Page 1

Anthony J. Pucciarella

PO Box 1835 Lusby, MD 20657

240

- 538

- 8444 Tony@TeamAlaris.com

10 July 2015

United States Department of Transportation
Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition by Alaris for Grant of Exemption Pursuant to Section 333 of the FAA Modernization
and Reform Act of 2012

To Whom It May Concern :

Pursuant to Section 333 of the Federal Aviation Administration Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Alaris hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of the DJI Phantom 3 and DJI Inspire 1 s mall Unma nned Aircraft System s ( UAS ) to conduct aerial video, photography, inspection, and training , provided such operations are conducted within the conditions outlined in this exemption request or as established by the FAA

. Alaris respectfully submits that this

Petiti on for Exemption qualifies for approval, as the FAA has previously issued grants of exemption in circumstances similar to those presented in this petition.

In addition to this Petition for Exemption, Alaris will also submit the following s upporting documents ( referred to as “Operating D ocuments” in this petition ):

 Alaris UAS Operations Manual  Inspire 1 User Manual

 Phantom 3 User Manual  Inspire 1 Safety Guidelines

 Phantom 3 Quick Start Guide  Inspire 1 Quick Start Guide

 Phantom 3 Safety Guidelines  Inspire 1 Maintenance Manual

 Phantom 3 Safety Guidelines  Intelligent Flight Battery Safety Guidelines

Alaris submits the se documents a s confidential material under separate cover pursuant to 14 C.F.R. § 11.35(b) since the document s contain confidential commercial and proprietary
information that Alaris does not intend to share with others. The information contained in
th ese document s is not generally available to the public and is protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.Page 2

Petitioner Background and Description of Proposed Operations

Alaris is a Maryland

- based , veteran

- owned small business specializing in unmanned systems integration and operations. The company is owned and operated by an A irline Transport Pilot (A TP ) certificated Pilot who has been active in the UAS industry (DoD and Civil) for over seven years and co

- Leads the Right

- of

- Way ( R O W ) sub workgroup on RTCA SC

- 228 which is developing the Minimum Operation al Performance Standards (MOPS) for UAS Sense and Avoid (SAA).

T his petition is intended to allow Alaris to conduct the following commercial UAS operations:

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

, engineering

, and other related professional activities.

- Aerial video / photography for public / private use including television, public events, cinematography and n ews gathering.

- Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

- Aerial inspection/photography of residential/commercial utility infrastructure including
but not limited to elec trical power lines, wind turbines and cell towers.

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

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

As described in the following paragraphs, an approved exemption would permit operations of
the DJI Phantom 3 and DJI Inspire multi

- rotor UAS under controlled conditions in limited airspace with the approval o f cooperating property owners. These operations would provide improved safety over the exist ing means of obtaining the same data with larger manned
systems.

In accordance with 14 C.F.R. § 11.81(a), Alaris provides the following information in support of its Petition for Exemption.

The contact information for Petitioner is as follows:

Name: Alaris

Attn: Anthony Pucciarella
Phone: 240

- 538

- 8444
Address: PO Box 1835

Lusby, MD 20657

E

- mail: Tony@TeamAlaris.comPage 3

Regulations F r om W hich E xemption I s R equested

91.7 (a)

– Civil Aircraft Airworthiness

91.9 (c), 45.23(b) , and 45.27 (a)

– Aircraft Marking and Identification Requirements 61.101 (e) and 61.113

– Private and Recreational Pilot Privileges and Limitations 91.9 (b) (2)

– Civil Aircraft Flight Manual in the Aircraft 91.203 (a) and (b)

– Certifications required for Civil aircraft

91.103

– Preflight Action

91. 109 (a)

– Flight Instruction

91.119 (b) and (c)

– Minimum Safe Altitudes

91.121

– Altimeter Settings 91.151 (a)

– Fuel Requirements for Flight in VFR Conditions 91.405 (a) , 91. 407 (a) (1) , 91. 409 (a ) (1) and (2) , 91. 417 (a) & (b)

– Maintenance Inspections

The systems requested in th is exemption are the DJI Phantom 3 and DJI Inspire 1 multi

- rotor
UAS

. Each system weighs less than 7 pounds each fully loa ded

– considerably less than the 55 pound requirement that defines s mall UAS. Alaris will operate the se systems with in Visual Li ne of S ight (VLOS) of the Pilot and Visual O bserver. The UAS will operate at speeds less than 87
knots and ha ve the ability to hover. Area of operations will be over private property with owner permiss ion or public property with permission from the appropriate officials

. A laris operations
will not create a hazard to users of the national airspace system or the public.

