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Anthony J. Pucciarella

ALARIS

PO Box 1835

Lusby, MD 20657

240.538.8444

Tony@TeamAlaris.com

20 March 2016

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Petition for Grant of Exemption Pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012

To Whom It May Concern:

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

and 14 C.F.R. Part 11, UAV Solutions Inc. (UAVS) hereby applies for an exemption from the 

listed Federal Aviation Regulations (FARs) to allow commercial operation of its Cougar Small 

Unmanned Aircraft System (UAS) to conduct aerial video, photography, inspection, and 

training, provided such operations are conducted within the conditions outlined in this 

exemption request or as established by the FAA.

In addition to this Petition for Exemption, Alaris will also submit the Cougar UAS Operations and 

Maintenance Manual (referred to as “Operating Documents” in this petition). Alaris submits 

this document as confidential material under separate cover pursuant to 14 C.F.R. § 11.35(b) 

since the documents contain confidential commercial and proprietary information that UAVS 

does not intend to share with others. The information contained in this document is not 

generally available to the public and is protected from release under the Freedom of 

Information Act, 5 U.S.C. § 552 et seq.

Petitioner Background and Description of Proposed Operations

UAVS was formed in 2006 to research, design and manufacture unmanned systems. The 

Maryland-based company is ISO 9001:2008 certified for the design, manufacture, and sale of 

UAS. As described in the following paragraphs, an approved exemption would permit 

operations of the UAV Solutions Cougar UAS under controlled conditions in limited airspace 

with the approval of cooperating property owners. These operations would provide improved 

safety over the existing means of obtaining the same data with larger manned systems.
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This petition is intended to allow UAV Solutions to conduct the following commercial UAS 

operations:

- Aerial photography/video for public/private use including land surveys, architecture,

real estate, engineering, and other related professional activities.

- Aerial video/photography for public/private use including television, public events, 

cinematography and news gathering.

- Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority.

- Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers.

- Aerial video/photography to assist with search and rescue operations in cases of an 

emergency or natural disaster when requested by local authorities or government

organizations.

- Training public/private individuals that have interests in the use and application of UAS 

to support safe operations that enhance the safety of the National Airspace System 

(NAS) as well as for the protection of persons and property.

In accordance with 14 C.F.R. § 11.81(a), UAV Solutions provides the following information in 

support of its Petition for Exemption. 

The name and contact information for the applicant is:

Name: UAV Solutions, Inc.

Attn: William Davidson

Phone: 240-456-0195

Address: 8280 Patuxent Range Road, Suite E

Jessup MD 20794

Regulations from Which Exemption Is Requested

91.7 (a) – Civil Aircraft Airworthiness

91.9 (c), 45.23(b), and 45.27 (a) – Aircraft Marking and Identification Requirements

61.101 (e) and 61.113 – Private and Recreational Pilot Privileges and Limitations

91.9 (b) (2) – Civil Aircraft Flight Manual in the Aircraft

91.203 (a) and (b) – Certifications required for Civil aircraft

91.103 – Preflight Action

91.109 (a) – Flight Instruction

91.119 (b) and (c) – Minimum Safe Altitudes 

91.121 – Altimeter Settings 

91.151 (a) – Fuel Requirements for Flight in VFR Conditions

91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), 91.417 (a) & (b) – Maintenance 

Inspections

The UAVS system requested in this exemption is the Cougar UAS (see attached Operations and 

Maintenance manual for more detailed specifications and procedures). The Cougar Air Vehicle

weighs 14 pounds fully loaded – considerably less than the 55-pound requirement that defines 
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small UAS. UAVS will operate the Cougar UAS within Visual Line of Sight (VLOS) of the Pilot and

Visual Observer. The UAS will operate at speeds less than 87 knots. Operations will be 

conducted over private property with owner permission or public property with permission 

from the appropriate officials. UAVS operations will not create a hazard to users of the national 

airspace system or the public.

