May 12,	2015	

U.S.	Department	of Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	SE	

Washington,	DC	20590	

Dear	Sir	or	Madam:	

Attached	please	find	Alaska	Channel's	request	for	an	exemption	from	the	listed

Federal	Aviation	Regulations to	allow	commercial	operation	of	its	Small	Unmanned	

Aircraft	Systems	("sUASs")	for	aerial	cinematography,	real	estate	photography, and	

monitoring	of	secured	and	controlled	environments	with	respect	to	construction	

sites,	transmission	towers,	other	similar industrial	elevated	structures.	This	

exemption	request	is	exclusively	for	the	use of	the	DJI	S800	EVO	(reserved	NNumber	N4949)	to	be	used	by	Alaska	Channel.	

In	addition	to	having	years	of	experience	flying	sUASs,	I	hold	a	private	pilot	

certificate	and	a	current	medical.	I	have	over	600	hours	of	flight	time	as	a	private	

pilot,	and	take	recurrent	instruction.	I	have	also	received	instruction	in	a	manned	

helicopter.	As	a	result,	I	understand	the	responsibilities	undertaken	when	operating	

as	pilot	in	command	of	any	aerial	vehicle	and	will	ensure	that	any	sUAS	operated	by	

Alaska	Channel	will	abide	by	all	necessary	safety	and	regulatory	requirements.		

Please	be	advised	that	this	exemption	request	being	submitted	by	Alaska	Channel is	

extremely	similar	in	nature	to	the	exemption	submitted	to	the	FAA	by	Clayco,	Inc.	

For	purposes	of expediting	the	exemption	process,	Alaska	Channel is	agreeable	to	

abide	by	and	accept	the	Conditions	and	Limitations	stipulated	in	Clayco,	Inc,	

Trudeau,	and	other	recent	approvals.	Grant	of	Exemption	Nos.	11109 &	11138.	

Thank	you	for	your	time	and	consideration,	and	please	let	me	know	if	you	have	any	

questions.	

Sincerely,	

President	&	Founder	Alaska	Channel
May	12,	2015

U.S.	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	SE	

Washington,	DC	20590	

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations	from	14	C.P.R.	45.23(b);	14	CFR	Part21;	14	CFR	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)	&(b);	91.405	(a);	91.407(a)	(1);	91.409	(a)	(2);	91.417	(a)	&	(b).	

Dear	Sir	or	Madam:	

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

Reform	Act)	and	14	C.P.R.	Part	11,	Alaska	Channel ("Alaska	Channel"),	an imagery	

and	inspection	firm,	hereby	applies	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations	("FARs")	to	allow	commercial	operation	of	its	Small	Unmanned	

Aircraft	Systems	("sUASs")	for	aerial	imaging	for	cinematography and	aerial	

inspection and	monitoring	of	secured	and	controlled	environments,	such	as	

construction	sites or	other	elevated	industrial	structures,	so	long	as	such	operations	

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

established	by	the	FAA	as required	by	Section	333.	

As	detailed	in	this	document,	the	requested	exemption	would	permit	the	operation	

of	sUAS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	predetermined	

3)	controlled	as	to	access	and	4)	would	provide	for	safer	videography	and	

inspections	thus	preventing	the	use	of	conventional	aircraft	over	these sites	and	

eliminates	the	need	to	place	personnel	in	harm’s	way	when	attempting	to	access	

sites	or	elevated	structures	without	conventional	access.	Approval	of	this	exemption	

would	thereby	enhance	safety	and	fulfill	the	Secretary	of	Transportation's	(the	FAA	

Administrator's)	responsibilities	to"...establish	requirements	for	the	safe	operation	

of such	aircraft	systems	in	the	national	airspace	system."	Section	333(c)	of	the	

Reform	Act.	

