of preflight plans, the operator shall review all NOTAMs and file a DC SFRA Flight

Plan with the Washington Flight Standards Office. The operator shall state that “we would like

to file a DC SFRA flight plan for a VFR flight at subject property located at ___________________________________________ being inspected.” Next, the operator shall

remain only in Class G airspace and request approval to conduct flight operations. During flight

operations, the operator shall maintain communications with the Washington Flight Standards

Office stating current flight operations, location, and altitude. Once flight operations ends, the

operator shall notify the Washington Flight Standards Offices by cell phone that flight operations

are closed. Given these operational procedures, an equivalent level of means to identify, track

(locate), and communicate with the operator during flight operations provides the necessary

rationale to operate in the DC FRZ and DC SFRA.

5.16 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V-Washington,

DC Metropolitan Area Special Flight Rules, §93.341 (a);(c1) through (c5);(d): Aircraft

Operations in the DC FRZ

The Petitioner seeks an exemption from 14 C.F.R. §93.341 (a); (c1) through (c5) and (d) which

states that:

(a) Except as provided in paragraph (b) of this section, no pilot may conduct any flight

operation under part 91, 101, 103, 105, 125, 133, 135, or 137 of this chapter in the

DC FRZ, unless the specific flight is operating under an FAA/TSA authorization.

(b) (b) Department of Defense (DOD) operations, law enforcement operations, and

lifeguard or air ambulance operations under an FAA/TSA airspace authorization

are exempted from the prohibition in paragraph (a) of this section if the pilot is in

contact with Air Traffic Control and operates the aircraft transponder on an Air

Traffic Control-assigned beacon code.
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(c) The following aircraft operations are permitted in the DC FRZ:

1) Aircraft operations under the DCA Access Standard Security Program

(DASSP) (49 CFR part 1562) with a Transportation Security

Administration (TSA) flight authorization.

2) Law enforcement and other U.S. Federal aircraft operations with prior FAA

approval.

3) Foreign-operated military and state aircraft operations with a State

Department-authorized diplomatic clearance, with State Department

notification to the FAA and TSA.

4) Federal, State, Federal DOD contract, local government agency aircraft

operations and part 121, 129 or 135 air carrier flights with TSA-approved

full aircraft operator standard security programs/procedures, if operating

with DOD permission and notification to the FAA and the National Capital

Regional Coordination Center (NCRCC). These flights may land and depart

Andrews Air Force Base, MD, with prior permission, if required.

5) Aircraft operations maintaining radio contact with Air Traffic Control and

continuously transmitting an Air Traffic Control-assigned discrete

transponder code. The pilot must monitor VHF frequency 121.5 or UHF

frequency 243.0.

(d) Before departing from an airport within the DC FRZ, or before entering the DC

FRZ, all aircraft, except DOD, law enforcement, and lifeguard or air ambulance

aircraft operating under an FAA/TSA airspace authorization must file and activate

an IFR or a DC FRZ or a DC SFRA flight plan and transmit a discrete transponder

code assigned by an Air Traffic Control facility. Aircraft must transmit the discrete

transponder code at all times while in the DC FRZ or DC SFRA.

Given that an equivalent level of means to identify, track (locate), and communicate with the

operator during flight operations provides the necessary rationale to operate in the DC FRZ and

DC SFRA, the Petitioner requests authorization from the FAA/TSA to conduct flight operations

in the Class G airspace. All PICs and visual camera operators shall have background checks

conducted by the TSA. Additionally, the Petitioner shall engage and maintain contact with the

Washington Flight Standards Office by cell phone, without the need for the pilot to monitor VHF

frequency 121.5 or UHF frequency 243.0. Also, there will not be a need to transmit a discrete

transponder code assigned by the ATC, since the UAS doesn’t have an onboard transponder and

that the operator will be notifying the Washington Flight Standards Offices by cell phone of the

start and end of flight operations in the DC FRZ and DC SFRA. The Petitioner believes that this

system will provide a high-level of notification, tracking and communicating with the FAA, which ensures a level of safety equal to or greater than the rules from which this exemption is

requested.