Utilization of the Cougar UAS is of public interest and safety. The Cougar UAS is less intrusive 

than manned aircraft and helicopters and has less of an impact on the environment. The 

Cougar UAS is battery powered and energy friendly. The system is launched from the operation 

area which minimizes transit times and thereby the possibility of encounters with manned 

aircraft.

UAVS’ proposed operations in this Petition for Exemption qualify for expedited approval 

pursuant to Section 333 of the Reform Act, as each of the statutory criteria and relevant factors 

are satisfied. Approval is Warranted Based on the UAS’s Size, Weight, Speed, and Operational 

Capability. The FAA has already determined that similar systems chosen meet the requirements 

of Section 333 of the Reform Act. 

Description of Proposed Systems

The Cougar is a battery operated, hand or rail-launched, fixed wing UAS with an airframe 

weight of 14 pounds (including battery and payload). The Air Vehicle measures approximately 5

feet long, has a wingspan of approximately 9 feet, a cruise speed of 45 knots, operates on 900 

MHz for command and control, and either 2.4 or 5.8 GHz for datalink, and has a flight time of 

approximately 60 minutes. 

The Cougar operates safely after experiencing certain in-flight contingencies or failures and 

utilizes an auto-pilot system for stability and control. The UAS is also able to respond to a loss of 

GPS or a lost-link event with a pre-coordinated, predictable, automated maneuver. These 

safety features provide an equivalent level of safety compared to a manned aircraft performing 

a similar operation and mitigate the risk of command and control contingencies.

Previously Issued FAA Exemptions for Similar Operations

The FAA has previously issued grants of exemption in circumstances substantially similar to 

those presented in this Petition for Exemption, including, but not limited to:

- Exemption No. 13743 (Docket No. FAA–2015–3796) to UAV Solutions, Inc. to operate 

the Talon 120LE to conduct aerial data collection.

- Exemption No. 12646A (Docket No. FAA–2015–1602) to Measure, a 32 Advisors 

Company, LLC, to operate numerous UAS to perform aerial data collection.

Approval Is Warranted Based On the Operational Restrictions in UAVS’ Operating Documents 

UAVS’ operating documents contain the necessary procedures and limitations required to 

safely perform the proposed operations. To assist the FAA in making a safety assessment of 
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UAVS' proposed operations, the following summary is provided which includes the limitations 

and conditions that UAVS will adhere to, and which will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines by manned aircraft:

1. Operations authorized by grant of this exemption are limited to the UAVS Cougar UAS 

which weighs less than 55 pounds including payload. Proposed operation of additional

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not

permitted.

3. All flights will be conducted within VLOS of the Pilot and Visual Observer in day Visual 

Meteorological Conditions (VMC). This requires the PIC to use vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate or U.S. driver’s license.

4. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles. Flights under 

special visual flight rules (SVFR) are not authorized. 

5. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter 

of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

6. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

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

reserve power recommended by the manufacturer if greater. 

7. The PIC may not operate the UAS from any moving device or vehicle.

8. Flights will be operated at or below 400 feet AGL.

9. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

10. The UA must remain well clear and give way to manned aviation operations at all times.

11. The speed of the UAS will not exceed 87 KTS (100 MPH). In no case will the Air Vehicle 

be operated at airspeeds greater than the maximum airspeed recommended in the 

Operations Manual.

12. The operating documents and this exemption must be accessible to the PIC during UAS 

operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures 

outlined in the operating documents, the conditions and limitations herein take 

precedence and must be followed. The operator may update or revise its operating 

documents. It is the operator’s responsibility to track such revisions and present 
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updated and revised documents to the Administrator or any law enforcement official 

upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA 

granted this exemption, then the operator must petition for an amendment to its grant 

of exemption. 

13. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation and must follow the UAS manufacturer’s maintenance, 

overhaul, replacement, inspection, and life limit requirements for the UAS. Each UAS 

operated under this exemption must comply with all manufacturer safety bulletins.

14. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be safe for flight.

15. Minimum crew for each operation is a Pilot and Visual Observer (VO). The Air Vehicle 

must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. 

The VO may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC must be able to communicate verbally at all 

times. Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties required 

of the VO

16. Any PIC operating under this exemption must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. 

17. The PIC operating under this exemption must hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government.

18. The operator may not permit any PIC to operate UAS unless the PIC demonstrates the 

ability to safely operate the system in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification, flight hours, and 

currency must be logged in a manner consistent with 14 CFR § 61.51(b).

19. Flights will only occur over private property with owner approval or public property 

with permission from the appropriate officials (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).

20. Flight operations will not occur within 500 feet of personnel in the designated area that 

are not part of the specific operation.
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21. PIC will brief all involved personnel on flight operations and applicable safety 

procedures prior to flight operations. A single brief will suffice for multiple flights unless 

there are personnel or operational changes.

22. All operations shall be conducted in accordance with the issued Certificate of Waiver or 

Authorization (COA). 

23. Pilot and Visual Observer will have been trained in UAS operations as described in the 

UAVS UAS Operations manual. 

24. In case of “loss of communication/link” or “loss of GPS”, the proposed UAS will have 

the capability to return to a pre-determined point within the prescribed area of 

operations and land.

25. All Air Vehicles operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification markings 

in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

14 CFR 91.7(a) - Civil Aircraft Airworthiness 

Since there will be no airworthiness certificate issued for the UAS, Petitioner seeks an 

exemption from 14 CFR § 91.7(a), which requires that “no person may operate a civil aircraft 

unless it is in an airworthy condition.” The FAA has previously determined that for the purposes 

of this exemption, the pilot may determine the aircraft is in an airworthy condition prior to 

flight. The operating documents contain procedures which direct the PIC to determine whether 

the aircraft is in a condition safe for flight, and an exemption from § 91.7(a) is therefore 

warranted

14 CFR 91.9(c) and 45.23(b) - Aircraft Marking and Identification Requirements 

91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: 

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

accordance with Part 45 of this chapter. 

45.23(b), Markings of the Aircraft, states: 

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

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

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," 

or "provisional," as applicable.

In a prior grant of exemption under Section 333 of the Reform Act, the FAA determined that 

exemption from these requirements was warranted provided that the aircraft have 

identification markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as 

large as practicable. All Air Vehicles flown by Petitioner will bear N-number markings that are as 

large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 
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14 CFR § 61.101 (e) and 61.113 - Recreational and Private Pilot Privileges and Limitations

Sections 61.101 (e) and 61.113 limit Recreational and Private pilots to non-commercial 

operations.

The FAA recently determined that holders of recreational and sport pilot certificates would 

have adequate aeronautical knowledge to pilot a UAS. Accordingly, because these individuals 

would also be subject to security screening by the Department of Homeland Security (DHS), the 

FAA determined that holders of recreational and sport pilot certificates would be qualified to 

serve as the PIC for UAS operations (see Exemption 11213, Docket No. FAA-2014-0642). 

Petitioner will operate on private property away from persons and property not involved in the 

operation and will require all PICs to be thoroughly trained in the unique aspects of UAS flight. 

As set forth in the operating documents, pilots will have experience not only in UAS operations 

generally but have logged flight time in the specific make and model used for the operations 

before they are permitted to participate in commercial flights on behalf of the Petitioner. The 

pilot qualification, training, and currency requirements in the operating documents ensure that 

Petitioner’s pilots are competent and proficient in the UAS they are operating. The Petitioner's 

training and qualification requirements are consistent with those contained in prior FAA issued 

grants of exemption, and will provide a high level of competency and proficiency for its pilots 

and will ensure at least an equivalent level of safety.

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

Section 91.9 (b) (2) provides that no person may operate a U.S.-registered civil aircraft 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.

