August 19th, 2015

U.S. Department of Transportation

Docket Management System

800 Independence Ave. SW

Washington, DC 20591

Exemption Request Pursuant to Section 333 of FAA Reform Act 2012

To Whom It May Concern,

ALPS Company, the petitioner, is writing pursuant to the FAA Modernization and Reform Act of

2012 and the methodology contained within 14 C.F.R. 11, requesting that the petitioner, ALPS

Company, petition for exemption from the Federal Aviation Regulations listed below and any

regulation deemed necessary to operate small unmanned aerial vehicles (sUAVs) commercially.

The request exemption would allow the petitioner to conduct safe, professional, commercial

services for public and private entities in Indiana and surrounding states, using a sUAV

equipped with aerial photography and video capabilities for but not limited to the following

objectives:

­ Real Estate Photography and Videography

­ Industrial Inspection

­ Agriculture

­ Environmental and Natural Resources

­ Aerial Surveying

­ Disaster and Accident Analysis and Synopsis

The use of small UAVs would fill a void in service to consumers that would otherwise exist due

to the risks and costs associated with manned aircraft operation. The public safety is of utmost

importance when integrating small UAVs into the national airspace without interference or

hazard to manned aircraft or persons on the ground. The services ALPS Company propose are

offered with the motive of enhancing the development of safe operation of small UAVs,

understanding that current manned aircraft operations pose a greater risk of injury, death,

and/or property damage.
Summary

The petitioner, ALPS Company, hereby petitions the Federal Aviation Administration to

commercially operate small UAVs in the National Airspace, and requests exemption from the

requirements of 14 CFR § 61.113 (a) & (b), 14 CFR § 91.7(a), 14 CFR § 91.119(c), 14 CFR Part

91.121, 14 CFR Part 91.151 (a), 14 CFR §91.203 (a) & (b), 91.405(a) , 91.407(a)(1),

91.409(a)(1) and (2), 14 C.F.R. Part 21, Subpart H, and 91.417(a) and (b), to operate sUAVs

agreeable to Section 333 of the FAA Modernization and Reform Act of 2012. This exemption will

allow the petitioner to operate a small Unmanned Aerial Vehicle commercially in accordance

with exemption from the Federal Aviation Regulations listed and any regulation as required by

the FAA that is considered necessary to permissibly conduct commercial sUAV operations.

Small Unmanned Aerial Vehicle Used:

ALPS Raven X­8:

Normal flight time with 25% remaining battery capacity: 20 minutes

Pro­rated maximum flight time: 26.6 minutes

Height (gear deployed): 648mm

Height (gear retracted): 317mm

Width: 508mm

Diagonal Length W/O Rotor Blades: 698mm

Number of Motors: 8

Propeller Diameter: 15”

Empty Weight: 7.8lbs

Battery Payload Weight: 3.6lbs

Battery Type and Capacity: Lithium Polymer, 14.8V, 20,000mah

Maximum Takeoff Weight: 19lbs

Radio Control Frequency Band(s): 433Mhz & 915Mhz

Safety Features:

­ Redundant Propulsion System: Can sustain at least 1 motor failure while retaining stable

flight

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­ Radio Redundancy: Communications with the aircraft can occur on multiple frequencies

­ Radio Failsafe: Upon loss of all communications with the aircraft, it will automatically

return to and land at a predetermined point

­ Fuel Redundancy: Dual onboard batteries permit for a single battery failure to occur

while maintaining stable flight

­ Flight computer power redundancy: Dual onboard power regulators permit for a single

failure to occur while maintaining stable flight

­ Fuel feedback and failsafe: remaining battery levels are transmitted to the ground

station; automated landings to predetermined positions are programmed in the event of

critical battery levels

ALPS V1 Ground Station

Number of Channels on Primary Comm Frequency: 12

Control Radio Range: Up to 30km

Video Frequency Band(s): 5.8Ghz, 1.2Ghz (CH8)

Full Instrument On Screen Display: Yes

Power system: Multiple lithium polymer batteries with audible low voltage alarms

Dual video displays

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ALPS Company Flight Operations Checklist: ALPS Raven X-8

Arrival

- Check for people/bystanders/property in

vicinity

- Investigate potential alternative landing

sites in case takeoff site is obstructed

- Check weather forecast including visibility,

temperature, precipitation, and wind speed

- “Surrounding area clear for flight”