The	name	and	address	of	the	applicant	is:	

Alaska	Channel

c/	Bob	Kaufman

507	E	Street,	Suite	206

Anchorage,	AK	99501

Phone:	907-350-9127
Regulations	from	which	the	exemption	is requested:	14	C.P.R.	Part21	14	

C.F.R.45.23(b)	14C.F.R.	61.113	(a)	&(b)	14	C.P.R.	91.7	(a)	14	C.P.R.	91.9	(b)(2)	14	

C.P.R.	91.103	14	C.P.R.	91.109	14	C.P.R.	91.119	14	C.P.R.	91.121	14	C.P.R.	91.151	(a)	

14	C.P.R.	91.203	(a)	&	(b)	14	C.P.R.	91.405	(a)	14	C.P.R.	407	(a)	(1)	14	C.P.R.	409	

(a)(2)	14	C.P.R.	417	(a)	&	(b)	

I. STATUTORY	AUTHORITY	FOR	EXEMPTIONS	

The	Federal	Aviation	Act	expressly	grants	the	FAA	authority	to	issue	exemptions.	

This	statutory	authority	includes	exempting	civil	aircraft,	as	the	term	is	defined	

under	§40	101	of	the	Act,	including	sUASs,	from	the	requirement	that	all	civil	

aircraft	must	have	a	current	airworthiness	certificate.	

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	

prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	sections	44702-44716	

of	this	title	if	the	Administrator	finds	the	exemption	in	the	public	interest.	49	U.S.C.	

§4470	1(f)	See	also	49	USC	§4471	1(a);	49	USC	§44704;	14	CFR	§91.203(a)	(1).	

Section	333(b)	of	the	Reform	Act	assists	the	Secretary	in	determining whether	

sUASs	may	operate	in	the	National	Airspace	System	(NAS)	without	creating	a	hazard	

to	the	user,	the	public,	or	a	threat	to	national	security.	In	making	this	determination,	

the	Secretary	must	consider:	

• The	sUAS's	size,	weight,	speed,	and	operational	capability;	

• Whether	the	sUAS	operates	within	the	visual	line	of	sight	of	the	operator	

• Whether	the	sUAS	operates	outside	of	highly	populated	areas	and	away	from	

close	proximity	to	airports.

Reform	Act	§333(a).	If the	Secretary	determines	that	a	sUAS	"may	operate	safely	in	

the	national	airspace	system	(NAS),	the	Secretary	shall	establish	requirements	for	

the	safe	operation	of	such	aircraft	in	the	national	airspace	system."	Id.	§333(c).	

Alaska	Channel's	sUASs	are	multirotor	vehicles,	weighting	25	or	fewer	lbs.	including	

payload.	They	operate	under	normal	conditions	at	a	speed	of	no	more	than	40 knots	

and	have	the	capability	to	hover,	and	move	in	the	vertical	and	horizontal	plane	

simultaneously.	The	sUASs	will	operate	only	in	the	pilot's	visual	line	of	sight	at	all	

times	and	will	operate	only	within	sterile	areas.	Such	operations	will	insure	that	the	

sUASs	will	"not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	

public."	Reform	Act	Section	333	(b).	

Given	the	small	size	of	the	sUASs	involved	and	the	restricted	and	sterile	

environment	within	which	they	will	operate,	our	application	falls	squarely	within	

the	zone	of	safety	(an	equivalent	level	of	safety)	in	which	Congress	envisioned	that	

the	FAA	must,	by	exemption, allow	commercial	operations	of	sUASs	to	commence	

immediately.	Also	due	to	the	small	size	of	the	UASs,	the	low	altitudes,	and	restricted	

areas	in	which	our	sUASs	will	operate,	approval	of	the	application	does	not	present	

a	national	security	issue.	
Given the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority	contained	in	

the	Federal	Aviation	Act,	as	amended;	the	strong	equivalent	level	of	safety	

surrounding	the	proposed	operations,	and	the	significant	public	benefit,	including	

enhanced	safety,	the	grant	of	the	requested	exemptions	is	in	the	public	interest.	

Accordingly,	Alaska	Channel respectfully	requests	that	the	FAA	grant	the	requested	

exemption	without	delay.	