6 Public Interest

Across the United States, State & local municipalities are responsible for protecting the health,

safety, economic interests and the quality of life of local residents, businesses and visitors to

their specific jurisdictions. These municipalities’ charge an agency to regulate construction

activities for compliance determination and inspections of vacant or occupied buildings, crane
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assembly and bridges. However, as a result of budget cuts, many jurisdictions had to reduce

resources and the number of government employees to monitor, assess, and inspect these

activities. These agencies are faced with a public health and safety crisis that requires the use of

aerial technology using UASs. The Petitioner’s UASs will significantly increase productivity

and reduce the inherent safety risks to property and personnel. The UASs will capture critical

images that can then be uploaded to cloud software for rendering and can be processed into

orthomosaic and 3D images that will serve as evidence to fine and prosecute individuals breaking

local rules.

In order for the FAA to consider a petition for exemption, the petition must meet the requirements

of 14 CFR §11.81(d), which requires the Petitioner to state the reasons why granting a request

would be in the public interest and how it would benefit the public as a whole. Granting the

approval of exemption of UAS commercial operations for conducting aerial public safety

inspections and photography of vacant/and or occupied buildings, temporary tower crane

assembly verification inspection, determine compliance with respect to construction activities, and substructure bridge inspections will benefit the public as a whole in many aspects.

6.1 The Need for Aerial Building Photography & Inspections

In general, a vacant property becomes a problem when the property owner abandons the basic

responsibilities of ownership, such as routine maintenance or mortgage and property tax

payments. Multiple variables can lead authorities to designate a property as either vacant or

abandoned, including the physical condition of a structure, the amount of time that a property

has been in that particular condition, and the relationship of the owner to the property. For

example, in Baltimore, the city building code defines residences as vacant only if they are

uninhabitable, not if they are merely unoccupied. Also, in the District of Columbia, the Vacant

Building Enforcement Unit reaches out to owners of vacant buildings, and maintains a list of all

vacant and blighted buildings. This list is used by the District of Columbia’s Office of Tax and

Revenue in reclassifying vacant buildings to the higher property tax rate, as mandated by DC

Official Code. The absence of universal definitions of vacancy and abandonment complicates efforts to assess

the number of vacant and abandoned properties nationally. The best aggregate sources include

the U.S. Census Bureau and the U.S. Postal Service, although these are not without limitations.

Using these sources, the U.S. Government Accountability Office (GAO) reported in 2011 that

vacant residential units, not including those used seasonally or by migrant workers, increased

from 7 million in 2000 to 10 million in 2010. The Joint Center for Housing Studies of Harvard

University reported that a subset of this category, homes vacant and not being marketed for sale

or rent, reached a record high of 7.4 million in 2012, with increases concentrated in the highforeclosure areas of the South and West. Although vacant homes can be found throughout the

country, they tend to be concentrated; nearly 40 percent of the nation’s vacant homes are located

in just 10 percent of all census tracts. More than half of the census tracts with vacancy rates of

20 percent or higher were in just 50 counties, most of them in metropolitan areas. Wayne County

in Michigan and Cook County in Illinois, for example, each have more than 200 high-vacancy

neighborhoods. Another example is in the District of Columbia, where this 10 square mile city

has over 3,000 vacant and abandon buildings. In addition to the many vacant and abandoned
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residential properties across the nation, estimates place the number of brownfields — idle former

industrial properties with real or perceived environmental contamination — at approximately a

half-million (HUD, 2014). The use of UASs for inspecting vacant and abandon buildings is warranted and can considerably

reduce the risk of building collapse and identify dangerous building conditions for citizens. An

inspector may not have the most effective access to monitor, collect, and assess potential building

code violations. Also, he or she may not have access to the rear of the building, which could be

land locked by other buildings or by other obstacles. Moreover, a mUAS can gather more

information safely, survey the alleged violation, and save lives from buildings that may collapse. For example, the DJI Phantom 2 Vision Plus has the capability to inspect, photograph, capture,

collect images, and upload data to cloud software that is rendered into 3D images. The inspector

can now have the ability to gather 2D volumetric data points and view a 3D image of the entire

building through the use of the mUAS’s ability to hoover and circle the site.