Given the size of the proposed UAS Air Vehicle and the general nature of UAS operations, the 

Operations and Maintenance Manual for flights conducted under this exemption will be located 

in proximity to the PIC and Visual Observer. An equivalent level of safety is provided by keeping 

the manual on the ground for immediate access by the crew. 

14 C.F.R. § 91.103 - Preflight action

This regulation requires each pilot in command to take certain actions before flight to ensure 

the safety of flight.

Petitioner requests an exemption from 14 C.F.R. § 91.103 since an FAA approved flight manual 

will not be provided for the aircraft. The preflight procedures in the Operating Documents will 

ensure that the UAS is in an airworthy condition prior to flight and thereby provide an 

equivalent level of safety. The PIC will take all actions prior to initiating flight including 

reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft 

performance data.
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The PIC will complete a series of checklists designed to identify any defects or inoperable 

components, which cover pre-flight, take-off, landing and post-flight procedures. Petitioner's 

Operating Documents will be kept at the ground control station and will be accessible to the PIC 

at all times while operating the UAS. 

14 C.F.R. §91.109: Flight instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls.

Like other unmanned systems, the Cougar UAS does not have fully functional dual controls so 

an exemption from this rule is requested. Flight control is accomplished through the use of a 

ground control station that communicates with the aircraft via radio communications. The FAA 

has approved exemptions for flight training without fully functional dual controls and for flight 

instruction in experimental aircraft. An equivalent level of safety will be provided since neither 

a pilot nor passengers will be carried in the aircraft and by the limited aircraft size, speed, and 

operational area.

14 C.F.R. §91.119 - Minimum safe altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of § 91.119, 

which state: 

Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: 

(b) Over congested areas. Over any congested area of a city, town, or settlement, 

or over any open air assembly of persons, an altitude of 1,000 feet above the 

highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

As this exemption is for a small UAS and seeks authority to operate at altitudes up to 400 AGL,

the Petitioner requests an exemption to allow such operations. As set forth herein, the 

proposed UAS will not operate above 400 AGL. An equivalent level of safety will be achieved 

given the size, weight, and speed of the UAS as well as the location where operations occur. No 

flight will be taken without the permission of the property owner or appropriate official. 

Because of the advance notice to the property owner and participants, all affected individuals 

will be aware of the planned flight operations as set forth in the Petitioner’s Operating 

Documents. 
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The proposed UAS Air Vehicle weighs 14 pounds fully loaded and carries no pilot or passengers, 

explosive material or flammable liquid fuels. Compared to flight operations with manned 

aircraft or rotorcraft weighing far more, the risk associated with the proposed operations is far 

less than those presented by conventional aircraft operating at or below 500 AGL performing 

similar operations. Additionally, the proposed low-altitude operations of the small UAS will 

ensure separation from manned aircraft that must comply with Section 91.119. 

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

This regulation requires that each person operating an aircraft shall maintain the cruising 

altitude by reference to an altimeter that is set when operating below 18,000 MSL to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure (for the case of an aircraft not equipped with a radio).

The FAA has stated previously that an equivalent level of safety to the requirements of 14 C.F.R. 

§ 91.121 can be achieved in circumstances where: (1) the UAS will be operated below 400 feet 

AGL or below, (2) within VLOS, (3) where GPS based altitude information is relayed in real time 

to the operator at a ground-based on-screen display and, (4) where prior to each flight, a zero 

altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS (see 

Exemption No. 11062 , Docket No. FAA-2014-0352).

 

The UAS that the Petitioner intends to use for the proposed operations meets all these 

operational characteristics. Additionally, the operating document requires the PIC to calibrate 

the aircraft's GPS prior to each flight. As the FAA has determined in circumstances similar to 

this Petition, Petitioner's UAS and the safety mitigation procedures contained in the operating 

documents ensure that an equivalent level of safety will be achieved, and a grant of exemption 

to the requirements of § 191.121 is therefore appropriate.