II.	PUBLIC	INTEREST	

This	exemption	application	is	expressly	submitted	to	fulfill	Congress'	goal	in	passing	

Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	

Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may	

operate	safely	in	the	NAS	before	completion	of	the	rulemaking	required	under	

Section	332	of	the	Reform	Act.	By	granting	an	exemption	the	FAA	will	fulfill	

Congress's	intent	of	allowing	sUAS	to	operate	utilizing	significant	safety	precautions	

in	low	risk	environments.	

The	use	of	sUASs	to	inspect	and	monitor	elevated	structures	and	towers	can	

significantly	reduce	the	risk	to	workers	of	falls	while	inspecting,	surveying,	or	

monitoring	such	structures.	sUASs	can	inspect,	photograph,	and	collect	data	on	hard	

to	get	to	areas	that	otherwise	would	require	dangerous	worker	inspections.	

Historically,	falls	are	the	1	leading	source	of workplace	fatality	and	injury	on	

construction	sites,	and	reducing	falls	through	sUAS	use	for	site	imaging	could	save	

workers’ lives.	Additionally,	sUASs	could	replace	the	use	of	helicopters	and	small	

aircraft to	monitor	sites.	The	sUASs	we	propose	to	fly	in	this	application	is	under	

twenty-five	(25)	pounds,	and	carries	no	combustible	material	on	board,	as	opposed	

to	the	much	larger	conventionally	powered	small	aircraft.	Shifting	to	sUASs	from	

helicopters	presents	a	marked	safety	increase	for	our	workers	and	the	public.	·	

The	use	of	sUASs	to	acquire	aerial	cinematography	for	use	in	filmmaking	and	real	

estate	visualizations	has	similar	safety	benefits,	as	well	as	educational	benefits.	It	

will	allow	the	general	public	to	gain	a	much	better	understanding	of	the	physical	

layout	as	seen	from	low	altitudes.	It	is	far	safter	to	operate	an	sUAS	in	such	settings	

than	a	manned	helicopter	or	a	fixed	wing	aircraft.	

Lastly,	sUASs	reduce	the	environmental	impact	by	dramatically	decreasing	the	

energy	used	for	aerial	imaging	and	data	collection	over	a	construction	site1.	Our	

sUASs	use	rechargeable	lithium	ion	batteries,	as	opposed	to	fossil	fuels	burned	in	

operation	of	small	aircraft	that	are	many	hundreds	of times	heavier.	

																																																							 1 Commonly	Used	Statistics",	Occupational	Safety	&Health	Administration.	Available	
III.	EQUIVALENT	LEVEL	OF	SAFETY	

Alaska	Channel proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	

that	have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	

These	limitations	provide	for	at	least	an	equivalent,	or	even	higher,	level	of	safety	to	

operations	under	the	current	regulatory	structure	because	the	proposed	operations	

represent	a	safety	enhancement	to	the	already	safe	protocols	followed	on	industrial	

sites	and	imaging	operations	conducted	with	helicopters and	other	conventional	

aircraft.	

Alaska	Channel will	be	bound	by	the	following	limitations	when	conducting	its	sUAS	

operations	under	an	FAA	issued	exemption:	

1. The	sUAS	will	be	less	than	25	pounds.	

2. Flights	will	be	operated	within	visual	line of	sight	of a	pilot.	

3. Maximum	total	flight	time	for	each	operational	flight	will	be	30	minutes.	The	

UAS	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	

the	30	minute	limit.	

4. Flights	will	be	operated	at	an	altitude	never	exceeding	400 feet	AGL.	

5. Flight	Crew	for	each	operation	will	consist	of	the	sUAS	pilot	who	will	keep	

the	sUAS	within	his	visual	line	of	sight	at	all	times,	and	a	Visual	Observer	to	

assist	the	pilot.	

6. The	sUAS	pilot	and	the	Visual	Observer	will	be	trained	in	flight,	operations,	

and	safety	procedures.		

7. The	sUAS	will	only	operate	within	a	confined	"Sterile	Area."	We	will	also	

establish	a	"Security	Perimeter"	for	the	flight	operations	area.	

