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Alex Ottolini

Alexander Aerospace, LLC.

P.O. Box 681375

Franklin, TN 37068-1375

alexottolini@gmail.com

August 28, 2015

U.S. Department of Transportation

Docket Operations West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Alexander Aerospace, LLC Petition for Exemption pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012

To Whom It May Concern:

I am writing to ask that you consider my request for exemption from the following

Parts of 14 CFR, per Public Law 112-95, Section 333: 21 Part H, 61.23 (a) & (c),

61.101 (e) (4) & (5), 61.113 (a), 61.315 (c) (1), (2) & (3), 91.119, 91.121, 91.151,

91.405, 91.407, 91.409, 91.417.

Although we request exemption from the above mentioned Parts of 14 CFR,

Alexander Aerospace, LLC will adhere to 14 CFR Parts 43, 45, 47, 61, and 91 as

closely and practically as possible, even when exempt, in order to facilitate the

safest possible operations of unmanned aerial vehicles and systems.

Alexander Aerospace, LLC will also follow the rules laid out in previous exemptions

granted by the Administrator. We have used those exemptions, as well as the

requirements outlined in Proposed 14 CFR Part 107, as a basis for our request laid

out below. Regardless of our requests, Alexander Aerospace, LLC will abide by any

and all requirements and limitations set forth by the Administrator should our

petition for exemption be approved.

The petition is organized as follows:

GENERAL OPERATIONS

LIMITATIONS

EXPLANATION OF AMENDMENTS

SPECIFIC OPERATIONS

AIRCRAFT

CONCLUSION

NOTES
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GENERAL OPERATIONS

Alexander Aerospace, LLC, subsequently referred to as AAero in this document, will

utilize small unmanned aerial vehicles and systems to carry out commercial aviation

operations. Some of these operations will be similar to current manned aerial

vehicle operations, while others will be new utilizations of an incredibly fast moving

technology. However, the use of small unmanned systems will greatly increase

safety when compared to manned aircraft operations. With a lack of flammable fuel,

operators, or passengers on board, and the small size and visual line of sight (VLOS)

rules in place, risk to public safety is drastically reduced.

Certain examples of use by AAero include, but are not limited to the following:

photography and videography for private or commercial entities, land survey /

mapping / plotting, agricultural assessments, wildlife tracking, and search and

rescue / emergency response.

LIMITATIONS

As per acceptance by the FAA of recent Petitions of Exemption, the following list

includes, but is not limited to, operational limitations that will be adhered to:

• Operations will be limited to sUAV’s / sUAS’s weighing less than 55 pounds

including payload.

• The UA may not be operated at a speed exceeding 87 knots (100 miles per

hour). Use of groundspeed or calibrated airspeed to determine the 87 knot

speed restriction will be complied with. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airspeed recommended

by the aircraft manufacturer.

• The UA will be operated at an altitude of no more than 400 feet above ground

level (AGL). Altitude must be reported in feet AGL.

• The UA will be operated within visual line of sight (VLOS) of the PIC at all

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

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

airman medical certificate or U.S. driver’s license.

• All operations may utilize a visual observer (VO). The UA must be operated

within the visual line of sight (VLOS) of the PIC or VO at all times. A 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,
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if utilized, the VO can perform the duties required of the VO. (This

requirement has been amended, referencing rules listed in Proposed 14 CFR

Part 107. See NOTE 1 at the end of this section.)

• An exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in a

grant of exemption, will hereinafter be referred to as the operating

documents. The operating documents must be accessible during UAS

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

discrepancy exists between the conditions and limitations in the exemption

and the procedures outlined in the operating documents, the conditions and

limitations herein 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 or any law enforcement official upon

request. The operator must also present updated and revised documents if it

petitions for extension or amendment to a grant of exemption. If the operator

determines that any update or revision would affect the basis upon which the

FAA granted an exemption, then the operator must petition for an

amendment to its grant of exemption. The FAA’s UAS Integration Office

(AFS−80) may be contacted if questions arise regarding updates or revisions

to the operating documents.

