12/10/2015 tJ:S:DepartmentofTransportation, Docket Operations Ground Floor, Rm. W12-140 1200 New Jersey Ave, SE -.Washington, DC 20590 Nick Alati 6723 E Ellis street MesaAZ 85205
T:4805072775 ·Nick@Aisllc.us



### Regarding: FAA Exemption Rulemaking Section 333 ofthe FAA Reform Act and Part 11- 14 C.F.R. § 

### 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) & 

### (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a) & (b) 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b)**De~r** Sir orMadam:
Alati's Inspection Service LLC, is requesting exemption from the Federal Aviation Regulations ("PARs") listed below and.pursuant to the FAAModernization and Reform Act of2012 and the procedures contained within 14 C.P.R. 11. in orderto commercially operate a small ultra light unmanned aircraft system ("UAS"), specifically the following UAS platforms will be used:
DJIPhantom II Yuneec Typhoon Q500 4K 3DR Solo
Attachment 1lists the technical specifications for each ofthe previously listed UAS(s).
The Pilot In Command (PIC) willhold either an airline transport; commercial,private, recreational, or sport pilot certificate. The PIC will also hold a currentFAA airman medical certificate or a valid U.S. driver's license issued by a,state, the District ofColumbia, Puerto Rico, a·territory, a possession, or the Federal government. Alati's Inspection Service LLC, would like to expand its operations, and wishes to add the followng photography/videography services.

• Real Estate • Home Inspections· Specifically, it wishes to provide aerial imaging to its customers in need ofaerial photography/videography. With the advancement ofInternet technology and consumer adoption ofshopping for properties online, the demand for high-resolution aerialgraphics and video is unprecedented. In addition, it wishes to be able to



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" I ' , i ,, '•'perform property (primarily root) inspections via UAS. All UAS pertinent safety and risk management measures as specified in the FAA's Risk Management Handbook shall be complied with.
A grant ofthe exemption request, by the FAA, wouldpermit operation ofultra lightweight and unmanned UAS to operate inpredetermined areas away from the general public, airports, heliports and vehicular traffic, primarily over individual properties/communities for the purpose ofrecording real-estate listings (photo/video).
In summary and in accordance with this request ofexemptionrequest as authorized and outlinedbythe FAA under Section 333(c) ofthe Reform Act specified for use ofUAS' for "RealEstate" purposes, Alati's Inspection Service LLC will adhere to all FAAregulations at all times and shall conduct all flight operations in strictcompliance and safety protocols as mandated and required by regulations andbestpractices. Respectfully, we request the grant ofexemption to operate ultra light weight, remote controlled UAS's for commercial purposes as described in this request and as allowable by law. This grant ofexemption will allow the company to offer such services to private and govememententities who have little to no experience piloting UAS's buthave a need to getimages that are only possible from a UAS in order to compete within an ever demanding technology driven market. b:lati'slnspection Service

### LLC submits thatthis application has been preparedby Nick Alati (owner ofAlati's Inspection Service LLC) and not an attorney using his personal knowledge ofexisting FARs as well as utilizing excerpts from other similar applications and assistance from Mile High Drone Services. Consequently, ifNick Alati has unintentionally omitted any relative FARs, Alati's Inspection Service LLC,humbly request an opportunity to submitto those accidental omissions. The essence ofthis application is to declare that, Alati's Inspection Service LLC meets and exceeds the FAA's expected competency for piloting the listed UASs for commercial purposes and that the UAS that we specified earlier meets and exceeds the safety requirements as set forth by the Secretary of Transportation thereby prompting the request for COAunder Section 333. 

### 1. ContactInformation: Alati's Inspection Service LLC Attn: Nick Alati 6723 E Ellis street Mesa AZ 85205 4805072775 Nick@Aisllc.us


### 2. The Specific section(s) of 14 

### C.F.R. seeking anexemption from are: 14 CFR21; 14 C.P.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.P.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).


### 3. The extent andreason ofrelief:
Alati's Inspection Service LLC, is seeking relieffrom existing FARs that currently prohibitthe use of UASs from operating commercially for the purpose ofaerial photography/videography in accordance with the FAAModernization and Reform Actof2012 112 P.L. 95 § 331-334. The Reform Act Subtitle B: Unmanned Aircraft Systems- (Sec. 332) "Requires the Secretary to develop a plan to accelerate safely the integrationby September 30,2015,ofcivil unmanned aircraft systems (UASes, ordrones) into the national airspace system." The company humbly requests that itbe allowed to commercially operate the listed UASs during the time period the FAA is further establishing rules and regulations , governing the operations ofsuch craft.**~<)IL**The Secretary ofTransportation has been askedby Congress to, among other things, consider whether certain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUASs do not create a hazard to 