8. A	briefing	will	be conducted	in	regard	to	the	planned	sUAS	operations	prior	

to	each	day's	flight	activities.	It	will	be	mandatory	that	all	personnel	who	will	

be	performing	duties	within	the	boundaries	of	the	safety	perimeter	be	

present	for	this	briefing.	

9. All	onsite	personnel	will	consent	to	the	UAS	flyover	on	site	by	waiver,	and	the	

pilot	will	obtain	additional	verbal	or	written	consent	of	all	persons	who	will	

be	allowed	within	100	feet	of	the	flight	operation.	

10. Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	

obtained.	

11. 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.	

12. If the	sUAS	loses	communications	or	loses	its	GPS	signal,	it	will	have	

capability	to	return	to	a	pre-determined	location	within	the	Security	

Perimeter	and	land.	

13. The	sUAS	will	have	the	capability	to,	and	the	pilot	will	initiate	a,	flight	abort	

in	case	of	unpredicted	obstacles	or	emergencies.	
IV.	DESCRIPTION	OF	SPECIFIC REGULATIONS	

14 CFR Part	21, Subpart	H:	Airworthiness	Certificates	14C.F.R.	§91.203(a)(l)	

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	

requirements	for	the	issuance	of	airworthiness	certificates	as	required	by	FAR	

§91.203	(a)	(1).	Given	the	size	and	limited	operating	area	associated	with	the	

aircraft	to	be	utilized	by	the	Alaska	Channel,	an	exemption	from	Part	21	Subpart	

H	meets	the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	

Section	333	of	the	Reform	Act.	The	Federal	Aviation	Act	(49	U.S.C.§44701	(f))	

and	Section	333	of	the	Reform	Act	both	authorize	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.	Alaska	Channel's	sUAS	will	be	operated	at	

low	speed	in	a	controlled	environment,	at	least	five	miles	from	an	airport	and	

more	than	three	miles	from	any	city	or	densely	populated	area.	An	analysis	of

these	criteria	demonstrates	that	the	UAS	operated	without	an	airworthiness	

certificate,	in	the	restricted	environment	and	under	the	conditions	proposed	will	

be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	helicopter)	

operating	with	an	airworthiness	certificate	without	the	restrictions	

and	conditions	proposed.	

The	sUAS	to	be	operated	hereunder	is	less	than	25	lbs.	fully	loaded,	carries	

neither	a	pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	

fuels,	and	operates	exclusively	within	a	secured	area.	Like	other	civil	aircraft,	

operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	the	

pilot,	and	under	the	requirements,	and	in	compliance	with,	local	public safety	

requirements,	to	obtain	aerial	imagery.	The	FAA	will	have	advance	notice	of	all	

operations.	

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

connection	with	similar sites,	provide	a	greater	degree	of	safety	to	the	public	and	

property	owners	than	conventional	operations	conducted	with	airworthiness	

certificates	issued	under	14	C.P.R.	Part	21,	Subpart	H.	

Lastly,	application	of	these	same	criteria	demonstrates	that	there	is	no	credible	

threat	to	national	security	posed	by	the	UAS,	due	to	its	size,	speed	of	operation,	

location	of	operation,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	

ability	to	carry	an	external	load	no	greater	than	seven	(7)	lbs.	

14	C.F.R.	45.23(b):	Marking	of	the	Aircraft	

This	regulation	requires	certain	experimental,	provisionally	certificated	aircraft,	

or	light- sport	category	aircraft	to	be	marked	with	letters	between	2	inches	and	6	

inches	high	"limited,"	"restricted,"	"light-sport,"	"experimental,"	or	"provisional,"	

near	each	entrance	to	a	cabin,	cockpit,	or	pilot	station.	
Even	though	the	UAS	will	have	no	airworthiness	certificate,	an	exemption	will	be	

needed	as	the	UAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	

which	the	word	"Experimental"	can	be	placed.	Given	the	size	of	the	sUAS,	twoinch	lettering	will	be	impossible.	The	word	"Experimental"	will	be	placed	on	the	

fuselage	in	compliance	with	§45.29	(f).	