• 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 prior to conducting further

operations under this exemption. Functional test flights may only be

conducted by a PIC with an optional VO and must remain at least 500 feet

from other people. The functional test flight must be conducted in such a

manner so as to not pose an undue hazard to persons and property.

• The operator is responsible for maintaining and inspecting the UAS to ensure

that it is in a condition for safe operation.

• Prior to each flight, the PIC must conduct a pre-flight inspection and

determine the UAS is in a condition for safe flight. The pre-flight inspection

must account for all potential discrepancies, e.g., inoperable components,

items, or equipment. 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.
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• The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

• Each UAS operated under an exemption must comply with all manufacturer

safety bulletins.

• Under a grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also

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. The PIC must also meet the flight

review requirements specified in 14 CFR § 61.56 in an aircraft in which the

PIC is rated on his or her pilot certificate.

• The operator will not permit any PIC to operate unless the PIC demonstrates

the ability to safely operate the UAS in a manner consistent with how the UAS

will be operated under an 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). Flights for the

purposes of training the operator’s PICs and VOs (training, proficiency, and

experience-building) and determining the PIC’s ability to safely operate the

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

exemption are permitted under the terms of an exemption. However,

training operations may only be conducted during dedicated training

sessions. During training, proficiency, and experience-building flights, all

persons not essential for flight operations are considered nonparticipants,

and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 CFR § 91.119.

• UAS operations will not be conducted during night, as defined in 14 CFR § 1.1.

All operations will be conducted under visual meteorological conditions

(VMC). Flights under special visual flight rules (SVFR) are not authorized.

• 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.
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• The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from

the PIC.

• If the UAS loses communications or loses its GPS signal, the UA must return

to a pre-determined location within the private or controlled-access property.

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

emergencies.

• 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 20% of

the total flight time available, depending on aircraft configuration, or with the

reserve power recommended by the manufacturer if greater. (This

requirement has been amended, requesting that the Administrator take into

consideration the different payload configurations of different aircraft and the

effects these configurations have on power usage, and allow a variable

application of reserve power time limits based upon these configurations. See

NOTE 2 at the end of this section.)

• Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

All operations shall be conducted in accordance with an ATO-issued COA. The

exemption holder may apply for a new or amended COA if it intends to

conduct operations that cannot be conducted under the terms of the attached

COA.

• All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have

identification (N−Number) markings in accordance with 14 CFR part 45,

Subpart C. Markings must be as large as practicable.

• Documents used by the operator to ensure the safe operation and flight of

the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must

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

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

Administrator or any law enforcement official upon request.

• The UA must remain clear and give way to all manned aviation operations

and activities at all times.

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

that is operating in excess of 50 miles per hour. (This requirement has been

amended, requesting that the Administrator take into consideration operations

from suitable watercraft or land vehicles, provided said operations follow
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already set forth for clearances from, distances from, and protection of

nonparticipating persons. See NOTE 3 at the end of this section.)

• All Flight operations must be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from the UA and/or debris in the event of an

accident. The operator must ensure that nonparticipating persons

remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500

feet of the UA, flight operations must cease immediately in a manner

ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has

granted permission for operating closer to those objects and the PIC

has made a safety assessment of the risk of operating closer to those

objects and determined that it does not present an undue hazard.

c. Flight operations may be conducted closer than 500 feet from

nonparticipating persons consenting to be involved, but never operated

directly overhead of anyone not directly involved in the operation. (This

requirement has been amended, requesting that the Administrator take

into consideration nonparticipating persons that consent to

involvement. See NOTE 4 at the end of this section.)

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

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

with permission from the property owner/controller or authorized

representative. Permission from property owner/controller or authorized

representative will be obtained for each flight to be conducted.

• Any incident, accident, or flight operation that transgresses the lateral or

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

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

hours. Accidents must be reported to the National Transportation Safety

Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture

and television filming and production, the following additional conditions and

limitations apply.

