Alex Ottolini Alexander Aerospace, LLC. P.O. Box 681375 Franklin, TN 37068-1375 alexottolini@gmail.com August 28, 2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor Room W12-140 1200 New JerseyAvenue, SE Washington, DC 20590 RE: Alexander Aerospace, LLC Petition for Exemption pursuantto Section 333 of the FAA Modernization and Reform Act of2012 To Whom It May Concern: I am writingto askthatyou consider myrequestfor 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 orderto facilitate the safest possible operations ofunmanned aerial vehicles and systems. Alexander Aerospace, LLC will also follow the rules laid outin previous exemptions granted bythe 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 outbelow. Regardless ofour requests, Alexander Aerospace, LLC will abide by any and all requirements and limitations setforth bythe 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

1GENERAL 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 ofthese operations will be similar to current manned aerial vehicle operations, while others will be newutilizations ofan incredibly fast moving technology. However, the use ofsmall unmanned systems will greatly increase safety when compared to manned aircraft operations. With a lack offlammable fuet operators, orpassengers on board, and the small size and visual line ofsight (VLOS) rules in place, riskto public safety is drastically reduced. Certain examples ofuse byAAero include, but are not limited to the following: photography and videography for private or commercial entities, land survey 

### I mapping 

### I plotting, agricultural assessments, wildlife tracking, and search and rescue 

### I emergency response. LIMITATIONS As per acceptance bythe FAA ofrecent Petitions ofExemption, the following list includes, but is notlimited to, operational limitations thatwill be adhered to:

• Operations will belimited to sUAV's 

### I sUAS's weighing less than 55 pounds including payload.

• The UA may notbe operated ata speed exceeding 87 knots (100 miles per hour). Use ofgroundspeed 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 bythe aircraft manufacturer.

• The UA will be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude mustbe reported in feet AGL.

• The UA will be operated within visual line ofsight (VLOS) ofthe 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 

### mayutilize a visual observer (VO). The UA mustbe operated within the visual line ofsight (VLOS) ofthe PIC orVO at all times. AVO may be used to satisfy theVLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC mustbe able to communicate verbally at all times; electronic messaging ortexting is notpermitted duringflight operations. The PIC mustbe designated before the flight and cannottransfer his or her designation for the duration ofthe flight. The PIC must ensurethat,

2ifutilized, the VO can perform the duties required ofthe VO. (This requirementhas been amended, referencing rules listed in Proposed 14 CFR Part 107. See NOTE 1 atthe endof 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 ofexemption, will hereinafterbe referred to as the operating documents. The operating documents mustbe accessible during UAS operations and made available to the Administrator upon request. Ifa 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 mustbe followed. Otherwise, the operator mustfollow 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 presentupdated and revised documents to theAdministrator or any law enforcement official upon request. The operator must also presentupdated and revised documents ifit petitions for extension or amendmentto a grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted an exemption, then the operator mustpetition for an amendmentto its grant ofexemption. The FAA's UAS Integration Office (AFS-80) maybe contacted ifquestions arise regarding updates or revisions to the operating documents.

• Any UAS thathas undergone maintenance or alterations that affect the UAS operation or flight characteristics, 

### e.g., replacement ofa flight critical component, must undergo a functional testflight priorto conducting further operations under this exemption. Functional test flights may onlybe conducted by a PIC with an optional VO and mustremain atleast 500 feet from other people. The functional testflight mustbe conducted in such a manner so as to notpose 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. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operatinguntil the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

3• The operator mustfollow 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 complywith all manufacturer safetybulletins.

• Under a grant ofexemption, a PIC musthold either an airline transport, commercial, private, recreational, or sportpilot 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 ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC must also meetthe flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated onhis 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 consistentwith 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 mustbe logged in a manner consistentwith 14 CFR § 61.51(b). Flights for the purposes oftrainingthe operator's PICs andVOs (training, proficiency, and experience-building) and determiningthe PIC's ability to safely operate the UAS in a manner consistentwith howthe UAS will be operated under an exemption are permitted under the terms ofan 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 notbe 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 ofan airportreference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) orfor airports not denoted with anARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreementwith that airport's managementis obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport management mustbe made available to the Administrator or anylaw enforcement official upon request.

4• The UA may notbe operated less than 500 feet below orless than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC.

• Ifthe UAS loses communications orloses its GPS signal, the UA mustreturn to a pre-determined location within the private or controlled-access property.