The	equivalent	level	of	safety	will	be	provided	by	having	the	sUAS	marked	on	its	

fuselage	as	required	by	§45.29	(f)	where	the	pilot,	observer	and	others	working	

with	the	sUAS	will	see	the	identification	of	the	UAS	as	"Experimental."	The	FAA	

has	issued	the	following	exemptions	to	this	regulation:	Exemptions	Nos.	10700,	

873	8,	10167	and	10167A.	14	CFR	61.113	(a)	&	(b):	Private	pilot	privileges	and	

limitations:	Pilot	in	command	

Sections	61.113	(a)	&	(b)	limit	private	pilots	to	non-commercial	operations.	

Because	the	UAS	will	not	carry	a	pilot	or	passengers,	the	proposed	operations	

can	achieve	the	equivalent	level	of	safety	of	current	operations	by	requiring	the	

pilot	operating	the	aircraft	to	have	completed	a	UAS	flight	training	course	and	

have	accumulated	at least	twenty-five	(25)	hours	of	total	time	as	a	UAS	pilot,	

with	at	least	ten	(10)	hours	logged	as	a	UAS	pilot	with	similar	UAS	type,	before	

flying	a	UAS	for	Alaska	Channel in	commercial	operations.	Unlike	a	conventional	

aircraft	that	carries	the	pilot	and	passengers,	the	sUAS	is	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. The	risks	

associated	with	the	operation	of	the	sUAS	are	so	diminished	from	the	level	of	

risk	associated	with	commercial	operations	contemplated	by	Part	61	when	

drafted,	that	allowing	operations	of	the	sUAS	as	requested	with	a	pilot	who	has	

met	the	minimum	requirements	exceeds	the	present	level	of	safety	achieved	by	

14	C.P.R.	§61.113	(a)	&	(b).	

14	C.F.R.	91.7	(a):	Civil	aircraft	airworthiness	

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	

airworthy	condition.	As	there	will	be	no	airworthiness	certificate	issued	for	the	

aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	

for	determining	airworthiness.	Given	the	size	of	the	aircraft	and	the	

requirements	for	maintenance	and	use	of	safety	checklists	prior	to	each	flight,	an	

equivalent	level	of	safety	will	be	provided.	

14	CFR	91.9	(b)(2):	Civil	aircraft	flight	manual,	marking,	and	placard	

requirements	

The sUAS,	given	its	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	

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	a	flight	operations	

and	procedures	manual	that	exceeds	currently	exceeds	accepted	means	and	

methods	for	safe	flight	at	the	ground	control	point	where	the	pilot	flying	the	

sUAS	will	have	immediate	access	to	it.	The FAA	has	issued	the	following	

exemptions	to	this	regulation:	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	

9565,	9565B,	10167,	10167A,	10602,32827,	and	10700.	

14	C.F.R.	91.103:	Preflight Action	

This	regulation	requires	each	pilot	in	command	(PIC)	take	certain	actions	before	

flight	to	ensure	the	safety	of flight.	An	exemption	is	needed	from	this	

requirement	as	the	pilot	will	take	separate	preflight	actions,	including	checking	

for	weather	conditions,	checking	flight	battery	requirements,	checking	takeoff	

and	landing	areas,	and	all	other	actions	in	the	Preflight	Checklist. These	actions	

will	provide	an	equivalent	level	of	safety	and	are	prescribed	by	the	Alaska	

Channel sUAS	operations.	

14	C.F.R.	91.109:	Flight	Instruction	

Section	91.103	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.	

By	design,	sUASs	and	remotely	piloted	aircraft	do	not	have	fully	functional	dual	

controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that	

communicates	with	the	aircraft	via	radio	communications.	The	FAA	has	

previously	approved	exemptions	for	aircraft	without	fully	functional	dual	

controls.	See	Exemption	Nos.5778K	&	9862A.	The	equivalent	level	of	safety	

provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	

aircraft,	the	ability	to	control	the	sUAS	via	radio	signals	from	the	controller,	and	

by	the	size	and	speed	of	the	aircraft.	