Utilization of the proposed UAS is of public interest and safety. The proposed UAS are less intrusive than manned helicopter s and ha ve less of an impact on the environment. Both of the proposed UAS are battery powered and energy friendly. The system s take off vertically from the operat ion area which minimizes transit time s a s well as the possibility of encounters with
manned aircraft

.

Alaris’ proposed operations in this Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act, as each of the statutory criteria and relevant factors

are s atisfied. Approval is Warranted Based on the UAS’s Size, Weight, Speed, and Operational Capability. The FAA has already determined the DJI Phantom 3 and DJI Inspire 1 systems chosen by Alaris meet the requirements of Section 333 of the Reform Act.

Description O f P r o p o s e d S y s t e m s
The DJI Phantom 3 is a battery operated quadcopter with an airframe weight of 3 pounds (including battery and payload). The Phantom 3 measures approximately 23 inches in diameter (including propellers)

, has a maximum operating ground spe ed of 31 knots

, operates on 2.4 G H z and has a flight time of approximately 23 minutes

.

The DJI Inspire 1 is a battery operated quadcopter with an airframe weight of 6 .5 pounds (including battery and payload). The Inspire 1 measures approximately 23 inches in diameter (including propellers)

, has a maximum operating ground speed of 43 knots

, operates on 2.4 GHz and has a flight time of approximately 18 minutes

.Page 4

Both the DJI Phantom 3 and DJI Inspire 1 can operate safely after experiencing certain in

- flight contingencies or failures and u tilize an auto

- pilot system for stability and control. The UAS are also able to respond to a loss of GPS or a lost

- link event with a pre

- coordinated, predictable,
automated maneuver. These safety features provide an equivalent level of safety compared to a manned aircraft performing a similar operation and mitigate the risk of command and control contingencies

.

Previously I ssued FAA E xemptions F or Similar Operations

The FA A has previously issued grants of exemption in circumstances substantially similar to those presented in this Petition for Exemption, including, but not limited to:

- Exemption No. 11991 ( Docket No. FAA

– 2015

– 1492) to Direct Area Photo and Video to operate th e Phantom 3 for aerial video, photography, inspection, and training.

- Exemption No. 11778A ( Docket No. FAA

– 2015

– 0591 ) to Cloud9Drones LLC to operate the Phantom 3 and Inspire 1 to conduct aerial inspections of towers/tall structures for multiple industries, and videography for film and marketing.

- Exemption No. 11845 (Docket No. FAA

– 2015

– 0806) to Sky Eye LLC to operate the Phantom 3 and Inspire 1 to conduct aerial photography and videography to be used for construction, real estate, television com mercials, weather traffic and news reports, and sporting events.

- Exemption No. 11398 (Docket No. FAA

– 2015

– 0145) to Ventus Wind, LLC for DJI Inspire 1 ( and other UAS) operations to conduct aerial inspections of its legacy power generation customers and to expand to support the growth of new customers in the onshore and offshore regions of the United States.

- Exemption No. 11394 (Docket No. FAA

– 2015

– 0160 ) to Cirrus Exploration Company for DJI Inspire 1 (a nd other UAS ) operations to conduct flight instruction, commercial aerial work flight operation s, student instruction, aerial photography and survey, and power line or pipeline patrol.

A pproval I s Warranted Based O n T he O p e r a t i o n a l Restrictions I n Alaris’ Operating Documents

Alaris’ operating documents contain the necessary procedures and limitations required to safely pe rform the proposed operations. To assist the FAA in making a safety assessment of
Alaris ' proposed operations, the following summary is provided which includes the limitations
and conditions that Alaris will adhere to, and which will ensure an equivalent o r higher level of safety to operations conducted under current regulatory guidelines by manned aircraft :

1. Operations authorized by grant of this exemption are limited to the DJI Phantom 3 and DJI Inspire 1 which weigh less than 55 pounds including payload. Proposed operation
of additional aircraft will require a new petition or a petition to amend this exemption.Page 5

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. All f li ghts will be conducted within VLOS of the Pilot and Visual Observer in day Visual Meteorological Conditions (VMC). This requires the PIC to use vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman
medical c ertificate or U.S. driver’s license.

4. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles. Flights under special visual flight rules (SVFR) are not authorized.

5. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- publ ished aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the
Administrato r or any law enforcement official upon request.

6. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the

reserve pow er recommended by the manufacturer if greater.

7. The PIC may not operate the UAS from any moving device or vehicle.

8. Flights will be operated at or below 4 00 feet AGL.

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

10. The UA must remain well clear and give way to manned aviation operations at all times.

11. The speed of the UAS will not exceed 87 KTS (100 MPH)

. In no case will the Air Vehicle be operated at airspeeds greater than the maximum airspeed recommended by the

aircra ft manufacturer

.
12. The operating documents and this exemption must be accessible to the PIC during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the p rocedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present

up dated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator
determines th at any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption.Page 6

13. The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condition for safe operation and must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the UAS

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

14. Prior to each flight, the PIC must conduc t a pre

- flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performe d and the UAS is found to be safe for flight

.

15. Minimum crew for each operation is a Pilot and Visual O bserver (VO)

. The Air Vehicle must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requir ement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting i s 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 VO can perform the duties required
of the VO

16. Any PIC operating under this exemption must hold either an airline transport, commercial, private, recreational, or sport pilot certificate.

17. The PIC operating under this exemption must hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government.

18. The op erator may not permit any PIC to operate UA S unless the PIC demonstrates the ability to safely operate the system in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification

, flight hours

, and currency must be logged in a manner consistent with 14 CFR § 61.51(b).

19. Flights will only occur over private property with owner approval or public property
with permission from the appropriate officials (all required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies)

.
20. Flight operation s will not occur within 5 00 feet of personnel in the designated area that are not part of the specific operation.

21. PIC will brief all involved personnel on flight operations and applicable safety procedures prior to flight operations . A single brief will su ffice for multiple flights unless there are personnel or operational changes.

22. All operations shall be conducted in accordance with the issued Certificate of Waiver or Authorization ( COA )

.
23. Pilot and Visual Observer will have been trained in UAS operations as described in the Alaris UAS Operations manual

.Page 7

24. In case of “ loss o f communication /link ” or “ loss of GPS ”

, the proposed UAS will have the capability to return to a pre

- determined point within the prescribed area of operations and land.

25. All Air Vehicles operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

14 CFR 91.7(a)

- Civil Aircraft Airworthiness

Since there wi ll be no airworthiness certificate issued for the UAS, Petitioner seeks an exemption from 14 CFR § 91.7(a), which requires that “n o person may operate a civil aircraft unless it is in an airworthy condition .” T he FAA has previously determined that for t he purposes of this exemption

, the pilot may determine the aircraft is in an airworthy condition prior to flight. The operating documents contain procedures which direct the PIC to determine whether the aircraft is in a condition safe for flight, and an e xemption from § 91.7(a) is therefore
warranted

14 CFR 91.9(c), 45.23(b) and 45.27(a)

- Airc raft Marking and Identification Requirements

91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter.

45.23(b), Markings of the Aircraft, states: When marks include only the Roman capital letter "N" and the registration n umber is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not le ss than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable.

45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a prior grant of exemption under Section 333 of the Reform Act, the FAA determined that

e xemption from these requirements was warranted provided that the aircraft have identification markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable. All Air Vehicles flown by Petitioner will bear N

- number marki ngs that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C.

14 CFR § 61.101 (e) and 61.113

- Recreational and Private Pi lot Privileges and Limitations

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

- commercial operations.Page 8

The FAA recently determined that holders of recreational and sport pilot certificates would have adequate aeronautical knowledge to pilot a UAS. Accordingly, because these individuals would also be subject to security screening by the Department of Homeland Security ( DHS ), the FAA determined that holders of recreational and sport pilot certificates would be qualified to

serve as the PIC for UAS operations (see Exemption 11213

, Docket No. FAA

- 2014

- 0642 ).

