UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

In the matter of the petition for exemption of:

Thomas G. Alti

For an exemption seeking relief from the requirements of 

Title 14 of the Code of Federal Regulations

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

Concerning commercial operation of 

DJI FLAME WHEEL F450

DJI F550 HEX

DROIDWORX AD8-HL

Unmanned Aerial System

Pursuant to Section 333 of

The FAA Modernization and Reform Act of 2012

(Public Law 112-95)

Submitted on December 17, 2015

Thomas G. Alti

295 Urbandale Avenue

Benton Harbor, MI 49022

269-926-7581

tgarecording@sbcglobal.net
2

TABLE OF CONTENTS

Page 

Glossary of abbreviations..................................................................................................3 

Summary...............................................................................................................................4 

Introduction and interests of petitioner...........................................................................4 

Background..........................................................................................................................5

Basis for petition..................................................................................................................6

Name and address of petitioner.........................................................................................9

The specific sections of 14 C.F.R. from which Thomas G. Alti seeks exemption................9

The extent of relief Thomas G. Alti seeks and the reason Thomas G. Alti seeks relief.....13

The reasons why granting Thomas G. Alti’s request would be in the public interest........16

The reasons why granting the exemption would not adversely affect safety.......................20

Summary that can be published in the Federal Register.............................................33

Any additional information, views, or arguments available to support Thomas G. Alti’s 

request..................................................................................................................................34 

Conclusion..........................................................................................................................34

Appendices.............................................................................................36
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Thomas G. Alti seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Thomas G. Alti to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of residential and commercial real 

estate, weddings, precision agriculture with on board sensors, wildlife and forestry

monitoring, aerial surveying of construction sites, search and rescue operations under the 

authority and support of local authority officials, aerial video and photography for public 

and private use including television, public events and cinematography, live feed and live 

newsgathering, training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events including high schools, colleges, professional 

sports, open air events and fairs, motion picture production and closed-set filming, disaster 

and catastrophic events and landscapes over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Thomas G. Alti provides his clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. Thomas 

G. Alti also provides his clients with the highest quality digital content for use in their 

commercial, personal, and non-profit multimedia projects. Thomas G. Alti has 45 years of 

professional experience in video production. Thomas G. Alti has over 4 years of 
5

recreational/hobby experience in video and photography with Unmanned Aerial Systems. 

The objective of Thomas G. Alti’s aerial video and photography operations is to provide 

high quality imaging for a variety of commercial, public, private, and residential uses, 

specifically targeting

 Commercial building and facility documentation

 Motion Picture Filming and Commercial Cinematography

 Real Estate Videography and Photography

 Wedding Videography and Photography

 Landscape Videography and Photography

 Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft Systems

Thomas G. Alti seeks an exemption to operate the DJI Flame Wheel F450, DJI

F550 Hex and Droidworx AD8-HL, from here on referred to as the UASs, for 

compensation or hire within the NAS. The DJI Flame Wheel F450 has a take-off weight of 

1730 grams, a diagonal width of 28 inches, and height of 10 inches. The F550 Hex has a 

take-off weight of 2254 grams, a diagonal width of 32 inches, and height of 12.5 inches. 

The Droidworx AD8-HL has a take-off weight of 5302 grams, a diagonal width of 45 

inches and height of 18 inches. Maximum speed of these UASs is approximately 35 mph 

according to the best documentation available. These kinds of speeds have no value when 

doing aerial video or photography. All the flights Thomas G. Alti has done are at a very

slow methodical pace for smooth drifting motion video. The DJI Flame Wheel F450 is
6

equipped with four rotors, the F550 Hex is equipped with 6 rotors and the Droidworx 

AD8-HL is equipped with 8 rotors. These UASs are driven by Lithium Polymer battery

powered electric motors.

The UASs that will be operated by Thomas G. Alti will be registered in accordance 

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. 

BASIS FOR PETITION

Petitioner, Thomas G. Alti, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the UASs in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Thomas G. Alti’s operation of the UASs

meet the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Thomas G. Alti requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 
7

Thomas G. Alti submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Thomas G. Alti will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and their respective Instruction Manuals). Furthermore, Thomas G. Alti

will document and maintain all maintenance records for the UASs.

