UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________



### I **n 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 H**  **EX DR** **OIDWORX AD8 -**  **HL Unmanned Aerial System**  **Pursuant to Section 333 of The FAA Modernization and Reform Act of 2012** 

**(P ublic**  **L aw**  **112 -**  **95)**

Submitted on December 17 , 2015 Thomas G. Alti 295 Urbandale Avenue Benton Harbor, MI 49022 269

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- 7581 tgarecording@sbcglobal.net2 **TABLE OF CONTENTS** Page Glossary of abbreviations............... ...................................................................................3 S ummary .... ............................................ ...............................................................................4 Introduction and interests of petitioner....................... ....................................................4 B ackground......

.................................................................................................................... 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 rea son Thomas G. Alti seeks relief..... 1 3 The reasons wh y granting Thomas G. Alti’s request would be in the public interest... .....1 6 The reasons wh y granting the exemption would not adversel y affect safety

....................... 20 Summary that can be publishe d in the Federal Register...........................

... ............ ...3 3 Any additional information, views, or arguments available to support Thomas G. Alti’s request...........................................................................................................
................ . ......34 C onclusion...... ....................................................................................................................3 4 Appendices....

....................................................................................... . .3 63 **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 Regu lation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C 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 Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** T homas 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 Sy stem pursuant to Section 333 of the FAA M odernization and Reform Act of 2012 (FMRA). This exemption will permit Thomas G. Alti to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography of residential and commercial real estate, weddings, pr ecision 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 authorit y officials, aerial video and photography for public and priv ate 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 ope rations 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 landscape s over certain areas of the United Stat es.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** Thomas G. Alti provides his clients with expertise and knowledge i n 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 ye ars of professional experience in video production

. Thomas G. Alti has over 4 ye ars of5

recreational/hobb y e xperience in video and photography with Unmanned Aerial Sy stems
. 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, specificall y t argeting

 Commercial building and facility documentation

 Motion Picture Filming and Commercial Cinematography

 Real Estate Videograph y and Photograph y

 Wedding Videograph y and Photograph y

 Landscape Videograph y and Photograph y

 In crease public knowledge of UAS and promote safe UAS operations.

**BACKGROUND** Unmanned Aircraft Sy stems Thomas G. Alti seeks an exemption to operate the DJIFlame 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 DJ I 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 1 2.5 inches. The Droidworx AD8

- HL has a take

- off weight of 5302 grams, a diagonal width of 45 inches and height of 18 inches. M aximum 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 photograph y. All the flights Thomas G. Alti has done are at a very slow methodical pace for smooth drifting motion video. The DJ I Flame Wheel F450 is6

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 L ithium Poly

mer battery powered electric motors. The UA S s that will be operated b y Thomas G. Alti will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraf t , 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 , hereb y petitions the Administrator to commerciall y operate the UASs in the National Airspace Sy stem (NAS), and f

or 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. Accordingl y, 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 onl y 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 pr eventive maintenance on the UAS s using the methods, techniques, and prac tices prescribed in the operating documents (i.e., Monthly Maintenance Lo g, and their respective Instruction Manual s ). Furthermore, Thomas G. Alti will document and maintain all maintenance records for the UAS s . 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 PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and wh o 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 compe nsation or hire, act as PIC of an aircraft in connection with any business or employ

ment if: (1) The flight is only incidental to that business or employ ment; 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 PI C has met certain flight

- hour and currency requirements, demonstrating that the PI C is able to safel y 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 b y the PIC pursuant to the8

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 UAS s 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 UAS s are i n 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 Manual s ), 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 PI C 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 DJ I F450 UAS does not transmit telemetry data, but has a maximum altitude setting in the software that restrict s flight above a chosen altitude. This altitude information, combined with Thomas G. Alti ’s operation of the UAS s within visual line of sight, at or below 4 00 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 b y operation of the UA Ss duri ng daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR)

. B attery power has been documented and varies depending upon which of the UASs is being flown and the ambient9

temperature during flight

. No flights are started w ith 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

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- 7581 tgarecording@sbcglobal.net **B. The Specific Sections O**  **f 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 certificat e may act as a pilot in command (PI C) of an aircraft that is carrying passengers or propert y 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 an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; 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, b y 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 n o 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 insp ected 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 maintenan ce, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y 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 91.4**  **09(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 b y 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 c hapter. **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, a nd alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and12 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, fo r 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 b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y 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 b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retain ed 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 PI C 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 o r hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more fu lly

below, Thomas G. Alti submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the UAS s unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PI C is able to safel y operate the UAS s 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 b y the PI C pursuant to the grant of this Petition: (1) will be incidental to Tho mas 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 UAS s are in airworth y 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 Lo g, and UASs In struction 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. A lti will ensure that the UAS s 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 fo r 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 UAS s , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA Ss to the PI C 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 be cause the15