Preflight

- Remove transmitter from field box

- check transmitter battery

- make sure all toggle switches are

set to neutral

- Inspect craft

- apply pressure to arms and joints

to check stability

- inspect propellers, propeller

mounts, and propeller screws

- camera sd card inserted with

enough space

- camera battery charged

- camera lens cap removed

- camera secured to gimbal

- insert batteries and connect

voltage alarms

- Camera

- Battery

- Fiber cable secured

- Press focus button to initialize

- Connect UAV batteries

- connect video battery as well

- Ensure verified satellite connections

- Start video recording (if applicable)

- Engage arming mechanism

- “Prepare for arm”

- “Prepare for takeoff”

* ​All red text is audibly stated by the PIC

Midflight

- Hover approximately 30 seconds 5 feet

above ground to confirm UAV is

functioning properly with no failed

components

- Verify all transmitter functions

- Engage landing gear retraction

- “All systems go”

Pre-landing

- “Mission concluded, prepare for

descent”

- Make sure landing zone is clear of

obstructions

- “Landing zone clear”

- Engage landing gear to landing position

- “Prepare for landing”

- Land and disarm motors

- “Motors disarmed”

Post-landing

● Returning to flight immediately

○ Battery - remove and replace

○ Check for voltage alarms

○ Make sure takeoff area is secure

○ “Prepare for arm”

○ Arm motors

○ “Prepare for takeoff”

○ Hover check

○ “All systems go”

● End of ops

○ Batteries unplugged

■ UAV

■ fpv monitor

■ antenna tracker

○ Transmitter off

○ Input final flight data for

records

○ "Mission concluded"

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Basis For Exemption Requests

14 C.F.R. Part 21, Subpart H

With thorough consideration of the specifications of the ALPS Raven X­8 including weight, size,

speed, and limited operational area associated with the small UAV, ALPS Company operation

of the ALPS Raven X­8 sUAV meets the requirements of FMRA Section 333 and therefore, an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H, is not necessary

according to Exemption 11138 (DOUGLAS TRUDEAU).

14 CFR § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command

Section 61.113 (a) & (b) prevents private pilots from flying for compensation or hire. It is

proposed that all of the petitioner’s pilots will be operating with a minimum of a Sport Pilot

Certificate. None of the petitioner’s aircraft will carry pilots or passengers. Because no onboard

human life is at risk, the petitioner believes that operating with a Private Pilot Certificate would

achieve an equivalent level of safety as that of sUAV operations with the PIC holding a

Commercial Pilot Certificate or above. In addition, Grant of Exemption No. 11062 to Astraeus

Aerial determined that a PIC holding a private pilot certificate operating the Astraeus sUAV

would not adversely affect operations within the NAS or present hazards to persons or property

on the ground.

14 CFR § 91.7(a): Civil Aircraft Airworthiness

Because no Airworthiness Certificate is obtainable nor available for a small sUAV the petitioner

requests exemption of 14 CFR part 91.7(a), instead, utilizing an in depth flight operations

checklist (included). The petitioner agrees with compliance to part 91.7(b) in that the operation

will only be executed after an in depth flight operations checklist including air speed and

weather forecast, airspace, area of operations, alerting non participating persons in the area of

proximity, and performing a thorough inspection of the aircraft before flight as well as regular

maintenance per manufacturer standards.

14 CFR § 91.119(c): Minimum Safe Altitudes

Section 91.119 (c) requires that aircraft may not operate at less than 500 feet above surfaces

unless taking off or landing. In addition, it requires that the aircraft may not be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Due to the nature of operations

performed by unmanned aircraft, operations will require that flights be conducted at less than

400 feet. All of our vehicles will have a takeoff weight less than 55lbs, as well as a number of

redundancy and safety features and lack of flammable fuel that drastically reduce risk factors

associated with low altitude flight. The petitioner believes that due to the increased safety

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factors of unmanned aircraft in addition to the public need for low altitude aircraft operation,

exemption from section 91.119 (c) is in the public interest.

14 CFR Part 91.121: Altimeter settings

Section 91.121 requires a calibrated barometric altimeter be present for maintaining cruising

altitude. As discussed in Exemption 11138 (DOUGLAS TRUDEAU), this is not possible due to

the lack of an altimeter onboard a sUAV. Since some of our aircraft may not be constructed

containing a barometric altimeter, but rather with a GPS­based altimeter, an exemption may be

needed. We believe that an equivalent level of safety can be obtained by combining a GPS

altitude readout with visual altitude regulation. The altitude readout on the GPS would be

confirmed before takeoff as part of preflight checklist operations.