• The operator must have a motion picture and television operations manual

(MPTOM) as documented in this grant of exemption.
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• At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight

Standards District Office (FSDO) with jurisdiction over the area of proposed

filming. The 3-day notification may be waived with the concurrence of the

FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming

conducted

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene

operation of

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial

filming;

f. A statement that the operator has obtained permission from

property owners and/or local officials to conduct the filming

production event; the list of those who gave permission must be made

available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of

any area, city, town, county, and/or state over which filming will be

conducted and the altitudes essential to accomplish the operation.

• Flight operations may be conducted closer than 500 feet from participating

persons consenting to be involved and necessary for the filming production,

as specified in the exemption holder’s MPTOM.

• Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC,

and the UAS operations must comply with all applicable parts of 14 CFR

including, but not limited to, parts 45, 47, 61, and 91.

Explanations of amendments listed above

(NOTE 1) Visual Observer: Per Proposed 14 CFR Part 107, a visual observer

may be used, but is not required.

(NOTE 2) Power Reserves: This amendment requests the Administrator take

into account the varying time of flight of different UAS platforms and payload

configurations. In order to accurately assess power reserves, every combination

of platform and payload available to AAero will be flight tested and timed to

determine proper power reserves are available prior to commercial operation.

Ground stations used will also include power reserve indications.
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(NOTE 3) Operation from Moving Devices: While it will be uncommon, the

opportunity may arise where operation from a moving vehicle might be

requested or necessary. When this operation poses no additional risk to the

public, such as taking place over a large, unpopulated body of water or area of

land, AAero requests permission to assess the safety of the situation and make

the determination regarding operation from a moving device. Current rules in

regards to clearances from, distances from, and protection of nonparticipating

persons, and requirements for consent, will be followed.

(NOTE 4) “Nonparticipating Persons: Persons not directly involved with the

operation of the UAS, but that can consent to involvement with the product of

the operation.” This will allow operations nearer than 500 feet to

nonparticipating persons at an event that involves a group of people that

consent to involvement. This is ultimately a request for exemption from 14 CFR

91.119 (a), (b), and (c) for operations involving consenting nonparticipating

persons.

SPECIFIC OPERATIONS

All AAero operations will be overseen, directly or indirectly, by company owner and

founder Alex Ottolini. Alex is a certified Private Pilot and is a professional Airframe

& Powerplant Mechanic, with over six years and 4000 hours maintaining and

troubleshooting multiple makes and models of highly complex turbine engines and

turbine engine systems. He currently works for a Part 145 repair station ensuring

FAR compliance and performing administrative functions. He has also flown and

been involved with both manned and unmanned aerial vehicles for fifteen years.

Commercial and training flight operations will be conducted explicitly within the

requirements and limitations set forth by applicable FARs and the Administrator.

Should an exemption be granted to Alexander Aerospace, LLC, registration of UAs

and an application for applicable civil COAs will commence. Training requirements,

PIC currency, personnel requirements, and all other required operational processes

will be documented and stored, and will be available for inspection upon a

reasonable request by the Administrator, an authorized representative of the

National Transportation Safety Board, or any Federal, State, or local law

enforcement officer. Specific uses of AAero UAs will include:

 photography and videography for private or commercial entities

 land survey / mapping / plotting

 agricultural assessments

 damage assessment for insurance

 wildlife / livestock tracking or search and locate

 search and rescue / emergency response (only at the request of a public

agency, and only if the Administrator will approve quick response

operations)
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This list should not be considered complete, and the rate at which the UAV and UAS

industry is progressing will determine new uses and research by AAero. However,

any commercial operation not listed here, and found to be within the operational

capabilities of AAero, will be submitted as a request for amendment to a granted

Petition of Exemption, should AAero be approved.

The specific uses listed above are largely derived from the location from which we

base our operations. Living in central Tennessee, we have access to a large

agricultural region of the country. Assessing crop needs, and being able to aid in

search and location of livestock are ideas we want to pursue. To the east of us,

mountainous terrain creates an opportunity to use UAVs in place of manned aircraft

in multiple scenarios, from marketing and sales to information and research,

reducing costs for customers while extending their own potential revenue. The

number of visitors to the Great Smoky Mountains National Park, and the potential

for assistance needed in search and location, are other driving factors. The same

region could benefit from wildlife tracking and assessments. Apart from specific

locations, all areas are susceptible to natural disaster. UAVs can aid in information

gathering and search and rescue where neither people on foot nor manned aircraft

can safely survey the damage. The list goes on, but we want to provide a clearer

picture of our business direction.

