March 13, 2015

United States Department of Transportation

Docket Management System 

1200 New Jersey Ave, SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

RE: Exemption Request under Section 333 of the Federal Aviation Administration 

Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from: 

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 

(a)(l) and (2); 14 CFR 91.417(a) and (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of FAA Modernization Act of 2012 and 14 CFR Part 11, INNOVATIVE 

AIRWORKS, LLC operator of a training facility of specific models of DJI Small Unmanned 

Aircraft Systems (UAS) equipped with state of the art audio, video and data collection equipment;

hereby applies for an exemption from the listed Federal Aviation Regulations (FAR) to allow 

commercial operations of its UAS, so long as such operations are conducted within and under the 

conditions and limitations outlined herein or as may be established by the FAA as required by Section 

333. 

The ability to offer safe flight training to persons individually or belonging to both private and/or 

public organizations that have interests in the use and application of a UAS for the purpose of the 

safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for 

the protection of the persons and property. Therefore it is in the best interest of the Public for the 

FAA to approve the requested exemptions. 

 /s/

John King

INNOVATIVE AIRWORKS, LLC

President

157 Ram Dr.

Covington, GA 30014

(678)-314-4617
UNITED STATES OF AMERICA DEPARTMENT of TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

 Regulatory Docket No:_______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: INNOVATIVE 

AIRWORKS, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLLE: 14 OF THE CODE OF FEDERAL, REGULATIONS SECTIONS 61.113(a), 61.133(b), 

91.119(c), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1)&(2), 91.417(a), 121 CONCERNING 

OP.ERATION OF UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OFTHE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on March 13, 2015 

John King

INNOVATIVE AIRWORKS, LLC

President

157 Ram Dr.

Covington, GA 30014

(678)-314-4617
Table of Contents 

Glossary of Abbreviations 

List of Attachments 

Introduction and Interest of Petitioner 

Unmanned Aerial Systems 

Unmanned Aircraft Pilot in Command (PIC) 

Operations of sUAS 

Requested Exemptions from Regulations 

Public Interest 

Conclusion 
AGL 

ATC 

COA 

FAA 

FAR 

NAS 

PIC 

PQS 

Section 333 

SOP 

sUAS 

UA

UAS

VFR 

VMC 

VO 

VLOS 

Glossary of Abbreviations 

Above Ground Level 

Air Traffic Control 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

National Airspace System 

Pilot in Command 

Personnel Qualification System 

FAA Modernization and Reform Act of 2012, Section 333

Standard Operating Procedures 

Small Unmanned Aircraft Systems

Unmanned Aircraft

Unmanned Aircraft Systems

Visual Flight Rules 

Visual Meteorological Conditions 

Visual Observer 

Visual Line of Sight 
List of Attachments 

(1) DJI Phantom I User/OperatingManual

(2) DJI Phantom 2 Operating Manual 

(3) DJI Inspire Operating Manual

(4) DJI S800+ Operating Manual 

(5) DJI S900+ Operating Manual 

(6) DJI S1000+ Operating Manual

Innovative Airworks has chosen six models manufactured by DJI as their teaching and 

training platform and those models are listed above for which it is requesting the 

exemption.

Introduction and Interest of Petitioner 

Innovative Airworks is a veteran owned and operated company dedicated to the 

teaching and safe training/operation of UAS for individual and/or companies to 

enhance the safety of the NAS as well as for the protection of people and 

property.

Unmanned Aerial Systems 

Innovative Airworks will strictly adhere to the user/operating manual attached for 

the safe operation of their aircrafts. All procedures, such as pre-flight, inspections,

maintenance, and repair, will be conducted as specified by the manufacturer.

General Information Pertaining to All Proposed Flights

Innovative Airworks will operate less than fifty-five pound UAS, with the ability to 

conduct flight training. 

Prior to each flight the PIC shall inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft will be prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in aircraft records. 

Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics shall undergo a functional test flight in accordance 

with the manufacturer’s manual. The PIC who conducts the functional test flight shall 

make an entry in the UAS aircraft logbook of the flight. 

Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS shall comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 
Unmanned Aircraft Pilot in Command (PIC) 

All flight crewmembers, including PIC and VO, will have an understanding of, and comply 

with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, 

applicable to the airspace where the UAS will operate. Specifically all flight crew 

members will receive training on the rules and responsibilities described in 14 CFR Part 91 

Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot 

controller glossary, including standard ATC phraseology and communication. 

The PIC must possess at least a current private pilot certificate and third class medical 

certificate. The PIC must also meet the flight review requirements specified in 14 CFR 

Section 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 

A PIC will demonstrate a complete working knowledge of the UAV and will have 

accumulated a minimum of 10 hours of formal training and 10 hours of solo flight.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight 

(VLOS) requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times. This condition and limitation is 

consistent with all FAA approved Exemptions. 

Operations of UAS 

The UAS shall remain clear and yield the right of way to all other manned aviation 

operations and activities at all times. 

The UAS shall be operated at an altitude of no more than 400 feet above ground level 

(AGL) and shall not be flown at a ground speed exceeding 30 mph for quad copters. 

UAS Operations will be conducted under visual meteorological conditions (VFR). The 

UAS will not be operated less than 500 feet below or less than 2000 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, it must return to a predetermined location within the planned operating area and land or be recovered.

The UAS PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UAS with 25 battery power remaining. 

The UAS operated in accordance with this proposed exemption shall be identified by 

serial numbers, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as 

large as practicable. 