Thomas G. Alti seeks relief from Section 61.113(a) and (b) entitled Private pilot 

privileges and limitations: Pilot in command, is requested to the extent necessary to allow 

a PIC holding a private pilot or higher level certificate, as well as a current and valid 

airman medical certificate, and who has met certain flight-hour and currency requirements, 

to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for compensation

or hire. As set forth more fully below, Thomas G. Alti submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the UASs unless that 

PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate the UASs in a manner consistent with the operations specifications 

as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures. Further, 

Thomas G. Alti submits that all flights of the UASs, conducted by the PIC pursuant to the 
8

grant of this Petition: (1) will be incidental to the business; and (2) will not carry

passengers or property for compensation or hire. 

Thomas G. Alti seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the UASs do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Thomas G. Alti submits that he will ensure 

that the UASs are in an airworthy condition, prior to every flight, by determining that the 

UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, 

and UASs Instruction Manuals), and that the aircraft are in a condition for safe flight. 

Thomas G. Alti also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the UASs will not have a typical barometric altimeter 

onboard. However, altitude information of the UASs will be provided to the PIC via 

Global Positioning System (GPS) equipment and radio communications telemetry data 

link, which downlinks from the UASs to the GCS for active monitoring of the flight path. 

The DJI F450 UAS does not transmit telemetry data, but has a maximum altitude setting in 

the software that restricts flight above a chosen altitude. This altitude information, 

combined with Thomas G. Alti’s operation of the UASs within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Thomas G. Alti seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Thomas G. Alti submits 

that safety will not be affected by operation of the UASs during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR). Battery power has been 

documented and varies depending upon which of the UASs is being flown and the ambient 
9

temperature during flight. No flights are started with less than 5 minutes of flight time 

available.

In accordance with 14 C.F.R. § 11.81, Thomas G. Alti provides the following 

information in support of his petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Thomas G. Alti

295 Urbandale Avenue

Benton Harbor, MI 49022

269-926-7581

tgarecording@sbcglobal.net

B. The Specific Sections Of 14 C.F.R. From Which Thomas G. Alti Seeks Exemption. 

1. Thomas G. Alti Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Thomas G. Alti Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 
10

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Thomas G. Alti Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Thomas G. Alti Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft 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, to 

fly after that for at least 20 minutes. 

5. Thomas G. Alti Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—
11

(a) 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[.] 

6. Thomas G. Alti Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. Thomas G. Alti Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Thomas G. Alti Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 
12

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 
13

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Thomas G. Alti Seeks And The Reason Thomas G. Alti Seeks 

The Relief. 

1. Extent Of Relief Thomas G. Alti Seeks And The Reason Thomas G. Alti

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

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

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Thomas G. Alti submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the UASs unless that 

PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate the UASs in a manner consistent with the operations specifications 

as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures.
14

Further, Thomas G. Alti submits that all flights of the UASs, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Thomas G. Alti’s business; 

and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Thomas G. Alti Seeks And The Reason Thomas G. Alti

Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Thomas G. Alti to determine that the UASs are in airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the Thomas G. Alti Aerial Operations Manual, Monthly

Maintenance Log, and UASs Instruction Manual). 

Thomas G. Alti seeks the requested relief because the UASs do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

Thomas G. Alti will ensure that the UASs are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and UASs

Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Thomas G. Alti Seeks And The Reason Thomas G. Alti

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the UASs, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information from the 

UASs to the PIC at the ground control station (GCS). Since the FAA requires that any

altitude information concerning UAS operations be reported to air traffic control (ATC) in 

feet above ground level (AGL), Thomas G. Alti seeks the requested relief because the 
15

UASs altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the UASs are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UASs

on the heads-up display of the GCS. 

4. Extent Of Relief Thomas G. Alti Seeks And The Reason Thomas G. Alti

Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered UASs

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration based on documented battery life for each UAS. Thomas G. Alti

seeks the requested relief because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered DJI Phantom 2 Vision Plus UA will severely 

constrain the practicality of any aerial video or still photo flight operations that Thomas G. 

Alti proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2

Vision Plus operating documents, and Thomas G. Alti’s proposed operating limitations, 

ensure that Thomas G. Alti will safely operate the battery powered DJI Phantom 2 Vision 

Plus UAs during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR). Battery power has been documented and varies depending upon which 
16

of the UASs is being flown and the ambient temperature during flight. No flights are 

started with less than 5 minutes of flight time available.

5. Extent Of Relief Thomas G. Alti Seeks And The Reason Thomas G. Alti

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Thomas G. Alti requests relief from 

these Sections because the UASs do not require airworthiness certificates. As set forth 

more fully below, the UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Thomas G. Alti will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

using the methods, techniques, and practices prescribed in the UAS operating documents 

(i.e., the Thomas G. Alti Aerial Operations Manual, Monthly Maintenance Log, and UASs

Instruction Manual). Furthermore, Thomas G. Alti will document and maintain all

maintenance records for the UASs. 