## user·s ofthe National Airspace System orthe public orpose a threat to national security in light ofthe following:
The UAS's size, weight, speed, and operational capability; Operation ofthe UAS in close proximity to airports and populated areas; and Operation ofthe UAS within visual line ofsight (VLOS) ofthe Pilot and VO Accordingly, all flights will be conducted by a PIC and aVO in accordance with FAAPolicy N 8900.227 Section 14 "Operational Requirements for UASs" and with the following restrictions: All aircraft will bemade with a UAGross weight ofless than 55 pounds All flights will occur only during daylight hours. All flights 

### will occur at orbelow**400~feetAGL** 5 nautical miles from an airporthaving an operational control tower; or 3 NM from an airport with a published instrument flight procedure,but not an operational tower; or 

## .·Z NM from an airport without a published instrument flight procedure or an operation tower; or 2 NM from a heliport with a published instrument flight procedure. For safety, no flight with winds over 10 mph. Flight only in GPS mode that allows UAS to hover inplace when radio controls are released. All operations to be conducted inGPS mode only.


### 4. How therequestwill benefit the public as a whole: Aerial photography is becoming a critical component ofthe way a company does business. Aerial photography via UAS allows people to get a vantage pointthat never usedto be possible or economically feasible. It is much too dangerous and expensive to hire a manned aircraft to take many aerial images thereby making the UAS option more cost effective and safer. There simply is not enough 

### VAS Pilots to coverthe demand for these images, which is leading to unlicensed UAS operators which ultimately results inuntrained and unqualified operators. 

### 5. Reasons why the exemption would not adversely affect safety; orhow the exemption would provide a level for safety atleast equal to the existing rule:
An exemption would not adversely affect safety because this application applies only to aircraft characteristics and applications within FAA specified limitations. These limitations provide for at least an equivalent safety standard. However, the experience ofa certificated rated pilot allows him/her to utilize his/her experience in UAS operations thereby exceeding safety and improving airspace operations by allowing aerial imaging clients to choose an pilot that knows how to pilot an aircraft safely and within regulated limits. In addition, by providing unmanned services to the market place, there will beless of a demand for manned operations, which will provide for safer and quieter residential aerial photography. In addition, inspecting roofs via UAS will reduce the risk ofpersonal injury because people who no longer have to walk onroofs which is inherently dangerous.
As previously stated, all flights will be conductedby a PIC and a VO in accordance with FAAPolicy N 8900.227 Section 14 "OperationalRequirements for UASs" and with the following restrictions:
All aircraft will be made with a UA Gross weight ofless than 55 pounds 

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All flights will occur only during daylight hours. All flights will occur at orbelow 400 feet AGL 5 nautical miles from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure,but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operation tower; or 2 NM from a heliport with a published instrument flight procedure. Extensive, pre-flight briefings are required between the PIC and the VO. A flight plan is required prior to each flight. All aircraft operations must be conducted within manufacturer recommended specifications. All site permissions mustbe obtainedprior to flight.


### 6. Asummary the FAAmay publish 

### in the Federal Register: 14 C.P.R. 21 and 14 C.P.R. 91: Airworthiness Certificates, Manuals and The Like.
14 C.P.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(l).The size, weight and enclosed

.. _operationalareaoftheJistedUASspermitexemptionfmm Part 21·because**th~Hsted-U**ASs meets (and exceeds) an equivalent level of safety pursuant to Section 333 ofthe Reform Act. The FAAis authorized to exempt aircraft from the airworthiness certificate requirement underboththe Act ( 49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces oflegislationpermitthe FAA to exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability andproximity to areas such as airports and dense populations. The current and projected UAS's meet orexceedeach ofthe elements.
14 C.P.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplatedby the FARs, this Regulation is inapplicable.
14 C.P.R.§ 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on boardpilots or, passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such manuals onlocation with the Pilot. The FAAhas previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738,9299,9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.
14 C.P.R.§ 91.121 regarding altimeter settings is inapplicable insofar as all UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.P.R.§ 91.203 (a) and (b) provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level ofsafety will be achieved by maintaining any such required certifications and registrations with the Pilot.
14 C.P.R. § 45.23: Marking ofThe Aircraft. Applicable Codes ofFederal Regulation require aircraft to be marked according to certain specifications. The listed UASs are,by definition, unmanned. They therefore do nothave a cabin,

, ,cockpitorpilot station on which to mark certain words orphrases. Further, two-inch lettering is

difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. The FAAhas previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167Aand 10700.
14 C.P.R.§ 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.P.R. §§ 61.113 (a) & (b), privatepilots are limited to non-commercial operations. The 

### 1J<$a__PIC can achieve an equivalentlevel of safety as achievedby current Regulations because the listed UASs do not carry any pilots orpassengers. Further, the PIC possess an FAApilot certificate, which helps his remote control piloting skills and factors in his experience in assessing any flight risks. The risks attended to the operation ofthe listed UASs are far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61,et seq. Thus, allowing the PIC to operate the listed UASs and meet and exceed current safety levels inrelation to 14 C.F.R. §61.113 (a) & (b).
14 C.F.R. 91.119: Minimum Safe Altitudes.
14 C.F.R. § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. The listed UASs will never operate at an altitude greater than 400ftAGL. The PIC will also operate the listed UASs in safe areas away from public and traffic, providing a level ofsafety atleastequivalent to orbelow those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofthe listed UASs, an equivalent or higher level ofsafety will be achieved.
-14C**.F.R~** 91.405 (

### a)t-407(a){l); 409-(a)-(2-); 411fa)-&(b):M-aintenanreInspectiuns; The above-cited Regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribedin subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

... "
These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to the listed UASs. However, as a safety precaution the UAS which will be used will be inspectedbefore and after each flight.