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

Section	91.119	establishes	safe	altitudes	for	operation	of civil	aircraft.	Section	

91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	

prescribed,	provided	the	person	operating	the	helicopter	complies	with	any	

route	or	altitudes	prescribed	for	helicopters	by	the	FAA.	This	exemption	is	for	a	

multirotor	craft	that	flies	similarly	to	a	helicopter,	with	vertical	take	off	and	

vertical	landing,	which	will	typically	operate	at	altitudes	below	400'	AGL,	so	an	

exemption	may	be	needed	to	allow	such	operations.	The	sUAS	will	never	operate	

at	altitude	higher	than	400	AGL	and	will	be	in	a	restricted	area	with	security	

perimeter,	where	buildings	and	people	will	not	be	exposed	to	operations	

without	their	pre-obtained	consent.	
The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the

UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	

the	permission	of	the	property	owner	or	local	officials.	Because	of	the	advance	

notice	to	the	property	owner	and	any	onsite	personnel,	all	affected	individuals	

will	be	aware of	the	planned	flight	operations.	Compared	to	flight	operations	

with	aircraft	or	rotorcraft	weighting	far	more	than	the	sUAS	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	AGL	in	the	construction	of	filmmaking	industry.	In	

addition,	the	low-altitude	operations	of	the	sUAS	will	ensure	separation	between	

these	small- UAS	operations	and	the	operations	of	conventional	aircraft	that	

must	comply	with	Section	91.119.	

14	C.F.R.	91.121:	Altimeter	Settings	

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	

altitude	by	reference	to	an	altimeter	that	is	set	"...to	the	elevation	of	the	

departure	airport	or	an	appropriate	altimeter	setting	available	before	

departure."	As	the	sUAS	may	not	have	a	barometric	altimeter,	but	instead	a	GPS	

altitude	readout,	an	exemption	may	be	needed.	An	equivalent	level	of	safety	will	

be	achieved	by	the	operator,	pursuant	to	the	pre- flight	requirements	and	

checklists	confirming	the	altitude	of	the	launch	site	before	flight.	

14	CFR	91.151	(a):	Fuel	requirements	for	flight	in	VFR	conditions	

Section	91.151	(a)	outlines	fuel	requirements	for	beginning	a	flight	in	VFR	

conditions.	Our	UAS	is	limited	to	operations	in	sterile	and	controlled	

environments,	and	has	a	limited	range	and	flight	time	which	require	an	

exemption	from	14	CFR	91.151(a).	

The	battery	powering	the	sUAS	provides	no	greater	than	30	minutes	of powered	

flight.	To	meet	the	30-minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	

flights	would	be	limited	to	approximately	0	minutes	in	length.	Given	the	

limitations	on	the	UAS'	s	proposed flight	area	and	the	location	of	its	proposed	

operations	within	a	predetermined	area,	a	longer	time	frame	for	flight	in	

daylight	or	night	VFR	conditions	is	reasonable.	

Alaska	Channel believes	that	an	exemption	from	14	CFR	§91.151	(a)	falls	within	

the	scope	of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	

Corporation	to	operate	without	compliance	with	FAR	91.151	(a)).	Operating	the	

small	UAS,	in	a	tightly	controlled	area	where	only	people	and	property	owners	

or	official	representatives	who	have	signed	waivers	will	be	allowed,	with	less	

than	30	minutes	of	reserve	fuel,	does	not	engender	the	type	of risks	that	Section	

91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.	

Additionally,	limiting	sUAS	flights	to	0	minutes	would	greatly	reduce	the	utility	

for	which	the	exemption	will	be	granted.	
An	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	minutes,	or	

enough	battery	reserve	to	ensure	that	the	sUAS	lands	at	the	ground	station	with	

at	least	20%	of	battery	power	(as	determined	by	the	onboard	monitoring	system	

and	the	pilot),	whichever	happens	first.	This	restriction	would	be	more	than	

adequate	to	return	the	sUAS	to	its	planned	landing	zone	from	anywhere	in	its	

limited	operating	area.	