D. The Reasons Why Granting Thomas G. Alti’s Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Thomas G. 

Alti to safely, efficiently, and economically perform aerial video and photography of aerial 

video and photography of residential and commercial real estate, weddings, precision 

agriculture with on board sensors, wildlife and forestry monitoring, aerial surveying of 

construction sites, search and rescue operations under the authority and support of local 

authority officials, aerial video and photography for public and private use including 

television, public events and cinematography, live feed and live newsgathering, training to 

persons individually or belonging to both private and public organizations to increase 
17

awareness and improve safety for current and future UAS operations within the NAS, 

special events including high schools, colleges, professional sports, open air events and 

fairs, motion picture production and closed-set filming, disaster and catastrophic events 

and landscapes over certain areas of the United States.

Additionally, use of the UASs will decrease congestion of the NAS, reduce 

pollution, decrease fossil fuel usage, and provide significant benefits to the economy. 

Notably, the benefits of Thomas G. Alti’s proposed operation of the UASs will be realized 

without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The UASs are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of UASs would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, decreased fossil fuel usage, as well as increase the 

safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

UASs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in fewer aircraft that must 

be handled by air traffic control during the ground, takeoff, departure, arrival, and landing 

phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The UASs. 
18

Conducting aerial acquisitions with the UASs, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, the UASs produce no air pollution, and is the most 

viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The UASs, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, 

as the UASs are propelled by battery powered electric motors, rather than an internal 

combustion engine. 

By using the UASs to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside 

from the lack of flight crew members located onboard the aircraft, the UASs (weighing 

less than 12 pounds at the maximum gross weight, with diagonal widths of 45 inches or 

less, and with no fuel on board), has less physical potential for collateral damage to life 

and property on the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The UASs Will 

Benefit The Economy. 

In addition to being safe and efficient, the UASs are also an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of the 

UASs will allow United States based people, like Thomas G. Alti, to remain competitive 
19

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation 

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered UASs is one 

such technology that not only allows greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft. 

By operating the UASs, people such as Thomas G. Alti, can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors, 

which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the UASs, provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Thomas G. Alti’s proposed operation of the UASs will not implicate any privacy

issues. Specifically, the UASs will be operated only in compliance with operating 

documents (i.e., the Thomas G. Alti Aerial Operations Manual, Monthly Maintenance Log, 

and UASs Instruction Manuals) which requires property owner involvement as well as 

local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 
20

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Thomas G. Alti Seeks Exemption. 

1. Reasons Why The UASs Meet The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Thomas G. Alti’s operation of the UASs

meet the conditions of FMRA Section 333, and will not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 
21

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Thomas G. Alti submits that the UASs can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the UASs; (b) the pilot certification requirement; and (c) the specific 

operating limitations. 

a. The Specifications Of The UASs Demonstrate Its Safe Characteristics.

The UASs do not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The UASs. 

The technical specifications of the UASs are set forth by the Specifications and 

Data Sheet, attached hereto as Exhibit A, on page 23 of exhibit B and page 2 of exhibit G. 

ii. The UASs Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined Operational Area. 

The UASs may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the UASs is provided at pages 

10 – 15 of Exhibit B, Mission Planning section of Exhibit D, and pages 2 – 5 of Exhibit H.

iii. The UASs Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the UASs will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the UASs do not reacquire control link data from the 

GCS, the UASs will assume that the Control Link is lost and the UAS will return to the 

home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown. 
22

A complete description of the Failsafe Functions of the UASs at pages 16 through 

17 of the NAZA-M quick start guide v1.26, attached hereto as Exhibit B, in the Radio 

Failsafe section at http://copter.ardupilot.com/wiki/throttle-failsafe/, and in Exhibit J 

MikroKopter Failsafe.

iv. The UASs GCS And Its Operation.

A complete description of the operation and specifications of the DJI UASs GCS 

and flight control software is provided at pages 7 – 9 of the Naza-M Quick Start Guide 

v1.26 attached hereto as Exhibit B, Exhibit D Mission Planner, and Exhibit I MikroKopter 

tool OSD and WayPoints.

b. Flight Operations Of UASs Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Thomas G. Alti will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the UASs. Additionally, a 

safety observer will assist all pilots during flight time. 

c. Flights Of UASs Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, Thomas G. Alti proposes to commercially operate UASs

for the special purpose of conducting aerial video and photography over certain areas of 

United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: DJI F450, DJI F550 and Droidworx 

AD8-HL Unmanned Aircraft Systems. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UA may not be flown at an indicated airspeed exceeding 20 knots.
23

4. The UA must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

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

medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO 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 SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

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

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it 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 in a 

condition for safe flight. The Ground Control Station must be included in the 
24

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

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

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 
25

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

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

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. 