UA S s 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 full y set forth herein, an equivalent level of safety will be maintained since the UA Ss 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 UA Ss on the heads

- up display

of the GCS. **4. Extent Of Relief Thomas G. Alti**  **Seeks And The Reason Tho**  **mas 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 UA Ss during daylight hours in visual meteo rological 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 DJ I Phantom 2 Vision Plus UA will severel y constrain the practicality of an y aerial video or still photo flight operations that Thomas G. Alti proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I 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 DJ I Phantom 2 Visi on Plus UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR)

. B attery power has been documented and varies depending upon which16

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 appl y to aircraft with an airworthiness certificate, Thomas G. Alti requests relief from these Sections because the UAS s do not require airworthiness certificates. As s et forth more fully

below, the UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, 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 UAS s . **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 b y allowing Thom as G. Alti to safely , efficiently , and economically perform aerial video and photograph y of aerial video and photograph y 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 li ve newsgathering, training to persons individually

or belonging to both private and public organizations to increase17

awareness and improve safety for current and future UAS operations within the NAS, special events including high schools, colleges, profess ional 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 po llution , decrease fossil fuel usage, and provide significant benefits to the economy. Notably , the benefits of Thomas G. Alti ’s proposed operation of the UAS s will be realized without implicating any

privacy issues. **1. The Public Will Benefit From Decreas ed Congestion Of The NAS.**  The UA Ss 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 UAS s 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, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The UA Ss do not require an airport to takeoff or land. Likewise, a reduction of manned aircra ft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safe ty And Efficiency Of The UAS**  **s .** 18 Conducting aerial acquisitions with the UAS s , instead of manned aircraft, will greatl y benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still pho tograph y flight operations. By using battery power and electric motors, the UAS s produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typicall y utilized for aerial video and photography , while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The UA Ss , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA Ss are propelled by batte ry powered electric motors, rather than an internal combustion engine. By using the UAS s 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 f light operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the UA Ss (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 ph ys ical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 6,000 pounds with a wingsp an 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 UAS s**  **Will Benefit The Economy.**  In addition to being safe and efficient, the UAS s are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the UAS s will allow United States based people , like Thomas G. Alti , to remain competitive19

and contribute to growth of the U.S. econom y . Specificall y, 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 compe titive. Operating the battery powered UA Ss 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 operat ing the UA Ss , 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 UA Ss , 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 bo th 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 UA Ss will not implicate any privacy issues. Sp ecificall y, the UA Ss will be operated only in compliance with operating documents (i.e., the Thomas G. Alti Aerial Operations Manual, Monthly Maintenance Lo g, and UASs Instruction Manual s ) 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 Exemptio n 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 UA**  **Ss Meet The Conditions Of The FAA Modernization**  **and Refo rm 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 UA Ss meet the conditions of FMRA Section 333, and will n ot 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. Specificall y, 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 the21 na tional 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 UA Ss can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the UA S s; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The UA**  **Ss Demonstrate Its Safe Characteristics.**  The UA Ss 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 UA**  **Ss .**  The technical specifications of the UA Ss 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 UA**  **S s Autonomous Flight And Navigation Modes Enable The**  **UAS To Remain Within A Defined Operational Area.** The UA Ss may

be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the UA Ss is provided at pages 10

– 15 of Exhibit B , Mission Planning section of Exhibit D, and pages 2

– 5 of Exhibit H
.

**iii. The UA**  **S s Are Designed For Automatic Return To Home Point Or**  **Hover In The Event Of Loss Of The Control Link Or Navigation.** When the Control L ink is lost, the UA Ss will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the UA Ss do not reacquire control link data from the GCS, the UA S s will assume that the Control L ink is lost and the UA S 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 DJ I 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 IMikroKopter tool OSD and Way

Points. **b. Flight Operations Of UA**  **S s Are Limited To The Line Of Sight Of A**  **Certificated Pilot in Comma nd 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 (PI C) of the UA Ss . Additionally , a safety observer will assist all pilots during flight time.