AAero maintenance operations will be conducted in the spirit of the maintenance

requirements set forth in 14 CFR Part 43 and Part 91, Subpart E, as applicable. This

will be done to ensure the safety of the nonparticipating public, the safety of those

who hire AAero for our services, and the safety of AAero operations personnel.

Maintenance will be logged, flight times and cycles of major components calculated,

and determinations of maintenance and preventative maintenance needed will be

made and evaluated as more information presents itself. AAero will also adhere to

manufacturers’ Safety Bulletins, Recommended or Alert Service Bulletins,

Airworthiness Directives, or any other manufacturer or FAA required maintenance

publications. We intend to work closely with manufacturers, relaying pertinent

information from the field to help improve quality, reliability, and safety, and to

inform the manufacturers of any issues that need to be addressed. All individuals

working for AAero will be responsible for upholding these standards of operation.

AAero and the aircraft they own will be insured, and will have in effect liability

insurance coverage that at a minimum meets or exceeds the minimum motor vehicle

insurance coverages for both property damage and bodily injury required in the

state in which the operation occurs. The coverage will be specific to small

unmanned aerial vehicles and systems.

Safety is a critical concern to AAero. Small unmanned aerial vehicles , when used in

comparable capacities to manned aircraft, will inherently pose a much smaller

threat to the general public. The very nature of small UAS’s creates this result. A

lack of flammable fuels needed for most sUAS’s, especially when considering

quantities, is a major factor in the increase of safety. On-board systems technology
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is advancing at an incredible pace, and even current systems provide for a very large

margin of safety in unforeseen circumstances. When all of these things are coupled

with the regulations that are and will be put in place by the FAA, using sUAS’s in

place of large manned aircraft for similar commercial missions will simply be safer.

It is understood, however, that the ultimate responsibility will rest with the

operator, and AAero will strive to be an example regarding regulatory compliance.

Public privacy is of the utmost importance to AAero. No operations in surveillance

or unwanted photography or videography of people or property will be carried out.

Any incidental inclusion of non-consenting persons into information gained will not

be submitted for commercial use.

AIRCRAFT

Alexander Aerospace, LLC will utilize the following aircraft for our operations:

• DJI Spreading Wings S1000 (octocopter)

o Operating frequency between 2.4 and 2.483 GHz

o Operating weight of approximately 15 lbs

o Approximately 42” in diameter, approximately 15” in height

• DJI F550 (hexacopter)

o Operating frequency between 2.4 and 2.483 GHz

o Operating weight of approximately 5 lbs

o Approximately 24” in diameter, approximately 9” in height

• Quest Q200 (fixed wing)

o Operating frequency between 2.4 and 2.483 GHz

o Operating weight of approximately 7 lbs

o Wingspan approximately 58”

CONCLUSION

In conclusion, Alexander Aerospace, LLC respectfully petitions for exemption from

the current FARs previously listed. It is not the intent of AAero to be held

unaccountable by requesting exemption, but to allow AAero to begin business as a

commercial operator of small unmanned aerial vehicles and systems, and to become

an example by which to operate under guidance from the FAA. The FAA has a

sizable and important task at hand, developing and implementing the safe operation

of said aircraft and systems into the National Airspace System. AAero requests

permission to be a part of that task.

This petition for exemption was composed using the following petitions and FAA

acceptance letters as examples:

 Exemption No. 12009, Regulatory Docket No. FAA–2015-1466

 Exemption No. 11954, Regulatory Docket No. FAA–2015–1402

 Exemption No. 11172A, Regulatory Docket No. FAA-2014-0787
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Thank you for your consideration.

Regards,

Alex Ottolini

CEO & Founder

Alexander Aerospace, LLC