Lora Headrick ALTEA, LLC 1520 Mammoth Drive Saint Paul, MO 63366 636-336-2720 lh@alteals
.com January 22, 2016
U
.S. Department ofTransportation Docket Operations 1200 New Jersey Ave. , SE Washington, DC 20590 Re: Submission ofRequest for Determination under Section 333 ofthe FAA Modernization and Reform Act and Exemptions under 14 C
.F
.R. Section 11.81 Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA"), ALTEA, LLC (ALTEA), a woman owned business, does hereby request a determination by the Secretary of Transportation authorizing conduct of commercial operations of its UAS for the purposes of aerial imaging, mapping, inspections, and sensing. Pending a grant of exemption, we will provide a broad spectrum of safe, low

-cost, aerial solutions. ALTEA will be using UAS manufactured by 3D Robotics (3DR) or DJI. Operations will be conducted within and under the safeguards outlined herein and as may be established by the FAA under FMRA Section 333(c). ALTEA also petitions for exemptions as necessary to effect the determination requested pursuant to FMRA Section 333. The attached documentation includes detailed exemption requests that demonstrate how these exemptions are in the public interest and will maintain the required level of safety
. Authorizing ALTEA to conduct commercial UAS operations would enhance community education and awareness of UAS. Further, operation of our UAS in these commercial operations are less disruptive, safer, and more cost effective than manned aviation equivalents due to the low altitude environment, given the size, speed and inherent risk of traditional commercial helicopter operations
. These commercial operations often occur in the unsafe areas of the height-velocity diagram requiring special precision and skill. ALTEA will conduct the commercial UAS operations in a manner that will meet, and in many cases exceed, the current level of safety of commercial helicopter operations. ALTEA will employ UAS that weigh under 10 lbs, have a low noise signature, and carry no volatile fuel, which will limit collateral damage in the event of catastrophic failure. The low expense of operation compared to cost prohibitive manned aviation alternatives allow a greater economic benefit to businesses
. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for these commercial purposes benefit the public interest in the following ways:• Reduces the collateral damage risks to life and property associated with low altitude helicopter operations in undesirable portions ofthe height-velocity envelope. • Increased public awareness regarding safe and responsible utilization ofUAS. • Increased economic wellbeing to local businesses via cost reductions
. • Enabling aerial business solutions to be available to a larger market. • Enhanced agriculture practices resulting in reduced environmental contamination from pesticide/fertilizer runoff and increased crop yields
. • More efficient and frequent inspection ofinfrastructure due to reduced cost. Additionally, ALTEA commits to hiring appropriately qualified military veterans, minority and disadvantaged applicants from the local community whenever possible. As a Managing Member ofALTEA, I appreciate your careful consideration in granting this exemption.

Lora Headrick, Managing Member ALTEA, LLC 1520 Mammoth Drive Saint Paul, MO 63366 636-336-2720 lh@alteals
.comTable ofContents I. Regulations

- Exemptions Requested II. Commercial Operation/Operator III
. Unmanned Aircraft System (UAS) IV. UAS Pilot-in

-Command (PIC) V
. Public Interest VI. Summary VII
. Appendix A: "UAS Operating Manuals and Specifications" I. Regulations -Exemptions requested Pursuant to 14 C
.P
.R. § 11.81(e), ALTEA, LLC (ALTEA) seeks exemption from the below mentioned regulations and provide reason as to why the exemption should be approved based on the level of safety at least equal to that ofwhich the rulesrequire. Pursuant to Section 333 ofPL 112-95 commonly known as the "FAA Modernization andReform Act of 2012", ALTEA, hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the purposes ofaerial imaging, mapping, inspections, and sensing
. Rules in which ALTEA seeks exemption: 

# • 14 C.P
.R. Part 21 Subpart H 

## • 14 C
.P
.R
. § 45
.23(b) 

## • 14 C.P
.R.§ 61.101 (e)(4)(5) 

## • 14 C
.P
.R
. § 61.113 (a) 

## • 14 C.P.R.§ 61.315 (a) 

## • 14 C.P
.R.§ 91.7(a) 

# • 14 C
.P.R. 91.9(b) 

## • 14 C.P .R
. § 91.109(a) 

## • 14 C
.F
.R
. § 91.119 

## • 14 C.P
.R.§ 91.121 

# • 14 C.P.R.§ 91.151(a) 

# • 14 C
.P.R.§ 91.405(a) 

## • 14 C
.P.R. § 91.407(a)(1) 

## • 14 C.P.R. § 91.409(a)(2) 

## • 14 C.P.R.§ 91.417(a) & (b)Rules and exemptions requests in detail:

• 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates
o Establishes: The procedural requirements for the Issuance of airworthiness certificates as required by 14 C.F.R
. § 91.203(a)(1) Given the small size ofthe UAS and the safeguards that will be taken as outline below, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the FMRA with consideration "of the size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS
."