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

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

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

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, 

to fly after that for at least minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery of the proposed UAS provides approximately 60 minutes of flight time. To meet the 

30-minute reserve requirement of 91.151 would severely limit flight operations, therefore an 

exemption from this rule is requested. Due to the proposed altitude limitations and the area of 

operations, reduced reserve requirements for flight in daylight VFR operations is reasonable. 

The FAA has approved similar exemptions from the fuel requirements of § 91.151(a) for flight in 

day VFR conditions. The FAA determined that a requirement prohibiting the PIC from beginning 

a UAS flight unless (considering wind and forecast weather conditions) there was enough 

available power for UAS to operate for the intended operational time and to operate after that 

for at least five minutes or with the reserve power recommended by the manufacturer if 

greater, would ensure an equivalent level of safety to the fuel requirements of § 91.151(a) (see 
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Exemption No. 11213). Petitioner's operating documents impose this same requirement and an 

exemption from §91.151(a) for flight in VFR conditions is therefore appropriate.

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

The regulation provides in pertinent part:

(a) 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...

(b) 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 Cougar Air Vehicle weighs 14 pounds fully loaded and carries no passengers, explosive 

material, or flammable liquid fuels therefore no display of airworthiness or onboard documents 

is required. The FAA has issued numerous exemptions to this regulation that include but not 

limited to Exemptions 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) and (2); 417(a) & (b) - Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected 

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

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Petitioner is requesting an exemption to the Maintenance Inspection requirements contained 

in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b). These regulations 

apply only to aircraft with an airworthiness which the UAS in this petition will not have. 

Maintenance and inspections will be accomplished by the operator pursuant to the Operating 

Documents. An equivalent level of safety is provided because the UAS is limited in size, weight, 

payload capacity, and will be flown in limited areas for short periods of time. If mechanical 

issues arise, the proposed UAS Air Vehicle can be landed immediately and will be operating 

from no higher than 400 feet AGL. 

As provided in the Operating Documents, the PIC will ensure that the UAS is in working order 

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

performed. A functional test flight will be conducted and logged following the replacement of 

any flight-critical components. The maintenance and inspection procedures required by 

Petitioner's Operating Documents ensure that an equivalent or higher level of safety will be 

achieved.

National Security 

This requested exemption does not present a national security issue. Given that the UAS is 

small and lightweight, has lost-link and contingency capabilities, operates at very low speeds, 
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has extremely small payload capacities and carries no flammable, explosive or otherwise 

dangerous materials, the operations pose no threat to national security. 

Summary for Federal Register

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

Register should it be determined that publication is required:

Applicant seeks an exemption from the following rules: 

14 CFR §21, subpart H; 14 CFR 45.23(b);14 CFR § 61.101(e); 61.113(a) & (b); 91.7 (a); 

91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 

91.407 (a) (1); 91.409 (a) (2); and 91.417 (a) & (b) to conduct aerial data collection.

Conclusion

UAVS’ Petition for Exemption satisfies the criteria required in Section 333 of the Reform Act of 

2012, including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed operations in this Petition are 

similar to those in previously issued grants of exemptions, and will benefit the public by 

improving safety and minimizing risk by reducing the public's exposure to the danger and 

emissions associated with using manned aircraft to perform similar aerial data collection 

operations. The Cougar UAS is battery powered and creates no emissions. Additionally, in the 

unlikely event of an accident, there would be no fuel to ignite or explode – thereby presenting

significantly less danger to the pilot and other individuals on the ground than one involving a 

full size aircraft.

In consideration of the foregoing, this Petition for Exemption provides the FAA with the 

necessary justification for granting the requested exemptions to allow UAVS to use the Cougar

UAS to conduct aerial video, photography, inspection, and training. Thank you in advance for 

your prompt consideration of this exemption request. Please contact the undersigned should 

you have any questions, or if additional information is needed. 

Sincerely,

Anthony J. Pucciarella

ALARIS

Agent for UAV Solutions, Inc.

Cc: William Davidson