Similar	exemptions	have	been	granted	to	other	operations,	including	

Exemptions	2689F, 5745,	10673,and	10808.	

14	CFR	91.203	(a)	&	(b):	Carrying	civil	aircraft	certification	and	registration	

The	regulation	provides	in	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	UAS	fully	loaded	weighs	no	more	than	25	lbs.	and	is	operated	without	an	

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

registration	documents	or	to	display	them	on	the	sUAS.	

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	

ground	flight	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	

access	to	them,	to	the	extent	they	are	applicable	to	the	sUAS.	The	FAA	has	issued	

numerous	exemptions	to	this	regulation.	A	representative	sample	of	other	

exceptions	includes	Exemption	Nos.	9565,	9665,9789,	9789A,	9797,	9797A,	

9816A,	and	10700.	

14	CFR	91.405	(a);	407	(a)(l);	409	(a)(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.	

Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	

certificate,	these	sections	will	not	apply	to	Alaska	Channel.	Maintenance	will	be	
accomplished	by	the	operator	pursuant	to	standard	procedures and	

manufacturer	guidance.	An	equivalent	level	of	safety	will	be	achieved	because	

these	small	UASs	are	very	limited	in	size	and	will	carry	a	small	payload	and	

operate	only	in	restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	

arise	the	UAS can	land	immediately	and	will	be	operating	from	no	higher	than	

400	feet	AGL	and	within	visual	line	of	sight	of	the	pilot.	The	pilot	will	ensure	that	

the	UAS	is	in	working	order	prior	to	initiating	flight,	has	the	required	

maintenance,	and	keep	a	log	of	any	maintenance	performed/needed.	Moreover,	

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.	

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

in	the	Federal	Register,	should	it	be	determined	that	publication	is	needed:	

Applicant	seeks	an	exemption	from	the	following	rules:	14	C.F.R.	§21,	subpart	H;	

14	C.F.R	45.23(b);	14	C.F.R.	§§	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);	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate	commercially	a	

small	unmanned	vehicle	(55 lbs	or	less)	in	construction	operations.	

Approval	of	exemptions	allowing	commercial	operations	of	sUASs	in	the	

construction	and	filmmaking	industries enhance	safety	while	reducing	risk.	

Manned	aircraft	creates	a	greater	risk	because	the	craft	are	much	larger,	have	

combustible	fuel,	and	carry	an	onboard	human	pilot.	In	contrast,	a	sUAS	

weighing	fewer	than	25	lbs.	and	powered	by	batteries	eliminates	virtually	all	of	

that	risk	given	the	reduced	mass	and	lack	of	combustible	fuel	carried	on	board.	

The	sUAS	will	carry	no	passengers	or	crew	and,	therefore, will	not	expose	them	

to	the	risks	associated	with	manned	aircraft	flights.	

The	operation	of	small	UASs,	weighting	less	than	25	lbs.,	conducted	in	the	strict	

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	

the	grant	of	the	exemptions	requested	herein,	including	exempting	the	applicant	

from	the	requirements	of	Part	21	and	allowing	commercial	operations.	These	

lightweight	aircraft	operate	at	slow	speeds,	close	to	the	ground,	and	in	a	sterile	

environment	and,	as	a	result,	are far	safer	than	conventional	operations	

conducted	with	turbine	helicopters	operating	in	close	proximity	to	the	ground	

and	people.	

Privacy	

All	flights	will	occur	over	private	or	controlled	access	property	with	the	property	

owner's	prior	consent	and	knowledge.	Images	taken	will	be	of	individuals	who	

have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	

where	aerial	photography	will	take	place.	

*******
Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of 2012--

size,	weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	

areas	and	operation	within	visual	line	of	sight	and	national	security--provide	

more	than	adequate	justification	for	the	grant	of	the	requested	exemptions	

allowing	commercial	operation	of	applicant's	UASs	in	filmmaking,	real	estate	

photography, remote	inspections,	and	similar industries	requiring	aerial	data	

collection.	

Sincerely,

Bob	Kaufman

Alaska	Channel