• 14 C.F.R. § 45.23(b)- Aircraft Marking and Identification Requirements
o 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
. ALTEA' s UAS(s) will ensure compliance with § 45
.29(£) to meet the intent of the regulation by displaying the registration number in the largest practicable lettering
.
• 14 C.F.R. 61.101 (e)(4)(5) - Recreational Pilot Privilege and Limitations
o 14 C.F.R. § 61.101: (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft (4) For compensation or hire; (5) In furtherance ofa business ; Currently, there are no applicable areas identified for UAS in either the private or the commercial sector and therefore an exemption is required to conduct commercial operations. As flight operations will be conducted with a high degree of caution consistent with FAA pilot training and will follow the procedure outline below
. ALTEA' s operations will achieve an equivalent level of safety for each individual flight especially when compared to commercial flights identified in Part 61 when originally developed. ALTEA' s operations will be conducted by pilots who hold, at a minimum, an FAA pilot certificate ofany category or class and a 3rd class medical.

• 14 C.F.R. 61.113 (a) - Private and Commercial Pilot Privilege and Limitations
o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot incommand ofan aircraft in connection with any business oremployment. Currently: there are no applicable areas identified for UAS in either the private or the commercial sector and therefore an exemption is required to conduct commercial operations. As flight operations will be conducted with a high degree of caution consistent with FAA pilot training and will follow the procedure outline below. ALTEA's operations will achieve an equivalent level of safety for each individual flight especially when compared to commercial flights identified in Part 61 , when originally developed. ALTEA' s operations will be conducted by pilots who hold, at a minimum, an FAA pilot certificate ofany category or class and a 3rd class medical.
• 14 C.F.R. 61.315 (a)- What are the privileges and limits ofmy sport pilot certificate?
o (a) If you hold a sport pilot certificate you may act as pilot in command of a lightsport aircraft, except as specified in paragraph (c) ofthis section. As flight operations will be conducted with a high degree ofcaution consistent with FAA pilot training and will follow the procedure outline below. ALTEA's operations will achieve an equivalent level of safety for each individual flight especially when compared to commercial flights identified in Part 61 when originally developed. ALTEA's operations will be conducted by pilots who hold, at a minimum, an FAA pilot certificate ofany category or class and a 3rd class medical.
• 14 C.F.R. 91.7(a) - Civil Aircraft Airworthiness
o No person may operate a civil aircraft unless it is in an airworthy condition
. Daily pre and post flight inspections will be accomplished in accordance with manufactures maintenance manual(s) and guidance
. During flight, the PIC will adhere to 

### § 91.7(b) and abort air operations immediately upon identification of an in-flight emergency or other unsafe condition. By complying with procedures outlined by the manufacturer, an equivalent level ofsafety will be achieved.
• 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements
o (b)(2) prohibits operation ofU.S .-registered civil aircraft 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. By keeping all operating documents, manuals, authorizations and exemptions in a binder co-located with the GCS , ALTEA can meet the intent of the regulations and therefore achieve an equivalent level ofsafety
. • 14 C.F.R. 91.109(a) - Flight Instruction
o 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.The majority ofUAS by design are developed with single operational control through the use of pre-determined GPS enabled waypoints programmed before or during flight in addition to the use of a single hand held transmitter or control station controlled by the PIC. The design does not allow for dual controls during flight training and therefore the exemption is requested to train operators, build experience, and maintain proficiency
. An equal level of safety will be achieved by conducting all training in stile environment. Training sessions will be accomplished separately from flights conducted for compensation or hire.
• 14 C.F.R. 91.119 (c)- Minimum Safe Altitudes
o Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (b) 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 of2,000 feet ofthe 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. (d) Helicopters, powered parachutes, and weight-shift