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

the Administrator upon request. 

21. 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 from the 

PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 
26

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Thomas G. Alti submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the UAS’s

unless that PIC has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the UAS’s in a manner consistent with 
27

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Considering Thomas G. Alti’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the UAS’s, Thomas G. Alti submits that 

the additional manned airmanship experience of a commercially certificated pilot would 

not correlate to the airmanship skills necessary for Thomas G. Alti’s specific proposed 

flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Thomas G. Alti will not allow any PIC to operate the UAS’s unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the UAS’s training and 

currency requirements, that the PIC is able to safely operate the UAS’s in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 
28

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Thomas G. Alti’s proposed operations. The Administrator 

has held that prior documented flight experience that was obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Thomas G. Alti will ensure safe operations by not allowing any PIC 

to operate the UAS’s unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the UAS’s in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 
29

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Thomas G. Alti will ensure that the UAS’s are in an 

airworthy condition based upon the UAS’s compliance with its operating documents and 

as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the UAS’s will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UA 

to the GCS for active monitoring of the flight path and altitude. This altitude information, 

combined with Thomas G. Alti’s operation of the UAS’s within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The 

altitude information will be generated by GPS equipment installed onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically established by the UASs 

at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 
30

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the UAS’s; (2) 

the limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, Thomas G. Alti will ensure that it will safely operate the battery 

powered UAS’s during daylight hours in VFR conditions, with enough battery power to 

fly at normal cruising speed to the intended landing point and land the UA with 25% 

battery power remaining.

Here, as in Exemption No. 11109, the technical specifications of the UAS’s; the 

limitations on the proposed flight operations; and the location of the proposed operations, 

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the UAS’s provide audible and visual warnings to 

the PIC at the GCS when the UAS’s experience low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the UAS will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 
31

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Thomas G. Alti submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Thomas G. Alti will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS’s using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the Thomas G. Alti Aerial Operations Manual, 

Monthly Maintenance Log, and UAS’s Instruction Manuals). Furthermore, Thomas G. Alti

will document and maintain all maintenance records for the UAS’s. 

Since the UAS’s will be inspected as prescribed by the operating documents, 

Thomas G. Alti will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the UAS’s User Manuals are attached 

hereto as Exhibit E, F, and G. A copy of the monthly Maintenance LOG is attached hereto 

as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Thomas G. 

Alti will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS’s using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 
32

UAS’s will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Thomas G. Alti’s proposed operating limitations, the operating 

documents, and the technical aspects of the UAS‘s, Thomas G. Alti submits that safety will 

not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously

granted relief specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Thomas G. Alti requests that 

the FAA prescribe special conditions for the intended operation of the UAS’s, which 

contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the 

UAS’s for the limited purpose of conducting aerial video and photography over certain 
33

areas of the United States for compensation or hire. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the UAS’s, since the airworthiness regulations of 14 C.F.R. Part 

21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Thomas G Alti’s intended operation of the UAS’s, 

which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Thomas G. Alti Seeks Exemption: 
34

Thomas G. Alti seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Thomas G. Alti Seeks: 

This exemption will permit Thomas G. Alti to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography 

over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Thomas 

G. Alti’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Thomas G. Alti’s request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as 

set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Thomas G. Alti will operate the UAS’s safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 

CONCLUSION

As set forth herein, Thomas G. Alti seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the UAS’s commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over certain 
35

areas of the United States. By granting this Petition, the FAA Administrator will be 

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, 

while also advancing the interests of the public, by allowing Thomas G. Alti to safely, 

efficiently, and economically operate the UAS’s commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Thomas G. Alti respectfully requests 

that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Thomas G. Alti to operate the 

UAS’s commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Dated: December 21, 2015

Respectfully submitted,

Thomas G. Alti

_________________________

Thomas G. Alti

295 Urbandale Avenue

Benton Harbor, MI 49022

269-926-7581

tgarecording@sbcglobal.net
36

Appendices:

A – UAS’s Specification Sheet

B – DJI NAZA-M quick start guide v1.26

C – Monthly Maintenance Log

D – Mission Planner

E – DJI F450 User Manual

F – DJI F550 User Manual

G – AD8-HL User Manual

H – MikroKopter Tool Manual

I -- MikroKopter Tool OSD & Waypoints

J -- MikroKopter Failsafe