Petitioner will operate o n private property away from persons and property not involved in the operation and will require all PICs to be thoroughly trained in the unique aspects of UAS flight. As set forth in the operating documents, pilots will have experience not only in UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf of the Petitioner . The pilot qualification, training, and currency requirements in the operating documents ensure that

Peti tioner ’ s pilots are competent and proficient in the UAS they are operating. The Petitioner's training and qualification requirements are consistent with those contained in prior FAA issued grants of exemption, and wi ll provide a high level of competency and proficiency for its pilots and will ensure at least an equivalent level of safety.

14 C.F.R. § 91.9 (b) (2)

- Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides that n o person may operate a U.S.

- registered civil aircraft f or which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, marki ngs, and placards, or any combination thereof.

Given the size of the proposed UAS Air Vehicle s and the general nature of UAS operations, the Operations and Maintenance M anual s for flight s conducted under this exemption will be located in proximity t o the PIC and Visual Observer. An equivalent level of safety is provided by keeping the manual on the ground for immediate access by the crew.

14 C.F.R. § 91.103

- Preflight action

This reg ulation requires each pilot in command to take certain actions before flight to e nsure the safety of flight.

Petitioner requests an exemption from 14 C.F.R. § 91.103 since an FAA approved flight manual will not be provided for the aircraft. The preflight procedures in the Operating Documents will ensure that the UAS is in an airworthy condition prior to flight and thereby provide an equivalent level of safety. The PIC will take all actions prior to initiating flight including reviewing weather, flight batter y requirements , landing and takeoff distances, and aircraft performance data

.

The PIC will complete a series of checklists designed to identify any defects or inoperable components, which cover pre

- flight, take

- off, landing and post

- flight pro cedures

. Petitioner'sPage 9

O perating D ocuments will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS.

14 C.F.R. §91.109 (a)

- Flight instruction

Section 91.10 9 (a) provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual
controls.

Like other unmanned systems, t he proposed UAS do not have fully functional dual controls so the Petitioner requests an exemption from this rule. Flight control is accomplished through the

use of a remote controller that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully funct ional dual controls and for flight instruction in experimental aircraft. An equivalent level of safety will be provided since neither a pilot nor passengers will be carried in the aircraft and by the limited aircraft size

, speed , and operational area

.

1 4 C.F.R. §91.119

- Minimum safe altitudes

Petitioner requests an exemption from the minimum safe al titude requirements of § 91.119

, which state:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,00 0 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

As this exemption is for a small UAS multirotor and seeks authority to operate at altitudes up to

400 AGL

, the Petitioner requests an exemption t o allow such operations

. As set forth herein,
the proposed UAS will not operate above 400 AGL. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where operations

occur . No flight will be taken without the permission of the property owner or appropriate official. Because of the advance notice to the property owner and participants

, all affected individuals will be aware of the planned flight operations as set forth in th e Petitioner’s Operating Documents

.

The proposed UAS Air Vehicle s weigh less than 7 pounds each fully loaded and carr y no pilot or passengers, explosive material or flammable liquid fuels

. Compared to flight operations with
manned aircraft or rotorcraft weighing far more , the risk associated with the proposed operations is far less than those presented by c onventional aircraft operating at or below 500Page 10

AGL performing similar operations

. Ad dition ally , the proposed low

- altitude operations of the

s mall UAS w ill ensure separation from manned aircraft that must comply with Section 91.119.

14 C.F.R. §91.121

- Altimeter Settings

This regulation requires that each person operating an aircraft shall maintain the cruising altitude by reference to an altimeter that is set when operating below 18,000 MSL to t he elevation of the departure airport or an appropriate altimeter sett ing available before departure (for the case of an aircraft not equipped with a radio ).

The FAA has stated previously that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be achieved in circumstances where: (1) the UAS will be operated below 400 feet AGL or below, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator a t a ground

- based on

- screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to conf irm accuracy of the onboard GPS (see Exemption No. 11062 , Docket No. FAA

- 2014

- 0352 ).

The UAS that Petitioner int ends to use for the proposed operations meet all these operational
characteristics. Additionally, the operating documents require the PIC to calibrate the aircraft's GPS prior to each flight. As the FAA has determined in circums tances similar to this Pet ition

, Petitioner's UAS and the safety mitigation procedures contained in the operating documents ensure that an equivalent level of safety will be achieved, and a grant of exemption to the requirements of § 191.121 is therefore appropriate.

