(in vaFLIGHT 

Training & Systems 

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December 29, 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request under Section 333 of the FAA Modernization and Reform At;t of 2012 

and 14 C.F.R. Part 11 

Dear Sir or Madam: 

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

C.F.R. Part 11, Innova Flight, LLC. dba: Innova Flight Training and Systems ("Innova Flight"), hereby 

request an exemption from the Federal Aviation Regulations ("FARs") identified below, to allow 

commercial operations of its Sandstorm unmanned aerial system ("Sandstorm") (i.e., "small unmanned 

aircraft" or "UAS") as part of Innova Flight Instruction Program by instructors who, at a minimum, 

maintain a FAA private pilot certification or FAA-recognized equivalents, and have successfully 

completed Innova Flight's company flight training plan for Sandstorm. 

This exemption is made based on information outlined in this Petition for Exemption, as well as the 

accompanying Innova Flight Training Enhanced Private Pilot Airplane/UAS Ground Training Course, 

Innova Flight Training Enhanced Private Pilot Airplane/UAS Flight Training Course, Maintenance 

Instructions for Sandstorm Electric, Gas and Turbine Aircraft, Sandstorm Pilot Operating Manual and 

Innova Flight Safety Procedures for Sandstorm Unmanned Aerial Vehicle. 

Innova Flight submits these supporting materials as confidential documents pursuant to 14 C.F.R. § 

11.35(b), as the materials contain confidential commercial and proprietary information that Innova Flight 

has not and will not share with others. 

Additionally, these documents contain operating conditions and procedures that are not generally 

available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 

552 et seq., and any other requirements established by the FAA pursuant to Section 333 of the Reform 

Act. 

This Petition is organized as follows: 

1. Description of Petitioner 

2. Description of Proposed Operation 

3. Relevant Statutory Authority 

4. Innova Flight Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act 

A. Approval is Wan-anted Based on the UAS's Size, Weight, Speed, and Operationai 

Capability 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the lnnova 

Flight Safety Procedures and Maintenance Flight Manual 

5. Regulations from which Exemption is sought 

A. 14 C.F.R. Part 21, Subpart H 

B. 14 C.F.R. § 91.109(a): Flight Instruction 

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

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

E. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

F. 14 C. F. R. § Part 61, 14 C. F. R. § 61.3, 14 C. F. R. § 61.113: Private Pilot Privileges and 

Limitations 

6. Public Interest 

7. Privacy 

8. Federal Register Summary 

9. Conclusion 

1. DESCRIPTION OF PETITIONER 

Innova Flight was established in 2011 as a School for Aviation. Innova Flight instructors have extensive 

aviation experience, and our background closely matches and exceeds the needs to fulfill this 

exemption. 

Innova Flight team has extensive aviation experience in: 

• Field Utility Flight Operations 

• Contract Negotiations 

• Govemment Regulatory Compliance and Advanced Pilot Training 

• Senior Level Management of one of the top U.S Heavy Helicopter Companies 

• Extensive Experience in A&P Maintenance 

• Pilots of Large/Medium Aircraft (B-737/7571767) 

• Part 141 Airplane/Helicopter Operations 

• Military Combat Qualified Fighter Pilots (F-15/F-16) 

• Military Predator and Global Hawk Test Pilots 

• Boeing AH-64 Apache Test Pilot 

• Boeing Experimental Test Pilot 

• Aerospace Engineer UAS 

Innova Flight instructor's ofFer solid backgrounds with more than 100 years of flight instruction 

experience in both Civilian and Military Aviation. Innova Flight is able to instruct students from all 

learning backgrounds on ground, flight and instrument training of single/multipie engine airplanesrotorcraft helicopters and UAS qualification. This will include advanced maneuvers, pinnacle and 

confined area operations, safety and regulatory compliance, emergency procedures power-limited 

landings and Mountain Search & Rescue training. 

