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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 small Unmanned Aircraft Systems (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 

Petition 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 supporting 

documents (referred to as “Operating Documents” 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 these documents as confidential material under separate cover pursuant to 14 

C.F.R. § 11.35(b) since the documents contain confidential commercial and proprietary 

information that Alaris does not intend to share with others. The information contained in 

these documents 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.
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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 Airline Transport Pilot 

(ATP) certificated Pilot who has been active in the UAS industry (DoD and Civil) for over seven 

years and co-Leads the Right-of-Way (ROW) sub workgroup on RTCA SC-228 which is 

developing the Minimum Operational Performance Standards (MOPS) for UAS Sense and Avoid 

(SAA). 

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

- Aerial photography/video for public/private use including land surveys, architecture,

real estate, engineering, and other related professional activities.

- Aerial video/photography for public/private use including television, public events, 

cinematography and news 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 electrical power lines, wind turbines and cell towers.

- Aerial video/photography to assist with search and rescue operations in cases of an 

emergency or natural disaster when requested by local authorities or government

organizations.

- Training public/private individuals that have interests in the use and application of UAS 

to support safe operations 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 of cooperating property owners. These operations would provide 

improved safety over the existing 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.com
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Regulations From Which Exemption Is Requested

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 this exemption are the DJI Phantom 3 and DJI Inspire 1 multi-rotor 

UAS. Each system weighs less than 7 pounds each fully loaded – considerably less than the 55 

pound requirement that defines small UAS. Alaris will operate these systems within Visual Line 

of Sight (VLOS) of the Pilot and Visual Observer. The UAS will operate at speeds less than 87

knots and have the ability to hover. Area of operations will be over private property with owner 

permission or public property with permission from the appropriate officials. Alaris 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 helicopters and have less of an impact on the environment. Both of the 

proposed UAS are battery powered and energy friendly. The systems take off vertically from

the operation area which minimizes transit times as 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 satisfied. 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 Of Proposed Systems

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 speed of 31 knots, operates on 2.4 GHz

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

contingencies or failures and utilize 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 Issued FAA Exemptions For Similar Operations

The FAA 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 the 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 commercials, 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 (and other UAS) operations to conduct flight instruction, commercial aerial 

work flight operations, student instruction, aerial photography and survey, and power 

line or pipeline patrol.

Approval Is Warranted Based On The Operational Restrictions In Alaris’ Operating Documents 

Alaris’ operating documents contain the necessary procedures and limitations required to 

safely perform 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 or 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.
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2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted.

3. All flights 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 certificate 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-published 

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 

Administrator 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 power 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 400 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 

aircraft 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 procedures 

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 

updated 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 that 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. 
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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 conduct 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 performed and the UAS is found to be safe for flight.

15. Minimum crew for each operation is a Pilot and Visual Observer (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 requirement 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 is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the 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 Columbia, 

Puerto Rico, a territory, a possession, or the Federal government.

18. The operator may not permit any PIC to operate UAS 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 operations will not occur within 500 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 suffice 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. 
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24. In case of “loss of 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 will be no airworthiness certificate issued for the UAS, Petitioner seeks an 

exemption from 14 CFR § 91.7(a), which requires that “no person may operate a civil aircraft 

unless it is in an airworthy condition.” The FAA has previously determined that for the 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 exemption from § 91.7(a) is therefore 

warranted

14 CFR 91.9(c), 45.23(b) and 45.27(a) - Aircraft 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 number 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 less 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 

exemption 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 markings 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 Pilot Privileges and Limitations

Sections 61.101 (e) and 61.113 limit Recreational and Private pilots to non-commercial 

operations.
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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 on 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 

Petitioner’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 will 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 no person may operate a U.S.-registered civil aircraft for 

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, markings, and placards, or any combination thereof.

Given the size of the proposed UAS Air Vehicles and the general nature of UAS operations, the 

Operations and Maintenance Manuals for flights conducted under this exemption will be 

located in proximity to 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 regulation requires each pilot in command to take certain actions before flight to ensure 

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 battery 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 procedures. Petitioner's 
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Operating Documents 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 91.109 (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, the 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 functional 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.

14 C.F.R. §91.119 - Minimum safe altitudes

Petitioner requests an exemption from the minimum safe altitude 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 1,000 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 to 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 the Petitioner’s 

Operating Documents. 

The proposed UAS Air Vehicles weigh less than 7 pounds each fully loaded and carry 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 conventional aircraft operating at or below 500 
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AGL performing similar operations. Additionally, the proposed low-altitude operations of the 

small UAS will 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 the 

elevation of the departure airport or an appropriate altimeter setting 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 at a ground-based on-screen display and, (4) where prior to each flight, a zero 

altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS (see 

Exemption No. 11062 , Docket No. FAA-2014-0352).

 

The UAS that Petitioner intends 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 circumstances similar to this Petition, 

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 required. Due 

to the proposed altitude limitations and the area of operations, a longer time for flight in 

daylight VFR operations is reasonable. The FAA has approved similar exemptions from the fuel 

requirements of § 91.151(a) for flight in day VFR conditions. The FAA determined that a 

requirement 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 with the reserve 

power recommended by the manufacturer if greater, would ensure an equivalent level of 

safety to the fuel requirements of § 91.151(a) (see Exemption No. 11213). Petitioner's 

operating documents impose this same requirement and an exemption from §91.151(a) for 

flight in VFR conditions is therefore appropriate.
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14 C.F.R. §91.203 (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 an 

appropriate and current airworthiness certificate and an 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 authorization 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 Vehicles weigh less than 7 pounds each fully loaded (2.8 pounds for the 

Phantom 3, and 6.5 pounds for the Inspire 1) and carry 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 pilot flying the UAS will have access to them to the extent they are 

applicable. The FAA has issued numerous exemptions to this regulation (see Exemptions 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 required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Petitioner is requesting an exemption 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. 

Maintenance 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 Vehicles can be landed immediately and will be 

operating from no higher than 400 feet AGL. 

As provided in the Alaris UAS Operations Manual, 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 any flight-critical components. The maintenance and inspection procedures 

required by Petitioner's Operating Documents ensure that an equivalent or higher level of 

safety will be achieved.

National Security 

This requested exemption does not present a national security issue. Given that the UAS are 

small and lightweight, have lost-link and contingency capabilities, operate at very low speeds, 
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have extremely small payload capacities and carry no flammable, explosive or otherwise 

dangerous materials, the operations pose no threat to national security. 

Summary For 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 substantial hazards associated with using conventional fixed-wing aircraft or, 

rotorcraft 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 and minimizing risk by reducing the public's exposure to the danger and 

emissions associated with using manned aircraft to perform similar aerial data collection

operations. Alaris' UAS are battery powered 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 significantly less danger to the pilot and other individuals on the 

ground than one involving a full size aircraft.

In consideration of the foregoing, this Petition for Exemption provides the FAA with the 

necessary justification for granting the requested exemptions to allow 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