6.2 The Need for Substructure Bridge Inspections

In a recent analysis of the U.S. Department of Transportation’s bridge inventory database, the

2015 American Road & Transportation Builders Association (ARTBA) Report found that over

61,000 bridges in the U.S. need structural repair. The analysis of the federal government data,

conducted by ARTBA’s Chief Economist Dr. Alison Premo Black, shows cars, trucks and school

buses cross the nation’s 61,064 structurally compromised bridges 215 million times every

day. Not surprisingly, the most heavily traveled are on the Interstate Highway System, which

carries the bulk of truck traffic and passenger vehicles (Houlihan, 2015). Dr. Black suggests that the bridge problem could get worse. For instance, the Federal Highway

Trust Fund (HTF) is the source of 52 percent of highway and bridge capital investments made

annually by state governments. The HTF has suffered five revenue shortfalls between 2008 and

2014, and has been bailed out with nearly $65 billion in revenues from the General Fund just to

preserve existing investment levels. Nearly a dozen states so far have canceled or delayed road

and bridge projects because of the continued uncertainty over the trust fund situation. “State and

local governments are doing the best they can to address these significant challenges, given

limited resources,” Black says. ARTBA expects that number to increase as the deadline nears.

“Many of the most heavily traveled bridges are nearly 50 years old. Elected officials can’t just

sprinkle fairy dust on America’s bridge problem and wish it away,” Dr. Black said. “Bridge

decks and support structures are regularly inspected by the state transportation departments for

deterioration and are rated on a scale of zero to nine—nine being “excellent” condition. A bridge

is classified as structurally deficient and in need of repair if its overall rating is four or below.

The ARTBA analysis of the bridge data supplied by the states to the U.S. DOT also found

(Houlihan, 2015):
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Page 31 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

 Pennsylvania (5,050), Iowa (5,022),

Oklahoma (4,216), Missouri (3,310),

Nebraska (2,654), California (2,501),

Kansas (2,416), Mississippi (2,275),

Illinois (2,216) and North Carolina

(2,199) have the highest numbers of

structurally deficient bridges. The

District of Columbia (14), Nevada (34),

Delaware (48), Hawaii (61), and Utah

(102) have the least.  At least 15 percent of the bridges in eight states—Rhode Island (23 percent),

Pennsylvania (22 percent), Iowa (21 percent), South Dakota (20 percent),

Oklahoma (18 percent), Nebraska (17 percent), North Dakota (16 percent) and

Maine (15 percent)—fall in the structurally deficient category.

These State Bridge Inspection Units are responsible for managing their local transportation

structures. This includes performing bridge inspections in accordance with Federal regulations

on all bridges owned by local government agencies, making structure work repair

recommendations, determining the safe load capacity of all bridges, reviewing and approving

encroachment permits. These agencies hire engineering contractors or use internal staff to

inspect bridges. Various methods are used to inspect bridges. They include the use of helicopters,

truck & boom, underwater diving, trailer mounted units, and water taxi inspections (see Figure

3). However, these agencies are faced with many challenges using these current methods. One

such method, as shown in Figure 3, include utilizing a mobile inspection vehicle to lower

inspectors over the side of the bridge. This method causes traffic congestion, accidents, and has

the risk of the inspector falling out of the boom carry box. Challenges that agencies must mitigate

include:  Reduced work windows because of high traffic demands thus limiting inspectors’

access to key sections of bridges.  More stringent regulatory obligations also require adjustments to inspection

schedules to accommodate nesting periods of protected migratory bird species.  Inspection schedules have flexibility built to accommodate unplanned inspections

in the case of a bridge suffering unexpected damage.  New FHWA inspection performance measures require a bridge to be inspected as

close as possible to the date plus the inspection cycle (typically 2 years).

