Steve Massar - Chief Pilot 23 February 2016

RotorWorks,LLC

165 Commodore Path

Hiram, Georgia 30141

smassar@rotorworksllc.com

(843)860-6111

The following memo is an Exemption Request Under Section 333 of the FAA Reform Act and Part 11

The following are specific sections of 14 CFR that RotorWorks,LLC is asking for exemption:

14 CFR Part 21, (H) - Airworthiness Certificates

14 CFR 45.23(b) - Marking of the Aircraft

14 CFR 91.7(a) - Civil Aircraft Worthiness

14 CFR 91.9(b)(2) - Civil Aircraft Flight Manual in the Aircraft

14 CFR 91.109 - Flight Instruction

14 CFR 91.119 - Minimum Safe Altitudes

14 CFR 91.121 - Altimeter Settings

14 CFR 91.151(a) - Fuel Requirements for Flight in VFR conditions

14 CFR 91.203(a) & (b) - Carrying Civil Aircraft Certification & Registration

14 CFR 91.405(a) - Maintenance Inspections

14 CFR 407(a) (1) - Maintenance Inspections

14 CFR 409(a) (2) - Maintenance Inspections

14 CFR 417(a) & (b) - Maintenance Inspections

The extent and the reason of the relief Rotorworks,LLC seeks, is as follows:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

CFR Part 11, RotorWorks, a Part 135 Helicopter Operator, (R96A299L) hereby applies for an exemption 

from the listed Federal Aviation Regulations, in order to allow commercial operation of its UAS's, so 

long as such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

See Appendix A - Exemption Request and Equivalent Level of Safety
Benefit to the public:

RotorWorks would like to operate small unmanned UAS's under controlled conditions, in order to 

augment its helicopter powerline patrol, aerial surveying, and motion picture and television flight 

operations . While helicopter patrols, with our current assortment of mission camera equipment 

(camera, video, Infrared, corona) has excellent capability, we feel that the addition of UAS's with

comparable mission equipment, can successfully deliver a more comprehensive recorded assessment of

specific impending maintenance powerline equipment problems. We would deploy the UAS when a 

more comprehensive view is required, which would be difficult to obtain from a helicopter platform. 

Such an operation would clearly create a much smaller flight signature for a comprehensive inspection. 

This would facilitate our desire to maintain a friendly and neighborly relationship with all private or 

commercial property owners that maintain close proximity to our clients transmission line right of ways. 

This benefit would enhance our inspection deliverables to our clients, and have less impact on the 

general public during our data gathering operation. This would also be true for all aerial survey and 

motion picture flight operations.

RotorWorks will operate one of the following UAS's that have prior FAA section 333 exemption

approval:

Altus UAS Delta X-8 UAV Solutions - Phoenix 60

DJI - Phantom 2 UAV Solutions - Phoenix 60LE

DJI - Phantom 3 Pulse Aerospace - Vapor 

DJI - Inspire 1 Pulse Aerospace - Scout B1-100

DJI - F450 Riegl RiCopter 

DJI - F550 SenseFly - eXom

DJI - S800 SteadiDrone - Vader

DJI - S900 SteadiDrone - Mavrik

DJI - S1000 SteadiDrone - Flare

DJI - S1000+ Turbo Ace - Cinewing 6

DJI - Matrix 100 Turbo Ace - Matrix G

Yuneec - Q500 Typhon Turbo Ace - Matrix I

Yuneec - Tornado H920 Turbo Ace - Matrix E

DragonFlyer X4-P Turbo Ace - Matrix S

Microdrones MD4 Viking UAS - VikingOne

Skycatch Viking UAS - Patriot X4

AeroCine Kopterworx Hammer X12 Viking UAS - Patriot X8

AeroVironment Qube Viking UAS - Ranger EX

Aeryon Scout Viking UAS - VK X6 Model 800

CarbonCore - Cortex ARTF Volt Aerial Robotics - Venture

Cyber Technology - Cyber Quad Vulcan - Mantis

DraganFlyer - X6 Vulcan - Black Widow

DraganFlyer - Guardian Vulcan - Raven

DraganFlyer - Commander Walkera - QR X350PRO

KongCopter FQ700 Walkera - Scout X4

Lockheed Martin - Indago Walkera - Tali H500

Microdrones - MD4-200 Walkera - QR - X800

Microdrones - MD4-1000 Walkera - QR - X900

Microdrones - MD4-3000 Walkera - Voyager 3

UAV Solutions - Phoenix 30

RotorWorks - page 2
Safety

RotorWorks is a helicopter Part 135 Operator, certificate number R96A299L, based in Hiram, Georgia. 

RotorWorks has a very active safety program administered by the Director of Safety. Our program 

includes a top down safety philosophy, safety manual, SMS program, individual SOP's for each 

operation, monthly safety meetings with full participation. RotorWorks conducts annual external safety 

audits which is a requirement of many clients. RotorWorks was issued a certificate of registration for 

successful implementation of the International Standard for Business Aircraft Operations (IS-BAO), 31 

July 2014.

All RotorWorks flights require completion of a Risk Assement work sheet prior to departure, in order to 

mitigate all flight hazards and any possible adverse conditions (weather, crew rest, experience, air 

space,etc.). All company aircraft are equipped with an online flight tracking system, Spidertracks, which 

allows designated flight followers to track missions at all times. 

RotorWorks current pilots are Steve Massar (Chief Pilot) and Mark Caffrey (Director of Operations). 

Both pilots are Commercial Rotorcraft rated, with over 7,000 flight hours each. These pilots will be

RotorWorks UAS operators.