The UAS documents required under 14 CFR 9l.9 and 9l.203 shall be available to the PIC 

at the Ground Control Station of the UAS anytime the aircraft is operating. Those 

documents shall be available to the Administrator or any law enforcement official upon 

request. 

The UAS shall not be operated over congested or densely populated areas. These areas 

include but are not limited to the yellow areas depicted on World Aeronautical Charts 

(WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). 
Each training site will also be evaluated based on local conditions. 

Operations of UAS may be conducted at distances less than 500 feet from participating 

persons, vessels, vehicles or structures that perform an essential function in connection with 

these special purpose operations. Operations closer than 500 feet from the PIC, VO, 

operator trainees and essential persons are permitted when operationally necessary; but 

never so close to present an undue hazard. 

Operations of UAS may be conducted at distances less than 500 feet from unoccupied 

vessels, vehicles or structures owned by the land owner/controller when the land 

owner/controller grants such permission, and the PIC makes a safety assessment of the risk 

from operations and determines that it does not present an undue hazard to persons or 

property. 

Flight operations will be conducted at least 500 feet from all nonparticipating persons 

unless barriers or structures are present that sufficiently protect nonparticipating persons 

from the UAS and/or debris in the event of an accident. 

Q Q 

All operations of s UAS shall be conducted with the permission from the land 

owner/controller or authorized representative. Permission from the land owner/controller 

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

The UAS will not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator's COA. The letter of agreement with the airport 

management will be made available to the Administrator upon request. 

The UAS must be operated within VLOS of the PIC and VO at all times. This requires the 

PIC to be able to use human vision to see the UAS unaided by any device other than 

corrective lenses, as specified on the PIC's FAA issued medical certificate. 

All UAS operations must utilize a VO. 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. The PIC and VO must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. 
Requested Exemptions from Regulations

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 Lbs. Fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety

requirements. These safety enhancements provide a greater degree of safety to the 

public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by 

the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

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. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on 

which the word "Experimental" can be placed. Given the size of the UAS, two-inch 

lettering will be impossible. The word "Experimental" will be placed on the fuselage 

in compliance with §45.29 (f). 
14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate 

may act as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire. An equivalent level of safety may be achieved by current 

Regulations because the applicant's UAS do not carry any pilots or passengers nor 

property. The risks attendant to the operation of UAS is far less than the risk levels 

inherent in the commercial activities outlined in 14 CFR 61

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. Given the size of the aircraft for maintenance and use of 

safety check lists prior to each flight an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... 

(2) 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. The UAS, given its size and configuration has no ability or place 

to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. The 

equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions as 

stated in the FOM in Section 4 under Normal Procedures including but not limited to 

reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 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. UAS and remotely piloted aircraft, by their design do not 

have fully functional dual controls. 
Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight 

instruction in experimental aircraft. The equivalent level of safety provided by the fact 

that neither a pilot nor passengers will be carried in the aircraft and by the size and 

speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

(d) allows helicopters to be operated at less than the minimums prescribed, provided

the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL.

The equivalent level of safety will be achieved given the size, weight, speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to 

the property owner and participants in the filming activity, all affected individuals will 

be aware of the planned flight operations. Compared to flight operations with aircraft 

or rotorcraft weighting far more than the maximum 551bs. proposed herein and the 

lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft operating at or below 500 AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between these 

UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set " to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

safety check list and live flight data monitoring, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

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 powering the UAS provides approximately 30 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS 

flights would be limited to approximately 10 minutes in length. Given the 

limitations on the UAS's proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight 

or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. Operating the UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed 

waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given 

the size and speed of the small UAS. Additionally, limiting UAS flights to 10 

minutes would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25 of battery power- whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing 

zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b):Carrying 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 within it the following: 

(1) An appropriate and current airworthiness 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 UAS fully loaded weighs no more than 55 Lbs. and is operated without an 

onboard pilot, As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the UAS will have immediate access 

to them, to the extent they are applicable to the UAS. 
14 C.F.R.§91.405 (a); 407(a) (1);409 (a)(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. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook. 

An equivalent level of safety will be achieved because the UAS is very limited in size 

and will carry a small payload and operate only in restricted areas for a limited period 

of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log 

of any maintenance performed. Moreover, the operator is the person most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the UAS Manufacturer's User Manual. As 

provided in the FOM, the operator will ensure that the UAS is in working order prior 

to initiating flight and perform required maintenance needed. 

Additional Information 

The applicant, John King, has been involved in the building and piloting of remote 

controlled aircraft for many years. 

Also, the primary pilot/instructor, Mr. King holds a multi engine, IFR commercial pilot 

certificate and has an in-depth understanding of the capabilities and safety concerns 

involved in using this technology as an asset to the community. Satisfaction of criteria 

provided in Section 333 of the Reform Act of 2012 provide more than adequate 

justification for the grant of the requested exemptions allowing the commercial 

operation of the applicant's UAS. 
CONCLUSION 

As set forth above, Innovative Airworks LLC, seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of2012, 

which will permit safe operation of the above-named UAS commercially for the 

purpose of conducting proper teaching and training over other than congested areas. 

By granting this Petition, the FAA will allow Innovative Airworks LLC to safely, 

effectively and efficiently operate UAS commercially. 

Submitted March 13, 2015 

Respectfully submitted, 

John King

INNOVATIVE AIRWORKS, LLC

President

157 Ram Dr.

Covington, GA 30014

(678)-314-4617
ATTACHMENTS