The use of UASs for inspecting bridge substructures is warranted and the Petitioner’s planned

operations dramatically improves safety and reduces risk concerning bridge inspections by

alleviating human exposure to dangers associated with current methods such as helicopters, truck

& boom, underwater diving, trailer mounted units, and water taxi inspections. The most used

method, mobile truck and boom, is dangerous to ongoing motor vehicles and has caused serious

accidents over the years. In addition, these standard procedures are extremely labor-intensive

and time consuming. sUASs serves as a feasible solution for State Bridge Inspection Units

seeking an alternative method that is safer, less expensive, and efficient. For example, using the

Figure 3: A bridge inspection using truck & boom.
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Tali H500, we have the capability to inspect, capture, collect infrared data for analysis and upload

data to cloud software that allows engineers to conduct detail assessment of the bridge

substructure. 6.3 The Need for Construction Inspections

Construction is a high hazard industry that comprises a wide range of activities involving

construction, alteration, and/or repair. Examples include residential construction, commercial

building erection, excavations, demolitions, and large scale jobs. Construction workers engage

in many activities that may expose them to serious hazards, such as falling from rooftops,

unguarded machinery, being struck by heavy construction equipment, electrocutions, silica dust,

and asbestos (U.S. Department of Labor, 2015).

In general, construction activities falls into two categories, those activities which are conducted

in compliance with applicable authorities and those which are not. The vast number of compliant

activities are accounted for with permits. Construction activities which are conducted in

compliance with permits or regulations are inherently conducted in a safer manner. City

inspectors are not onsite full-time to assess potential dangers from deficiencies in excavation,

grading, building footings, foundations, and framing. Some general contractors and home

owners bypass the permitting process and begin and complete construction activities which are

not in compliance with the applicable regulatory or statutory authority. These noncompliant

activities are frequently missed by city inspectors, but are often discovered after an accident or

the death of workers or citizens.

Construction which is conducted in violation of permitting or regulatory requirements is difficult

to uncover due to some privacy and trespassing rules. Many times, neighbors or concerned

citizens call city inspectors to notify them of suspicious construction activities or projects. City

inspectors are often thwarted from pursuing an enforcement or compliance action by the simple

fact that the homeowner may not be home or the property owner may not be on site at the time

of the attempted inspection. The city inspector cannot gather evidence to support a case for

noncompliance without violating city regulations with respect to access to private property.

The use of UASs for determining whether construction sites are in compliance with applicable

permits and regulations is justified and can considerably reduce the risk to inspectors, workers,

residents, and survey teams. To monitor, gather, and collect data would often require an

inspector to get this information from difficult or dangerous areas onsite or be at risk of possibly

falling at the jobsite. Falls are the leading source of workplace fatalities and injuries on

construction sites (OSHA, 2015). However, a UAS can gather more information safely, reduce

falls, and save lives on these types of construction sites. For example, the DJI Phantom 2 Vision

Plus has the capability to inspect, photograph, capture, collect images, and upload data to cloud

software that is rendered into 3D images and maps. As a result of this technology, the building

inspector, now has the ability to gather data and view building site progress without going to the

site.
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6.4 The Need for Temporary Tower Crane Assembly Verification Inspections

The Federal Occupational Safety & Health Administration (OSHA) is a small agency that has

approximately 2,200 inspectors responsible for the health and safety of 130 million workers,

employed at more than 8 million worksites around the nation — which translates to about one

compliance officer for every 59,000 workers.

OSHA estimates that there are about 125,000 cranes in operation in the construction industry in

the United States every day. There are an additional 80,000 to 100,000 involved in the maritime

shipping industry. Because cranes are so large, and the weights they carry are so immense, even

the slightest operator error or improperly maintained bolt can result in a catastrophic accident. Early governmental regulation of the crane and rigging industries was light, mostly occurring at

the state level. The most significant development in the regulatory landscape took place when

the OSHA Act of 1970 was signed into law. OSHA regulations lagged behind industry standards

until 2010, when a broad update of OSHA construction crane regulations went into effect. In

developing the new regulations, OSHA consulted with a panel of industry experts and applied

cost-benefit analyses in addition to unalloyed safety considerations. Though portions of the

regulations remain controversial in the industry, the agency clearly based its work on a broad

view without reacting “knee-jerk” to particular events of failures (Shapiro & Ratay, 2013).