-control aircraft. If the operation is conducted without hazard to persons or property on the surface- (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA. ALTEA ' s commercial UAS operations will be conducted at or below 400ft. AGL. Given the size, weight and lack of fuel ; combined with operation limitations listed below, the operation will be conducted with a greater level of safety than exists with current manned aviation operations
. • 14 C.F.R. 91.121- Altimeter Settings
o Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating
.. . ALTEA' s UAS are equipped with Global Positioning System (GPS), which provide altitude and geo-location data to the operator without utilizing an altimeter. Due to this fact, an exemption is required. GPS are precise within a few feet and combined with fail-safes and a visual observer the operation will meet an equivalent level ofsafety
. • 14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR Conditions
o No person may begin 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 ;This regulation is written based on the capabilities of a traditional aircraft, which have flight times of several hours or greater; therefore, with the majority of UAS which have flight times of only an hour or less, this regulation would effectively deny the ability of the air vehicle to operate. ALTEA's UAS display a visual and emit an audible low battery alert at which time the UA will automatically engage the landing sequence. Based upon that safeguard and the small operational area in VLOS , the operation can meet an equivalent level of safety
.
• 14 C.F.R. 91.405(a), 91.407(a)(l), 91.409(a)(2) and 91.417(a) & (b) -Maintenance Inspections
o 91.405(a) States: Each owner or operator of an aircraft-(a) 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 ofthis chapter. o 91.407(a)(l) States : (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-(1) 

### It has been approved for return to service by a person authorized under § 43.7 of this chapter. o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had-(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 ofthis chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an " annual" inspection in the required maintenance records
. o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (paragraphs 1 (i

- iii) , 2 (i- vi)) ; (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1 - 3). Because 3DR and DJI UAS at present do not have airworthiness certificates, these regulations do not apply and therefore an exemption is required. Pre/Post flight inspections and maintenance will be conducted in accordance with the manufacturer's guidance as stated in the operations manual. In addition, to meet the intent of these regulations, ALTEA will maintain daily logs of pre and post flight inspections. If maintenance is required, a dedicated test flight will be conducted to ensure safety before resuming commercial operations. All inspection, maintenance and alterations will be documented and maintained in a record. These actions will meet the intent of the regulations from which exemption is being requested and lead to an equivalent level of safety.II. Commercial Operator/Operation ALTEA requests that its PIC employees be exempt from § 61.113 (a) and (b) allowing operations of its UAS for compensation or hire, possessing only a pilot certificate and 3rct class medical. A pilot certificate will demonstrate a safe and equivalent level of aeronautical safety, judgment, security and responsibility to operate ALTEA' s UAS. In addition to being certified FAA Airmen, ALTEA will only utilize PICs who are knowledge

able in human factors awareness and risk management. For each flight, ALTEA ' s UAS PIC will: • Will contact the controlling air traffic organization to issue a NOT AM. • Will obtain a preflight briefing from a pilot briefer, DUATS , or similar means. • Will conduct a comprehensive worksite inspection and analysis, identif ying limits of customer property or authorized access areas. • Will conduct preflight planning in accordance with Section 91.103 PreflightAction. • Will operate in those areas only with the consent ofthe landowner or designated representative
. • Will identify potential obstructions or other hazards to safe operation. • Will clear the area of personnel or bystanders that are non-essential to the operation, maintaining at a minimum, 500 feet away from non-participating persons. • Will conduct a preflight safety briefing to Visual Observer (VO) and participating persons . • Will at all times yield to manned air traffic
. • Will operate within VLOS ofboth PIC 

### .a.wLVO during daylight hours only. • Will maintain voice communications with VO and participating persons. • Will operate under Class D visual flight rules, defined as 500 feet below and 2000 feet horizontal from clouds with a minimum of3 statute miles ofvisibility
. • Will not exceed an altitude 400 feet AGL as determined by the installed GPS. • Will keep operating documents, manuals, authorizations and exemptions in a binder colocated with the GCS
. • Will immediately terminate flight, in the safest manner possible, when safety to persons or property become compromised
. • Will terminate flight, in the safest manner possible, when unable to comply with these limitations or any other limitations granted as part ofthis exemption
. In order to remain at an altitude at or below 400 feet AGL, reliefis needed from Section 91.119 (c) and (d)
. By following these operating standards, the commercial operation will meet an equivalent level ofsafety to the regulation in which reliefis sought.