In Summary:
Alati's Inspection Service LLC,respectfully request that the FAAgrant the exemption request and further volunteer any information gathered during flights in the eventthe FAAis interested in live field data. Alati's Inspection Service LLC, agrees and attests to adhere to any further limitations the FAA imposes, now orin the future. Satisfaction ofthe current criteriaprovidedin Section 333 ofthe Reform Act of2012- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security

- provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofthe listed UASs for commercial purposes. Alati'slnspection Service LLC looks forward to support the FAA and UAS community in its quest to establish proper**re(lu!atio~s.** andprotocols. for the s.afe introduction ofunmanned aircraft into the national**ain;pac1J~cl** Sincerely,

# ~;~/0~/~ Alati's Inspection Se 1ce

..., 6723 E Ellis street MesaAZ 85205

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Attachment 1 

### DJI Phantom II (http://www.dji.com/product/phantom-2/spec?www=v1)



### General Features: Ready to Fly, Multifunctional Quad-rotor System CustomizedH3-2D and H3-3D Gimbal Support PrecisionFlight and Stable Hovering 25minFlightTime & SmartBattery Auto Return-to-Home & Landing Advanced PowerManagement _IntelligentOritmtationControl (IOC)

..._- ..-· ---- - --

Easy BatteryReplacement Self-tightening Propeller Video Downlink Support CAN-Bus ExpansionModule 

### Aircraft: Weight (Battery & Propellers Included): lOOOg Hover Accuracy (Ready To Fly): Vertical: 0.8m;,Horizontal: 2.5m Max Yaw Angular Velocity: 200 degrees/s MaxTilt Angle: 35 degrees Max Flight Speed: 15rnls(NotRecommended) Max Ascent I Descent Speed: Ascent: 6m/s; Descent: 2rnls DiagonalLength: 350mm Supported Battery: DJI SmartBattery FlightTime: 25mins Take..:OffWeight: less than 1300g Operating Temperature: -lO(C),.., 50(C)



### Yuneec Typhoon QSOO 4K (http:// www.yuneec.com/Typhoon-Specifications- Typhoon-4K)

FlightTime: up to 25 minutes Weight with Battery and Payload: 60.0 oz (1700g) Weight without Battery and Payload: 40.0 oz (1130g) Batterx; 5400mAh 3S 11.1V LiPo (included) Charger: 3S ll.lVLiPo DC Balancing Smart Charger wjth AC Adapter (included)

### Tra~smitter: 10-channel2.4GHz with 5.8GHz video downlink (included) 3 FhghtModes: Smart (Follow Me and Watch Me), Angle and

### Hom~~MaximumFlying Height :Default 122m (400ft) above Ground Level (Adjustable viathe Typhoon GUI) Maximum Rotation Rate: 65 degrees/s Maximum Roll Angle: 35 degrees Operating Temperature Range: ?5(C) to 80(C) Radio Control Frequency Band: 2.4GHz Max. Descent Speed: 2m/s Max. Flight Speed: 17mph 

### I 27 kph (Angle Mode), 22mph 

### I 35 kph (Follow Me/WatchMe)

3DR Solo (https://3drobotics.com/solo-gopro- drone-specs/)

_Cameras: Compatible with-GoPro.HER03,3-+and4;-opt-imized-for-JIER0-3+-and4-

- -**--~----** -"·
---·-- --- Streaming video quality: 720p Flighttime: 25 minutes; 20 minutes with payload* Range: .5 miles** (.8 km) Max speed: 55 mph (89 km/h) Max ascent speed: 10m/sin stabilize mode; 5 m/s in "fly" mode Max descent speed: ditto Max payload: 420 g Max altitude: 400ftperFAAregulation, user adjustable (122m) Motors: 880 kV Propellers: 10?? diameter 4.5?? pitch self-tightening (24 em diameter 144 empitch); glass-reinforced nylon

· Autopilot: Pixhawk 2

Software: APM:Copter Communication: 3DR Link secureWiFi network Frequency: 2.4 GHz Weight: 3.3lbs. (1.5 kg) 

### I 3.9lbs. (1.8 kg) with GoPro+ and Solo Gimbal Dimensions: 10 in. tall (25 em), 18 in. (46 em) motor-to- motor Flightbattery: Lithium polymer 5200 mAh 14.8 Vde Battery charge time: ,.., 1.5 hours Controllerbattery: 2600 mAh 7.2 Vde rechargeable lithi- urn ion App requirements: iOS 8.0 or later 

### I Android 4.3 orlater (}.__

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