By its very nature, construction is a challenging and dangerous industry. In contrast to most

industries, construction often requires travel to multiple sites, each with their own constantly

changing hazards. Temporary tower cranes play an essential role on construction sites

throughout the United States on a daily basis. Also, temporary tower cranes add many complex

risks to the construction process. Recently, numerous fatal crane collapses have grabbed national

news headlines, increasing attention and scrutiny of construction crane operations. The most

highly publicized being massive tower crane failures in New York, Miami, and Seattle. Estimates

indicate that up to 33% of construction casualties and between 8 to 16% of construction fatalities

involve cranes (Parfitt, 2010). Between 1992 and 2006, 610 construction worker deaths were attributed to crane accidents,

about 42 per year. Nearly two-thirds of all crane-related accidents are caused by tower style

cranes. Other styles responsible for injuries include mobile cranes, gantries and loader cranes. In

the US, most medium-sized and large construction sites are serviced by mobile cranes. Their

variety, purposes and duration of use vary greatly. A truck-mounted mobile crane may show up

at a site to make a handful of picks before departing, while a crawler crane could be set up for a

year-long assignment. Mobility confers its own set of hazards, inferring likelihood that an

operating site has not been adequately surveyed beforehand and perhaps not prepared for the

presence of a crane. Moreover, the operator and crew may be encountering unfamiliar conditions

with unexplored hazards. Mobility also confers the possibility of last-minute changes or

improvisations, defeating the benefit of a plan (Shapiro & Ratay, 2013). The Petitioner’s work

shall focus on the assembly/disassembly failures and among mobile cranes, the frequent types

of serious accidents are:
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 Electrocution – the victims is usually a rigger handling the load when the boom or

load line contacts an overhead power line.  Overturning – caused by overloading, ground support failure or improper

operation of the crane (see Figure 4).  Collision – a portion the crane or a suspended load strikes a building, person or

object, or a suspended load is trapped.  Over-travel – the load block strikes the boom tip or boom runs up against the

backstops.  Structural failure – from excessive side loading, overloading or an equipment

deficiency.  Assembly/disassembly failure – the crew deviates from a qualified procedure.  Crushing – a worker is caught by a rotating or moving part such as a revolving

deck or a spooling rope.

Similar types of accidents can occur with tower cranes,

albeit less frequently because tower cranes tend to work

under more controlled circumstances than mobile

cranes. Tower cranes are used in the US primarily on

major construction sites. By nature, they are fixed or

semi-fixed in place and, therefore, less prone to

problems caused by scanty planning, hasty preparation

or last-minute improvisation. The greatest exposure of

these machines to accidents occurs when they are being

erected, dismantled or jumped (Shapiro & Ratay,

2013). A crane accident in the core of a large city can be a catastrophic event that splashes across

television screens and tabloid covers (see Figure 5). Government officials are compelled by

public outcry to react; their constituents must be made to feel safe while walking through streets

stalked by the shadows of giant construction cranes. Under such circumstances, major accidents

in dense urban zones have spurred the creation of crane regulations, particularly in California

and New York. Officials in other localities have reacted similarly to singular dramatic accidents,

sometimes creating laws that are closely crafted to the particularities of the accidents that

spawned them (Shapiro & Ratay, 2013).

Figure 4: A crawler crane relies on firm level

ground support to keep it from tipping.
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This jagged path to the making of crane rules is an aberration. The great bulk of crane standards

and regulations in both the United States and the world at large are, instead, the product of a

steady progression of deliberations, built upon collective knowledge and wisdom acquired over

decades. Much of the knowledge, unfortunately, comes

from the experience of accidents.