### III. Unmanned Aircraft System ALTEA seeks an exemption to operate the DJI Phantom 3 professional, 3DR Solo, 3DR X8

-M and 3DR Aero-M UAS. The 3DR solo is the primary aircraft in our operation for which we seek exemption. We will be acquiring the DJI Phantom 3 professional (Phantom 3), 3DR X8-M and Aero-M UAS at a later time and so wish to include those platforms in this exemption as well. The 3DR and DJI UAS utilize a common autopilot system and common ground control station software (GCS)
. The UAS will be flown via a combination of RC control, Tablet GCS , or PCbased GCS
. The Phantom 3, Solo and X8

-M are GPS equipped, multirotor helicopters
. The Phantom 3 and Solo is a quad-type utilizing four rotors with a max airspeed of 55 MPH (Solo) and 35 MPH (Phantom 3). The X8

-M is a quad

-type utilizing eight rotors in an "X" configuration a max airspeed of 25 MPH. The Aero -M is a GPS equipped, lightweight, foam, fixed wing aircraft with a minimum airspeed of 22 MPH and a max airspeed of 45 MPH
. The UAS are powered by lithium-polymer batteries. The UAS will carry Go Pro and other small cameras or sensors still keeping within the weight payload requirements. The Phantom 3, Solo and X8-M UAS have the capability to land at its current location with a dedicated switch
. The UAS also have several fail-safes for loss ofcommunications, loss of GPS , and low battery as outlined in the respective Operation Manuals
. The UAS display a visual and emit an audible low battery alert at 25% (3DR) or critically low level (DJI) at which time the UA will automatically engage the landing sequence. Based upon that safeguard, ALTEA requests exemption from Section 91
. 151 (b) Fuel requirements for flight in VFR conditions
. The UAS also have a geofence function, which will be programmed for a maximum altitude of 400 feet AGL and within the lateral boundaries of the worksite
. The UAS , except for the Aero-M, will not have an installed barometric altimeter and will rely on GPS to determine altitude and speed
. Given the aircraft will be operated within VLOS with the aid of aVO, ALTEA believes the operation can be conducted with an equivalent amount of safety and therefore request exemption from Section 91
. 121 UAS manuals and specifications are provided and attached here to by reference in Appendix A:
"UAS Operating Manuals and Specifications"
. Given the size, weight, speed, and controlled operating area associated with the UA to be utilized, an exemption from 14 CFR part 21 , Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) is requested
. ALTEA seeks exemption f rom§ 45
.23 Marking of the aircraft
. The UA will display the registration number in the largest practicable lettering. ALTEA wishes to be exempt from§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.41 7(a) and (b) Maintenance inspections will be conducted according to operations manual and prudent judgment as previously outlined to determine the integrity and safety of the UAS and associated equipment. Further, ALTEA requests relieffrom 91.7(a), which prohibits the operation ofan aircraft without an airworthiness certificate and 91.9(b) (2) requiring an approved flight manual in the aircraft
. The UAS will not be operating with an airworthiness certificate therefore, this would be inappropriate
. The UAS are too small to carry the operating documents so an equivalent amount ofsafety can be achieved through keeping the operating documents and manuals at the GCS.IV. UAS Pilot in Command CPIC) Under § 61.113 (a) and (b) private pilots are limited to non-commercial operations, however ALTEA can ensure its operation will achieve an equivalent level of safety as current regulation because ALTEA's UAS do not carry any pilots or passengers. A pilot certificate will not ensure RC piloting ability, as the psychomotor skills are different. The inherent risks ofoperating a UAS are far less than in the commercial activities outlined in 14 CFR part 61 , et seq. , thus ALTEA requests an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command All UAS PICs will have logged, in accordance with 61.51 (b), appropriate training on the UA consisting ?f 25 hours as UAS rotorcraft, 10 hours multirotor UAS or 25 hours as UAS airplane, 10 hours smgle