All UAS operations will be performed under the safety program that RotorWorks currently has in place. 

RotorWorks has a comprehensive safety program with very experienced Commercial Pilots. We can 

ensure that the combination of RotorWorks Safety Program and the experience and knowledge base of 

its fully qualified pilots, along with strict operation under the guidelines established, will provide the FAA 

with a high level of confidence that UAS deployment will meet or exceed the level of safety in manned 

aircraft performing the same mission.

RotorWorks intend to follow these, and all other COA limitations:

*UAS will weigh less than 55 lbs.

*UAS will always be operated within line of sight of the operator

*UAS will be operated at an altitude no greater than 400' AGL

*RotorWorks is responsible for maintaining and inspecting the UAS to ensure that it is in a 

 condition for safe operation

*RotorWorks will perform a comprehensive preflight prior to each UAS flight

*RotorWorks will follow the UAS manufacturer's maintenance, overhaul, replacement, 

 inspection, and life limit requirements for the UAS

*All operators will be rated pilots

*If UAS loses communications or loses its GPS signal, the UAS will return to a predetermined 

 location

*UAS must remain clear and give way to all manned aviation operations and activities

*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 within 24 hours

RotorWorks - page 3
Summary

RotorWorks hereby provides, pursuant to Part 11, a summary of its application to allow commercial use 

of UAS's in the National Airspace System (NAS). The following regulations are what we are requesting 

for exemption: 14 CFR Part 21, (H) , 14 CFR 45.23(b), 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 14 CFR 

407(a) (1) 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203(a) & (b), 14 CFR 

91.405(a), 14 CFR 407(a) (1), 14 CFR 409(a) (2), 14 CFR 417(a) & (b).

RotorWorks is a Part 135 Helicopter Operator, whose main clients are the Transmission power 

companies that employ us to inspect their power grids. We currently perform these functions with 

single engine turbine helicopters and would like to augment our inspections, aerial surveying and 

motion picture flight operations, when necessary and prudent, with the use of UAS's. The use of UAS's 

will, in most cases, allow RotorWorks to obtain a much more detailed inspection of customer 

equipment, with a smaller flight signature and near zero human risk. This exemption would allow 

RotorWorks to do so.

Additional Information:

see appendix A 

RotorWorks has no intention on using this exemption outside of the United States.

Thank you for your consideration of our request for exemption. Please feel free to contact me any time 

if additional information or clarifications are required.

Regards,

Steve Massar

Chief Pilot - RotorWorks,LLC

165 Commodore Path

Hiram, GA 30141

smassar@rotorworksllc.com

(843)860-6111

RotorWorks - page 4
Appendix A

Exemption Requests and Equivalent Level of Safety

14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance

of airworthiness certificates as required by FAR §91.203(a) (1).

Due to the fact that there will be no airworthiness certificate issued for any UAS, no FAA regulatory standard will 

exist for determining airworthiness. Given the size and limited operating area associated with the aircraft to be 

utilized by the exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety. Section 

333 authorizes the exemption of 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 UAS operation. The 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 operating with an airworthiness certificate without the restrictions and conditions 

proposed.

Any UAS to be operated will be less than 55 lbs fully loaded, carries no humans, carries no explosive materials or 

flammable liquids, and operates within a controlled area as set out in the limitations. Unlike other civil aircraft, 

Operations under this exemption will be tightly controlled and monitored by the operator as per limitations issued 

through the COA.

14 CFR § 45.23 (b). Marking of the Aircraft

The regulation requires that 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). The equivalent level of safety will be provided by having the UAS marked

"Experimental" on its fuselage where the operator working with the UAS will see the identification. The FAA has 

issued the following exemptions on prior COA's.

14 CFR §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 and the

issued limitations and requirements, contained for maintenance and use of safety check lists prior to each

flight, an equivalent level of safety will be provided.
14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft.

The regulation requires that 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 operator flying the UAS will have immediate access to it. The FAA has issued the following exemptions 

on prior COA's.

14 CFR §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.

UASs 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 CFR §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 request is for a UAS that will have the authority to operate at altitudes up to 400' AGL, an exemption may 

be needed. As set forth, except for the limited conditions that may be stated in the COA, the UAS will never 

operate at higher than 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. Low-altitude operations of the UAS will ensure separation 

between these and conventional aircraft.

14 CFR §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." 

Most UAS are not equipped with 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 Procedures and Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.
14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation 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 batteries that power UAS's provide approximately 30 to 40 minutes of powered flight. To meet the 30 minute

reserve requirement, UAS flights would be limited to approximately 10 to 20 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 night VFR conditions is reasonable. Applicant believes that an 

exemption from this CFR falls within the scope of prior exemptions. Operating the small UAS, in a tightly 

controlled area, with less than 30 minutes of reserve fuel, does not pose the type of risks the CFR intended to 

alleviate. Limiting UAS flights to 10 minutes would also reduce the utility for which the exemption will be granted. 

We believe the equivalent level of safety can be achieved by limiting flights to 30 minutes or 15% 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 CFR §91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

This regulation states that 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.

Any UAS fully loaded weighs no more than 55 lbs and is operated remotely. There is no ability to carry 

certification and registration documents on board the UAS. An equivalent level of safety will be achieved by 

keeping these documents on the ground where the operator flying the UAS will have immediate access to them, to 

the extent they are applicable.

14 CFR §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 thes sections apply only to aircraft with an airworthiness certificate, these sections will not apply. 

Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as 

referenced in the Procedures. An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in controlled areas for limited periods 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.