• The PIC must abortthe flight in the event ofunpredicted 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 conductthe intended operation and to operate after that for atleast 20% of the total flight time available, depending on aircraft configuration, or with the reserve power recommended bythe manufacturer ifgreater. (This requirementhas been amended, requesting thattheAdministrator take into consideration the differentpayload 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 NOTE2 atthe end of thissection.)

• Air Traffic Organization (ATO) Certificate ofWaiver orAuthorization (COA). All operations shall be conducted in accordance with an A TO-issued COA. The exemption holder may apply for a new or amended COA ifitintends to conduct operations that cannotbe conducted under the terms ofthe attached COA.

• All aircraft operated in accordance with this exemption mustbe identified by serial number, registered in accordance with 14 CFR part47, and have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings mustbe as large as practicable.

• Documents used bythe operatorto 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 atthe Ground Control Station ofthe UAS any time the aircraft is operating. These documents mustbe 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 notbe operatedbythe PIC from any moving device or vehicle thatis operating in excess of50 miles perhour. (This requirement has been amended, requesting that theAdministrator take into consideration operations from suitable watercraftor land vehicles, provided said operations follow

5alreadyset forthfor clearances from, distances from, andprotection of nonparticipatingpersons. See NOTE 3 atthe end of this section.)

• All Flight operations mustbe conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are presentthat sufficientlyprotect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuringthe safety ofnonparticipating persons; and b. The owner

### Icontroller ofany vessels, vehicles or structures has granted permission for operating closer to those objects andthe PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined thatit does notpresent an undue hazard. c. Flight operations maybe conducted closer than 500 feet from nonparticipatingpersons consenting to be involved, butnever operated directly overhead of anyone notdirectly involved in the operation. (This requirementhas been amended, requesting that theAdministrator take into consideration nonparticipating persons thatconsent to involvement. See NOTE4 atthe end of this section.) The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons underthis 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

### Icontroller or authorized representative will be obtained for each flight to be conducted.

• Any incident, accident, or flight operation thattransgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA mustbe reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Ifthis exemption permits operations for the purpose ofclosed-set motion picture andtelevision filming and production, the following additional conditions and limitations apply.

• The operator musthave a motion picture and television operations manual (MPTOM) as documented in this grant ofexemption.

6• At least 3 days before aerial filming, the operator ofthe UAS affected bythis exemption must submit a written Plan ofActivities to the local Flight Standards District Office (FSDO) withjurisdiction overthe area ofproposed filming. The 3-daynotification maybe waived with the concurrence ofthe FSDO. The plan ofactivities mustinclude atleastthe following: a. Dates and times for all flights; b. N arne and phone number ofthe operator for the UAS aerial filming conducted underthis grant ofexemption; c. Name and phone number ofthe person responsible for the on-scene operation of the UAS; d. Make, model, and serial or N-Number ofUAS to be used; e. Name and certificate number ofUAS PICs involved in the aerial filming; f. Astatementthatthe operatorhas obtained permission from property owners and/or local officials to conduct the filming production event; the list ofthose who gave permission mustbe made available to the inspector upon request; g. Signature ofexemption holder or representative; and h. Adescription ofthe 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 maybe conducted closer than 500 feet from participating persons consenting to beinvolved and necessaryfor the filming production, as specified in the exemption holder's MPTOM.

• Unless otherwise specified in this grant ofexemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, butnotlimited to, parts 45, 47, 61, and 91. Explanations ofamendments listed above (NOTE 1) Visual Observer: Per Proposed 14 CFR Part 107, a visual observer maybe used, butis notrequired. (NOTE 2) Power Reserves: This amendment requests the Administrator take into account the varying time offlight ofdifferent UAS platforms and payload configurations. In order to accurately assess power reserves, every combination ofplatform and payload available to AAero will be flight tested and timed to determine properpower reserves are available priorto commercial operation. Ground stations used will also include power reserve indications.