Most crane accidents do not occur in the center of

major cities, nor do they make the front pages of

tabloids. These lesser-publicized events add up to a

much greater human and economic toll than the

headline-grabbers. They do not, however, escape

attention. Stakeholders, who suffer the losses and deal

with the consequences, do not ordinarily forget them

(see Figure 6). For those apt to learn from experience,

the cruel lessons of a serious mishap will be

internalized, analyzed and applied (Shapiro & Ratay,

2013). Regardless of what laws are in the books -- if enforcement is lacking -- conditions are not apt to

improve. The arrest of former inspector Edward J. Marquette for allegedly falsify a business

record and filing it with the buildings department has reduced the number of crane inspectors in

New York to four. With only four inspectors being left responsible for 250 cranes in use, of

which 30 are tower cranes, the ability to fully enforce regulations is clearly questionable

(Sawyer, et al., 2008). Moreover, some building inspection units don’t have certified inspectors

to climb and assess cranes. For example, in the District of Columbia, there are over 52 cranes in

operations that are required to be inspected by law. However, the D.C. Building Inspection Unit

does not have a certified inspector on staff to enforce the regulations.

The use of UASs for inspecting cranes is justified and

alleviates human exposure to danger associated with

this high-risk job. The current crane inspection method

consists of an inspector climbing the crane and visually

inspecting the base, mast, jib, and counter-jib.

Inspectors are at risk and are exposed to unsafe

conditions when conducting these inspections. In

some situations, building inspection units may rely on

the general contractor to conduct self-inspection of the

crane, since they lack the resources to provide a

certified staff to verify the assembly. The Petitioner’s

planned operations addresses the safety issues and

diminishes the risk to workers, inspectors, and citizens

by ensuring that the assembly was constructed

properly and reduces the chances of crane failure. To further enhance safety and the public

interest, the inspector has the ability to review, inspect, and assess the entire crane from detailed

images gathered from the UAS. The UAS has the capability to capture and upload data to cloud

Figure 5: On the Upper East Side of Manhattan,

a tower crane collapsed during a climbing

operation, resulting in multiple deaths and

massive property damage.

Figure 6: A half-mile-long cableway across

Black Canyon on the Colorado River collapsed

during high winds. Its loss set back construction

of a vital interstate bridge link by two years.
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Page 36 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

software that renders the crane as a 3D image. The inspector, located onsite, now has the ability

to view 3D images of the entire crane within 45 minutes. The Petitioner’s UASs remove the environmental impact by significantly decreasing the energy

used for aerial imaging for crane, bridge and construction site inspections. The UAS uses a

rechargeable lithium polymer battery, as opposed to Jet A or JP5 (kerosene based) fuel that burns

in the operations of a helicopter, which weights thousands of pounds. Also, the public’s interest

is further minimized in the event of an accident, thus reducing the human exposure to harmful

carbon emissions associated with helicopters and/or manned aircraft.

In addition, the Petitioner’s UASs may well replace the need to use helicopters and manned

aircraft to inspect cranes, bridges, and construction sites. For our planned operations, our

proposed UASs are under 6 pounds and carry no combustible fuel on board, as opposed to the

larger powered helicopters and manned aircraft. The paradigm shift to UASs from larger manned

aircraft minimizes risks to the public and improves the overall health and safety of workers.

Finally, granting this Petitioner’s exemption application will fulfill Congress’s intent of allowing

UASs to operate with significant safety precautions in low risk environments as stated in Section

333 (a) – (c) of the FMRA. The law directs the FAA Administrator to grant case-by-case

authorization for certain unmanned aircraft to perform commercial operations prior to the

finalization of the small UAS Rule under Section 332 of FMRA, which will be the primary

method for authorizing small UAS operations once it is complete (Section 333, 2015). In

addition, the Petitioner’s goal is to aide and assist government agencies as a contractor to perform

aerial public safety inspections and photography of vacant/and or occupied buildings, crane

assembly verification, construction activities for compliance determination, and substructure bridge

inspections using UASs. As a result, the public as a whole will benefit from the safer, efficient,

and reliable aerial services that UASs operations will provide for state and local government

agencies.