**c. Flights Of UA**  **S s Will Be Conducted Pursuant To Specific Operating**  **Limitations.** In seeking this exemption, Thomas G. Alti proposes to commerciall y operate UA Ss 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: DJ I F450, DJIF550 and Droidworx AD8

- HL Unmanned Aircraft Sy stems. Proposed operations of an y 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 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is m ade and approved b y 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 PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corre ctive lenses, as specified on the PI C’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satis fy the VLOS requirement as long as the PIC alway s maintains VL OS capability

. The SO and PI C 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 PI C 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 PI C with s eeing 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 av ailable 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 e xemption 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 r evision 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 t o the operating documents. 10. Prior to each flight the PI C 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 the24 preflight inspection. All maintenance and alterations must be properl y documented in the ai rcraft 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 PI C 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 aircraf t 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. Th e authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical c ertificate. 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y 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 fl ight operations are considered nonparticipants, and the PI C 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 FAA25 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 5 00 feet below or less than 2,000 feet hori zontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in acc ordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C 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 oper ator 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 an y law enforcement official upon request.26 29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be operated b y the PIC from any moving device or vehicle. 31. Flight operations must be conducte d at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating per sons 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, f light 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 PI C has made a safety assessment of the ris k of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All op erations 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 co nducted. 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 r eported 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 Adverse**  **ly 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 PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the UAS ’s in a manner consistent with27

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 safel y operate the UAS ’s , Thomas G. Alti submits that the additional manned airmansh ip experience of a commerciall y 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, 1106 6, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Thomas G. Alti will not allow an y P IC to operate the UAS ’s unless that PIC has demonstrated, b y meeting minimum flight

- hour requirements or the UAS ’s training and currency requirements, that the PI C 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. Sp ecificall y, the PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experi ence 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 logg ed, 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 PI C must also have accumulated an d 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 PI C 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 accomplis h the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, Thomas G. Alti wi ll ensure safe operations by not allowing any

PI C to operate the UAS ’s unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PI C is able to safel y operate the UAS ’s in a manner consistent with the exemption, i ncluding 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 b y Section 91.7(a) will be maintained because prior to every

flight, Thomas G. Alti will ensure that the UAS ’s are in an airworth y 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, 1 1080, 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 b y Section 91.121 will be maintained because the altitude information of the UA S’s will be provided to the PI C 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 UA S’s within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitu de 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. 110 62, 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 UA S’ 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 safel y operate the battery powered UA S’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 UA S’ s; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety establishe d by

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the UA S’s provide audible and visual warnings to the PI C at the GCS when the UA S’s experience low battery voltage, the first warning occurring at approximately 33% remaining battery p ower, and again at approximately 10% remaining battery

power. At the criticall y low battery level, the UAS will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversel y 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, 11 067, 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 S afety.**  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 Ae rial Operations Manual, Monthly Maintenance Log, and UAS’s Instruction Manual s ). Furthermore, Thomas G. Alti will document and maintain all maintenance records for the UA S’s

. Since the UA S’ s will be inspected as prescribed by the operating documents, Tho mas 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 cop y of the monthly Maintenance LOG is attached here to as Exhibit C

. Likewise, the exemption sought will not adversel y 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 pre scribed b y 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 the32

UA S’s will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y 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 adv ersel y 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 as pects of the UA S‘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 m aterial 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 UA S’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 UA S’ s for the limited purpose of conducting aerial video and photography over certain33

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 UA S’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 Con ditions, 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 p ropeller, 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 find s 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 intend ed operation of the UA S’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 comm ercially 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 airworth iness certification. As discussed in detail above, Thomas G. Alti will operate the UA S’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, Tho mas 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 UA S’s commercially , without an airworthiness certificate, for the limited purpose o f conducting aerial video and photography over certain35

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, b y allowing Thomas G. Alti to safely , efficientl y, and economically operate the UA S’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 UA S’s commercially

for the purpose of conducting aerial video and photography over certain areas of the United States. Date d: December 21 , 2015

Respectfully

submitted, Thomas G. Alti

_________________________ Thomas G. Alti 295 Urbandale Avenue Benton Harbor, MI 49022 269

- 926

- 7581 tgarecording@sbcglobal.net36

Appendices : A

– UAS’s Specification Sheet B

– DJ I NAZA

- M quick start guide v1.26 C

– Monthly

Maintenan ce L og D

– Mission Planner E

– DJ I F450 User Manual F

– DJ I F550 User Manual G

– AD8

- HL User Manual H

– MikroKopter Tool Manual I
-- MikroKopter Tool OSD & Way points J
-- MikroKopter Failsafe