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

Past exemptions have been granted for manned aircraft to operate at less than prescribed

minimums, including Exemptions Nos. 2689, 5745, and 10650. Also, similar sUAV­specific relief

has been granted an exemption through Nos. 8811, 10808, and 10673 for daytime VFR

conditions. The petitioner’s sUAV has audible low voltage battery alarms that indicate the PIC

should land the sUAV immediately. The sUAV also has an automatic landing failsafe when the

battery levels reach critical levels. The battery voltage is continuously transmitted to the PIC,

thus having constant knowledge of battery voltage. The petitioner warrants that the sUAV will be

landed with 25% battery levels remaining, and immediately upon hearing the low voltage battery

alarm, both of which permit more than enough time to execute a safe landing. The petitioner will

not initiate a flight without having the battery capacity to safely take off, fly at normal cruising

speed during operation, and land safely with excess battery level remaining.

14 CFR §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

The full takeoff weight of the petitioner’s aircraft will be less than 55 lbs. In addition, the aircraft

does not have an onboard pilot, passengers, or crew. As a result, there is no practical manner

for these documents to be carried onboard the aircraft. The FAA is authorized to exempt aircraft

from the airworthiness certificate requirement under both the Act 49 U.S.C. § 44701 (f) and

Section 333 of the Reform Act with consideration of the weight, size, speed, maneuverability

and proximity to persons and areas such as dense populations. The petitioner’s current and

projected sUAVs do not meet or exceed these elements.

91.405(a); 91.407(a)(I); 91.409 (a)(I) & (2); 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), sections 91.405(a); 91.407(a)(I);

91.409 (a)(I) & (2); 91.417(a) & (b) “only apply to aircraft with an airworthiness certificate”. In

addition, the petitioner proposes its own preflight inspections as well as regular maintenance in

accordance with any manufacturer standards in order to ensure that the sUAV is safe for flight.

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Public Interest

Approval of this petition will be in the public interest in multiple ways including:

Safety

Performing aerial services with the ALPS Raven X­8 will greatly benefit the public

interest by decreasing the air pollution. The ALPS Raven X­8 is completely battery

powered and electric, which means no air pollution is emitted from the sUAV.

Considering public safety, the ALPS Raven X­8 is a safer alternative for manned flight

concerning personal injury, property damage, and death to the pilot and or passengers.

The substantial risk to human lives will be drastically reduced or even completely

eliminated through the use of sUAVs such as the ALPS Raven X­8, assuming all flight

operation checks are utilized and executed.

Decreased Airspace Congestion

By using sUAVs such as the ALPS Raven X­8, the decreased congestion of the National

Airspace System will be substantially lowered by sUAVs taking the place of manned

aircraft services in multiple circumstances. This will reduce the number of manned

aircraft operation in the National Airspace System, as well as decreasing the congestion

of airspace in proximity to airports with less manned aircraft arriving and departing. The

ALPS Raven X­8 does not require an airport for takeoffs or landings, resulting in fewer

aircraft that must be handled by air traffic control at towered airports.

Economy

Allowing ALPS Company to perform commercial flights with the ALPS Raven X­8 will

benefit the economy. In addition to being safe and promoting green energy, the ALPS

Raven X­8 is an economical benefit compared to the cost of operating and upkeep of a

manned aircraft. Operation of sUAVs will allow ALPS Company and similar businesses

to contribute to the growth of the U.S. economy. By allowing sUAV businesses such as

ALPS Company an exemption pursuant to Section 333, there will be more jobs created,

increased tax revenue, and a greater economy.

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Privacy

Privacy compliance will be the same as that of manned aircraft operations that have been

conducted for years. ALPS Company’s proposed operation of the ALPS Raven X­8 will not

hinder any privacy issues. ALPS Company will only operate the ALPS Raven X­8 in compliance

with operation procedures and documents which will require property owner involvement and in

accordance with the Federal Aviation Regulations encapsulated in the sUAV requirements of 14

C.F.R. § .

Respectfully submitted,

Tanner Atkins

ALPS Company

12710 Waters Edge Ct

Camby, Indiana 46113

Email: tanner.atkins@alpscompany.com

Phone: (317)­694­9238

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