7 Drug Free Workplace

Alternatives Renewable Solutions, LLC intends to help provide a safe and drug-free work

environment for our clients, employees, and contractors. All employees or contractors who

perform safety inspection related activities and functions are prohibited from performing work

if they have alcohol or prohibited drugs in their system. With this goal in mind and because of

the serious drug abuse problem in today's workplace, we are establishing the following policy

for existing and future employees, staff, and contractors of Alternatives Renewable Solutions,

LLC.

The Company explicitly prohibits:  The use, possession, solicitation for, or sale of narcotics or other illegal drugs,

alcohol, or prescription medication without a prescription on Company, customer

premises or while performing an assignment in public domain.  Being impaired or under the influence of legal or illegal drugs or alcohol away from

the Company customer premises, or public domain, if such impairment or influence
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Page 37 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

adversely affects his/her’s work performance, the safety of the of others, or puts at

risk the Company's reputation.  Possession, use, solicitation for, or sale of legal or illegal drugs or alcohol away from

the Company, public domain or customer premises, if such activity or involvement

adversely affects the employees or contractors work performance, the safety of the

employee or of others, or puts at risk the Company's reputation.  The presence of any detectable amount of prohibited substances in the employees or

contractors system while at work, while on the premises of the company, or its

customers, or while on company business. "Prohibited substances" include illegal

drugs, alcohol, or prescription drugs not taken in accordance with a prescription given

to the employee or contractor.

The Company will conduct drug and/or alcohol testing under any of the following circumstances:  RANDOM TESTING: Employees or contractors may be selected at random for drug

and/or alcohol testing at any interval determined by the Company.  FOR-CAUSE TESTING: The Company may ask an employee or contractor to

submit to a drug and/or alcohol test at any time it feels that the employee or contractor

may be under the influence of drugs or alcohol, including, but not limited to, the

following circumstances: evidence of drugs or alcohol on or about the his/her person

or in the his/her vicinity, unusual conduct on the his/her part that suggests impairment

or influence of drugs or alcohol, negative performance patterns, or excessive and

unexplained absenteeism or tardiness.  POST-ACCIDENT TESTING: Any employee or contractor involved in an on-thejob accident or injury under circumstances that suggest possible use or influence of

drugs or alcohol in the accident or injury event may be asked to submit to a drug

and/or alcohol test. "Involved in an on-the-job accident or injury" means not only the

one who was or could have been injured, but also any employee or contractor who

potentially contributed to the accident or injury event in any way.

If an employee or contractor is tested for drugs or alcohol outside of the employment/contractor

context and the results indicate a violation of this policy, or if an employee/contractor refuses a

request to submit to testing under this policy, the he or she may be subject to appropriate

disciplinary action, up to and possibly including discharge from contract or employment. In such

a case, the employee/contractor will be given an opportunity to explain the circumstances prior

to any final action becoming effective.

8 Privacy Policy

All flights will occur in accordance with state, county, or local laws regarding privacy.
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Page 38 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

9 Federal Registry Summary

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Parts

21, 27, 45, 61, 91, and 93, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

The Petitioner seeks an exemption from the following rules:

a) 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

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

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

Identification Requirements

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

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

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

g) 14 C.F.R. §91.103: Preflight Action

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

i) 14 C.F.R. §91.119: Minimum Safe Altitudes

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

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

l) 14 C.F.R. §91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

m) 14 C.F.R. §§91.405(a); 407(a)(1); 409(a)(s); 417(a)(b): Maintenance

Inspections

n) 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V- Washington, DC Metropolitan Area Special Flight Rules, §93.333: Failure to

Comply with this Subpart

o) 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V- Washington, DC Metropolitan Area Special Flight Rules, §93.339 (a) through

(e): Requirements for Operating in the DC SFRA, including the DC FRZ

p) 14 C.F.R. Subchapter F, Part 93-Special Air Traffic Rules, Subpart V- Washington, DC Metropolitan Area Special Flight Rules, §93.341 (a);(c1)

through (c5);(d): Aircraft Operations in the DC FRZ

Approval of these exemptions will allow the Petitioner to offer a unique and real-time

commercial UAS services for a host of industries and applications. The exemptions will improve

and enhance safety by reducing risk to the public and property owners from the hazards

associated with performing equivalent work with conventional aircraft and rotorcraft.

