Page 1

Anthony J. Pucciarella

ALARIS

PO Box 1835 Lusby, MD 20657

240.538.8444 Tony@TeamAlaris.com

2 0 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 C ougar Small

Unma nned Aircraft System ( U AS ) 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 C ougar UAS Operations and
Maintenance Manual (referred to as “Operating D ocuments” in this petition )

. Alaris submits
th is document a s 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 th is 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

U A S

. 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 o f cooperating property owners. These operations would provide improved safety over the existing means of obtaining the same data with larger manned systems.Page 2

This petition is intended to allow UAV Solutions to conduct th e following commercial UAS operations:

- Aerial photography / video for public / private use including land survey s, architecture,
real estate

, engineering

, and other related professional activities.

- Aerial video / photography for public / private use including tele vision, 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 infra structure including but not limited to electrical power lines, wind turbines and cell towers.

- Aerial video/photography t o assist with search and rescue operations in cases of an emergency or natural disaster when requested by local authorities or governmen t organizations.

- T raining public/private individual s that have interests in the use and application of UAS
to support safe operation s that enhance the safety of the National Airspace System (NAS) as well as for the protection of persons and property.

In a ccordance 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 th is exemption i s the Cougar UAS (see attached Operations and

Maintenance manual for more detailed specifications and procedures ) . The Cougar Air Vehicle weigh s 14 pounds fully loaded

– considerably less than the 55

- pound requirement that definesPage 3

s mall UAS. UAV S will operate the Cougar UAS with in Visual Li ne of S ight (VLOS) of the Pilot and
Visual O bserver. The UAS will operate at speeds less than 87 knots. Operations will be
conducted over private property with owner permission or public property with per mission from the appropriate officials

. UAV S 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 helicopter s and ha s less of an impact on the environment. The Cougar UAS is battery powered and energy friendly. The system is launched from the operat ion
area which minimizes transit time s and thereby the possibility of encounters with man ned
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, ha nd 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 4 5 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 6 0 minutes

.

The Cougar operate s safely after experiencing certain in

- flight contingencies or failures and

u tilizes an auto

- pilot system for stability and control. The UAS is also a ble 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 I ssued FAA E xemptions 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. 1 2646A (Docket No. FAA

– 2015

– 160 2) to Measure, a 32 Advisors Company, LLC, to operate numerous UAS to perform aerial data collection.

Approval I s Warranted Based O n the Operational Restrictions in UAVS ’ Operating Documents

UAVS’ operating documents contain the necessary procedures and limitations required to safely pe rform the proposed operations. To assist the FAA in making a safety assessment ofPage 4

UAVS ' proposed operations, the following summary is provided which includes the limitations
and conditions that UAVS will adhere to, and which will ensure an equ ivalent 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. Prop osed 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 Pil ot 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 m iles 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 reque st.

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

reser ve 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 Oper ations 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 pro cedures 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 presentPage 5

upda ted 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

i n 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. Prio r 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 ne cessary 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 requir ement 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

mus t 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 Distric t of Col u mbia, 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 p rivate 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 ot her 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.Page 6

21. PIC will brief all involved personnel on flight operations and applicable safety

proce dures 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 V isual Observer will have been trained in UAS operations as described in the UAVS UAS Operations manual.

24. In case of “ loss o f communication/link” or “ loss of GPS ” , the proposed UAS will have the capability to return to a pre

- determined point within the p rescribed 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 wi ll be no airworthiness certificate issued for the UAS, Petitioner seeks an exemption from 14 CFR § 91.7(a), which requires that “n o person may operate a civil aircraft unless it is in an airworthy condi tion .” T he 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 a ircraft 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)

- Airc raft Marking and Identification Requirements

91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, prov ides 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
exempt ion 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 t hat are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C.Page 7

14 CFR § 61.101 (e) and 61.113

- Recreational and Private Pi lot Privileges and Limitations

Sections 61.101 (e) and 61.113 limit Recreational and P rivate pilots to non

- com mercial 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 pr ivate 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 operat ions 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 t he 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 wi ll 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 n o person may operate a U.S.

- registered civil aircraft f or 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, marking s, 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 e nsure 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 p reflight 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, fl ight batter y requirements , landing and takeoff distances, and aircraft performance data

.Page 8

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 proc edures

. Petitioner's

O perating D ocuments 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 91.10 9 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, t he Cougar UAS does not have fully funct ional 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 wi thout 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

oper ational area

.

14 C.F.R. §91.119

- Minimum safe altitudes

Petitioner requests an exemption from the minimum safe al titude 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 1,00 0 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 for th 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 pr operty 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

.Page 9

The proposed UAS Air Vehicle weigh s 14 pounds fully loaded and carr ies 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 c onventional aircraft operating at or below 500 AGL performing
similar operations

. Ad dition ally , the proposed low

- altitude operations of the s mall 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 t he

e levation of the departure airport or an appropriate altimeter sett ing 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.
§ 9 1.121 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 pri or to each flight, a zero altitude initiation point is established for the PIC to conf irm 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 meet s all these operational characteristics. Additionally, the operating document require s the PIC to calibrate the aircraft's GPS prior to each flight. As the FAA has determined in circums tances similar to
this Petition , Petitioner's UAS and the safety mitig ation 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 V FR 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, assumin g 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 provide s approximately 6 0 minutes of flight time

. To m eet the

30

- minute reserve requirement of 91.151 would severely limit flight operations, therefore an exemption from this rule is requ est ed . Due to the proposed altitude limitations and the area of operation s, 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

. T he 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
f or at least five minutes or with the reserve power recommended by the manufacturer if greater, would ensure an equivalent level of safety to the fu el requirements of § 91.151(a) (seePage 10

Exemption No. 11213 ). Petitioner's operating documents impose this same r equirement an d an exemption from §91.151(a) for flight in V FR 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 t his 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 carr ies no passengers, explosive

materia l

, 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 Exemption s 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 betwe en 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 perio ds of time. If mechanical

issues arise

, the proposed UAS Air Vehicle can be land ed 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 i nitiating 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

a ny flight

- critical components. T he maintenance and inspection proce dures r equired by
Petitioner's O perating D ocuments ensure that an equivalent or higher level of safety will be
achieved.

N ational Security

This requested exemption does not present a national security issue . Given that the UAS is small and lightweight, ha s lost

- link and contingency capabilities, operate s at very low speeds,Page 1 1

ha s extremely small payload capacities and carr ies no flammable, explosive or otherwise
dangerous materials, the operations pose n o 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 man ned aircraft to perform similar aerial data collection operations. The Cougar UAS is battery po wered and creates no emissions. Additionally , in the unlikely event of an accident , there would be no fuel to ignite or explode

– thereby presenting significant ly 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 e xemptions 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 additio nal information is needed

.

Sincerely,

Anthony J. Pucciarella

ALARIS Agent for UAV Solutions, Inc.

Cc: William Davidson