-engine as appropriate. PICs will maintain recent flight experience on the UAS. Training and experience flights will be conducted separate from commercial operations. PIC Training will consist of: • Pre-flight Tasks o Assembly and inspection ofUAS o Set-up and configuration ofRC radio and GCS o System checks • Mission Tasks o Takeoffand landing o Manual flight modes o Autonomous flight modes o Emergency Procedures • Post-flight Tasks o Inspection o Shutdown o Disassembly • Other Tasks o Regulations o Operating limitations o Flight planning V. Public Interest Given the above stated evidence, procedures, and precautions; ALTEA feels that operating their UAS commercially for the purposes of conducting aerial imaging, mapping, inspections, and sensing will ultimately be in the public interest. These operations, when executed with prudence, will exceed the current level of safety as the regulations from which ALTEA seeks exemption. ALTEA's operation will allow greater access to commercial aerial services that were not previously economically feasible for many firms
. This will provide a much needed economic uplift to the community and hence the public. ALTEA' s operation will be conducted with less risk of collateral damage to persons and property while limiting disruptive noise pollution associated with low altitude aviation operations. A major factor to consider regarding the public interest is the current state ofUAS operations in the US. As a manned aviator, the need to integrate UAS into the national airspace system in a safe, deliberate manner, is always at the forefront of my mind. While not all, many individuals operate UAS and model aircraft in a reckless manner out of either ignorance or carelessness, as

# I 11



# ~
evidenced by the increasing reports of manned-unmanned incursions and incidents such as the DJI Phantom that recently crashed on the White House lawn
. As the technology becomes more readily available, the challenges will intensify. By allowing commercial operations, it will enable communities to become educated in the proper use of this technology. ALTEA is already working to foster positive awareness and safe, responsible utilization of UAS technology. Granting ALTEA' s exemption will result in a direct extension of these efforts, which is in the public interest.


### VI. Summary Pursuant to Section 333 ofPL 112

-95 commonly known as the "FAA Modernization andReform Act of 20 12", ALTEA, hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the purposes ofaerial imaging, mapping, inspections, and sensing. Rules in which ALTEA seeks exemption: 

## • 14 C.F.R. Part 21 Subpart H 

# • 14 C.F .R. 

### § 45.23(b) 

## • 14 C
.F.R
. 

### § 61.101 (e)(4)(5) 

## • 14 C
.F
.R
. 

### § 61.113 (a) 

## • 14 C
.F.R. 

### § 61.315 (a) 

## • 14 C
.F.R. 

### § 91.7(a) 

# • 14 C
.F
.R. 91.9(b) 

# • 14 C
.F.R
. 

### § 91.109(a) 

## • 14 C.F .R. 

### § 91.119 

## • 14 C.F
.R
. 

### § 91.121 

## • 14 C
.F
.R. 

### § 91.151 (a) 

## • 14 C.F.R. 

### § 91.405(a) 

# • 14 C
.F.R. 

### § 91.407(a)(1) 

## • 14 C
.F
.R
. 

### § 91.409(a)(2) 

## • 14 C
.F
.R
. 

### § 91.417(a) & (b) Throughout this exemption request, ALTEA has demonstrated the expertise and knowledge with UAS technology and FARs that will ensure the public 's best interest is at hand and how ALTEA' S operation will aid in safely integrating civil UAS into the national airspace system.VII. Appendix A: "UAS**Operatin~** Manuals and Specifications"
The specifications and manuals for the 3DR Solo UAS can be found here: https ://3dr
.com/solo-gopro-drone-specs/ https:/ /3dr
.com/wp-content/uploads/20 16/0 1/v8 01 05 16.pdf The specifications and manuals for the 3DR X8-M UAS can be found here: https://3dr
.com/wp-content/uploads/20 15/04/XS-Operation-Manual-vC
.pdf https:/ /3dr.com/wp-content/uploads/20 15/04/XS-Checklist-vB.pdf The specifications and manuals for the 3DR Aero-M UAS can be found here: https://3dr.com/wp-content/uploads/2014/10/Aero-M-Spec-Sheet-v3.pdf https://3dr.com/wp-content/uploads/2015/04/AeroM-Operation-Manual-v3.pdf The specifications and manuals for the DJI Phantom 3 professional UAS can be found here: http://www.dji.com/product/phantom

-3-pro/info https://dl.djicdn.com/downloads/phantom 3/en/Phantom 3 Professional User Manual Vl.6.p df