10 Conclusion

Based on the information submitted within, the Petitioner requests that the FAA Administrator

grant this exemption. Given the description of proposed operations, procedures and supporting

documents, the Petitioner’s proposed usage does not pose a hazard to the NAS or to the public. Moreover, the size, weight, speed, operating capabilities, and operations within visual line of
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Page 39 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

sight and security provides more than adequate justification for granting the requested

exemption. Therefore, granting of the exemption will permit the Petitioner to offer aerial

inspection services to State and local government agencies using both mUAS and sUAS assets

for a host of industries and applications. Accordingly, the Petitioner respectfully requests that

the FAA grant the requested exemption without delay.

Submitted on May 23, 2015

William T. Jones

William T. Jones, Esq.

General Counsel

Alternatives Renewable Solutions, LLC

1725 I Street, NW, Suite 300

Washington, DC 20006
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Page 40 Petition of Alternatives Renewable Solutions, LLC for Exemption Pursuant to Section 333 of FMRA of 2012

11 References

Culver, C. (1994). Mobile Crane Inspection Guidelines for OSHA Compliance Officers. Washington, DC:

U.S. Department of Labor.

Houlihan, E. (2015, April 1). No April Fools’ Day Joke: Over 61,000 U.S. Bridges Need Structural Repair,

New Analysis of U.S. Department of Transportation Data Finds. Retrieved from ARTBA:

http://www.artba.org/2015/04/01/no-april-fools-day-joke-over-61000-u-s-bridges-need-structuralrepair-new-analysis-of-u-s-department-of-transportation-data-finds/

HUD. (2014, Winter). Evidence Matters. Retrieved from HUD User:

http://www.huduser.org/portal/periodicals/em/winter14/highlight1.html

OSHA. (2015). Commonly Used Statistics. Retrieved from Occupational Safety & Health Administration:

https://www.osha.gov/oshstats/commonstats.html

Parfitt, K. (2010). Crane Failures. Retrieved from Crane Failures:

https://failures.wikispaces.com/Crane+Failures

Perlman, M. (2014, 10 14). High Flyer? Dji Phantom 2 Vision+ Drone Review. Retrieved from Digital

Photography Review: http://www.dpreview.com/articles/6508751066/dji-phantom-2-vision-dronereview

Sawyer, T., Carlsen, R., Barner, C., Fulmer, B., Bodilly, L., E., S., & Wood, D. (2008, March 31). Tower- Crane Fears Drive Regulations. Engineering News Record, p. 11.

Section 333. (2015, March 25). Retrieved from FAA:

http://www.faa.gov/uas/legislative_programs/section_333/

Shane, J. M. (2011). Abandoned Buildings and Lots. Retrieved from Center for Problem-Oriented Policing:

http://www.popcenter.org/problems/abandoned_buildings_and_lots/1

Shapiro, L., & Ratay, R. (2013, November). Structure Magazine. Retrieved from Changes in Codes,

Standards and Practices Following Crane Failures, Part 3 – Cranes:

http://www.structuremag.org/?p=1110

U.S. Department of Labor. (2015, April). Construction Industry. Retrieved from OSHA:

https://www.osha.gov/doc/index.html
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12 Supporting Documents

12.1 Aerial Inspection Flight Sign

12.2 DJI Phantom 2 Vision Plus User Manual

12.3 DJI Pilot Training Guide

12.4 DJI Prop Guard Assembly Guide

12.5 DJI Battery Safety Guide

12.6 DJI Flying Flowchart

12.7 DJI Advanced Manual

12.8 Tali H500 GoPro Manual

12.9 Tali H500 Bluetooth Datalink Manual

12.10 Tali H500, Quick Start Guide

12.11 Tali H500 iLook Settings

12.12 ARS Flight Safety and Procedures Manual