14 C.F.R. § 91.151(a)

- Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly
to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery of the proposed UAS provide less than 30 minutes of flight time (23 minutes for the Phantom 3 and 18 minutes for the Inspire 1)

. To meet the 30 minute reserve requirement of
91.151 would prevent flight operations

, therefore an exemption from this rule is req uired . Due
to the proposed altitude li mitations and the area of operation s , a longer time for flight in daylight V F R operations is reasonable. The FAA has approved similar exemptions from the fuel requirements of § 91.151(a) for flight in day V FR conditions

. T he FAA determined that a requir ement prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there was enough available power for UAS to operate for the intended operational time and to operate after that for at least five minutes or wit h the reserve power recommended by the manufacturer if greater, would ensure an equivalent level of safety to the fu el requirements of § 91.151(a) (see Exemption No. 11213 ). Petitioner's operating documents impose this same requirement an d an exemption fro m §91.151(a) for flight in V FR conditions is therefore appropriate.Page 11

14 C.F.R. §91.2 03 (a) and (b)

- Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has a n appropriate and current airworthiness certificate a n d a n effective registration certificate

. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authori zation issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The proposed UAS Air Vehicle s weigh less than 7 pounds each fully loaded (2.8 pounds for the
Phantom 3

, and 6.5 pounds for the Inspire 1) and carr y no passengers, explosive material

, or flammable liquid fuels therefore no display of airworthiness or onboard documents is required. An equivalent level of safety will be achieved by keeping these documents at the ground control station where the pi lot flying the UAS will have access to them to the extent they are applicable. The FAA has issued numerous exemptions to this regulation (see E xemptions 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700 )

.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) and (2); 417(a) & (b)

- Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between requi red inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Petitioner is requesting an exemp tion to the Maintenance Inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b)

. These regulations apply only to aircraft with an airworthiness which the UAS in this petition will not have.

Maintena nce and inspections will be accomplished by the operator pursuant to the Operating

Documents

. An equivalent level of safety is provided because the UAS are limited in size, weight, payload capacity, and will be flown in limited areas for short periods of time. If
mechanical issues arise

, the proposed UAS Air Vehicle s can be land ed immediately and will be operating from no higher than 400 feet AGL.

As provided in the Alaris UAS Oper ations M anual, the PIC will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and will keep a log of any maintenance performed. A functional test flight will be conducted and logged following the replacement of a ny flight

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

N ational Security

This requested exemption does not present a national security issue

. Given that the UAS are small and lightweight, have lost

- link and contingency capabilitie s , operate at very low speeds,Page 12

have extremely small payload capacities and carry no flammable, explosive or othe rwise dangerous materials, the operations pose n o threat to national security.

Summary F or Federal Register

Pursuant to 14. C.F.R. Part 11, the following summary is provided for publication in the Federal Register should it be determined that publication is required:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations:

45.23(b); 45.27(a); 61.113; 61.101(e); 91.7(a); 91.9(b)( 2); 91.9(c); 91.103; 91.109(a); 91.119(b) and (c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners
from the su bstantial hazards associated with using conventional fixed

- wing aircraft or,

rotorc raft for aerial video, photography, inspection, and training

.

Conclusion

Alaris’ Petition for Exemption satisfies the criteria required in Section 333 of the Reform Act of 2012, including weight, speed, operating capabilities, proximity to airports and populated areas, operation within VLOS and national security. The proposed operations in this Petition are similar to those in previously issued grants of exemptions, and will benefit the public by improving safety a nd minimizing risk by reducing the public's exposure to t h e danger and emissions associated with using manned aircraft to perform similar aerial data collection operations . Alaris ' UAS are battery po wered and create no emissions. Additionally , in the unlikely event of an accident with one of Alaris ’ UAS , there would be no fuel to ignite or explode

– thereby presenting s i g n i f icantly less danger to the pilot and other individuals on the ground than one involving a full size aircr aft.

In consideration of the foregoing, this Petition for Exemption provides the FAA with the necessary justification for granting the requested e xemptions t o a l l o w Alaris to use small UAS
to conduct aerial video, photography, inspection, and training

. Thank you in advance for your prompt consideration of this exemption request

. Please contact the undersigned should you have any questions, or if additional information is needed

.

Sincerely,

Anthony J. Pucciarella
Alaris