7(NOTE 3) Operation from Moving Devices: While itwill be uncommon, the opportunitymay 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 ofwater or area of land, AAero requests permission to assess the safety ofthe situation and make the determination regarding operation from a moving device. Current rules in regards to clearances from, distances from, and protection ofnonparticipating persons, and requirements for consent, will befollowed. (NOTE 4) "Nonparticipating Persons: Persons not directly involved with the operation ofthe UAS, butthat can consentto involvement with the product of the operation." This will allow operations nearer than 500 feet to nonparticipating persons at an eventthatinvolves a group ofpeople that consentto involvement. This is ultimately a requestfor 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 ofhighly 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 setforth byapplicable FARs andthe Administrator. Should an exemptionbe granted to Alexander Aerospace, LLC, registration ofUAs 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 requestbythe Administrator, an authorized representative ofthe National Transportation Safety Board, or any Federal, State, or local law enforcement officer. Specific uses ofAAero UAs will include:

• photography and videographyfor private or commercial entities • land survey 

### I mapping 

### I plotting • agricultural assessments • damage assessment for insurance • wildlife 

### I livestock tracking or search and locate • search and rescue 

### I emergency response (only atthe request ofa public agency, and only ifthe Administrator will approve quick response operations)

8This list should notbe considered complete, and the rate atwhich the UAV and UAS industry is progressingwill determine new uses and research byAAero. However, any commercial operation notlisted here, and found to be within the operational capabilities ofAAero, will be submitted as a requestfor amendmentto a granted Petition ofExemption, 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 ofthe country. Assessing crop needs, and being able to aid in search and location oflivestock are ideas we wantto pursue. To the east ofus, mountainous terrain creates an opportunityto use UAVs in place ofmanned aircraft in multiple scenarios, from marketing and sales to information and research, reducing costs for customers while extendingtheir own potential revenue. The number ofvisitors to the Great Smoky Mountains National Park, andthe potential for assistance needed in search and location, are other driving factors. The same region could benefitfrom wildlife tracking and assessments. Apartfrom 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 surveythe damage. The list goes on, butwe wantto provide a clearer picture ofour business direction. AAero maintenance operations will be conducted in the spirit ofthe maintenance requirements setforth in 14 CFR Part43 and Part 91, Subpart E, as applicable. This will be done to ensure the safety ofthe nonparticipating public, the safety ofthose who hire AAero for our services, and the safety ofAAero operations personnel. Maintenance will be logged, flight times and cycles ofmajor components calculated, and determinations ofmaintenance and preventative maintenance needed will be made and evaluated as more information presents itself. AAero will also adhere to manufacturers' Safety Bulletins, Recommended orAlert 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 ofanyissues that need to be addressed. All individuals working for AAero will be responsible for upholding these standards ofoperation. AAero and the aircraft they own will be insured, and will have in effect liability insurance coverage that ata minimum meets or exceeds the minimum motor vehicle insurance coverages for both property damage andbodily 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 ofsmall UAS's creates this result. A lack offlammable fuels needed for most sUAS's, especially when considering quantities, is a major factor in the increase ofsafety. On-board systems technology

9is advancing at an incredible pace, and even current systems provide for a very large margin ofsafety in unforeseen circumstances. When all ofthese things are coupled with the regulations that are and will be putin place bythe FAA, using sUAS's in place oflarge manned aircraft for similar commercial missions will simplybe safer. It is understood, however, that the ultimate responsibility will restwith the operator, and AAero will strive to be an example regarding regulatory compliance. Public privacy is ofthe utmostimportance to AAero. No operations in surveillance or unwanted photography or videography ofpeople or propertywill be carried out. Any incidental inclusion ofnon-consenting persons into information gained will not be submitted for commercial use. AIRCRAFT Alexander Aerospace, LLC will utilize the following aircraftfor our operations:

• DJI SpreadingWings S1000 (octocopter) o Operating frequency between 2.4 and 2.483 GHz o Operating weight ofapproximately 15 lbs o Approximately 42" in diameter, approximately 15" in height • DJI FSSO (hexacopter) o Operating frequency between 2.4 and 2.483 GHz o Operating weight ofapproximately 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 ofapproximately 7lbs o Wingspan approximately 58" CONCLUSION In conclusion, Alexander Aerospace, LLC respectfully petitions for exemption from the current FARs previously listed. It is notthe intent ofAAero to be held unaccountable byrequesting exemption, butto allowAAero to begin business as a commercial operator ofsmall unmanned aerial vehicles and systems, andto become an example bywhich to operate under guidance from the FAA. The FAA has a sizable and importanttask athand, developing and implementing the safe operation ofsaid aircraft and systems into the National Airspace System. AAero requests permission to be a part ofthattask 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

10Thankyou for your consideration.

Alex Ottolini CEO & Founder Alexander Aerospace, LLC

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