Innova Flight offers over 250 years of experience in aviation and is dedicated to continuing to build a 

robust, visionary aviation and aerospace program that enhances economic development, discovers 

new products and processes, and creates opportunities for students for research and development. As 

part of this vision, Innova Flight seeks an exemption for commercial operations of small UAS to conduct 

training courses to instruct students in the operation of unmanned aircraft and their associated systems. 

In accordance with 14 C.F.R. § 11.81(a), Innova Fiight provides the following information in support of 

its Petition for Exemption. 

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The contact information for Petitioner is as follows: 

lnnova Flight LLC. 

Address: 1940 Airport Road, Great Falls, Montana 59404 

Attn: Douglas M. Forest 

Ph: (406) 799-0507 

Email: Doug@InnovaFlight.com 

Attn: Bruce J. Determann 

Ph: (603) 472-3342 

Email: Bruce nlnnovaFlipht.com 

2. DESCRIPTION PROPOSED OPERATION 

Innova Flight intends to establish a UAS Flight Instruction Program. This program will introduce 

students to the elements of UAS operation from a commercial and noncommercial perspective and how 

these operations must fit into the National Air Space System ("NAS"). AII UAS training and instruction 

activities wi11 occur under tightly controlled conditions in UAS airspace approved by the FAA. Upon 

completion of Innova Flight's Program, students will be provided with a Certificate of Achievement. This 

Certificate of Achievement does not permit the student to engage in commercial UAS activities that are 

not in accordance with the FARs, but rather will provide a background of basic experience and 

understanding of UAS navigable airspace as the FAA promulgates specific Operator Certification 

requirements. 

Innova Flight will serve students, federal, state, and local governments, and the aviation industry as a 

whole by pioneering UAS academic programs, enhancing relationships with government and industry, 

strengthening UAS flight operations and training, and collaborating with other aviation institutions. This 

exemption request is an opportunity to not only prepare students for aviation and aerospace careers in 

the UAS industry, but also to collaborate with the FAA to study and address training and qualification 

needs specific to the UAS industry. Furthermore, Innova Flight will coordinate and continuously update 

its cun-iculum to take advantage of new guidance and regulations proposed and implemented by the 

FAA. lnnova Flight is committed to ensuring that its instruction program not only is compliant, but 

always reflects best practices as UAS integration into the NAS proceeds. 

Additionat information, views, or arsauments available to support our reguest 

Innova Flight has established standard operating procedures within our company to enable safe and 

efFective use of our unmanned systems (Sandstorm) in any situation. Our operations and these 

standards are based on our extensive military flying experience in the MQ-1 and MQ-9 systems for 

nearly 250 years combined, and innova Flight will comply with 14 CFR to the maximum extent possible. 

Furthermore, our operations are safe, efficient, and will assist the public and FAA in developing 

operating regulation for UAS. 

The Innova Flight training and certification team will enhance Regulation of Unmanned Aircraft (UA) 

Airmen, Visual Observers and other crew members. Innova Flight training course will include UAS 

ground and flight syllabus that meets 14 CFR Part 61 and 14 CFR Part 141, safety procedures, lesson 

plans, maneuvers guide, stage checks, policy and procedures, TSA security awareness training, 

training guidelines and procedures, practical evaluation standards for uas aircraft, plan of actions and 

flight risk assessment logs. 

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Innova Flight Instructors designated for these courses meet the qualifications for 14 CFR Parts § 61.57, 

recent flight experience: Pilot in command and § 61.56, Flight review. Chief Flight and Assistant Chief 

Flight Instructor designated for these courses meet the qualifications listed in the applicable parts of 14 

CFR Part 141.35. and 14 CFR Part 141.36. 

Innova Flight Check Instructor designated for these courses meets the qualifications listed in the 

applicable parts of 14 CFR Parts § 61.57, recent flight experience: Pilot in command and § 61.56, Flight 

review and 14 CFR Part 141.37. 

Innova Flight Ground Instructor designated for these courses meets the qualifications listed in the 

applicable parts of 14 CFR Parts § 61.213(a) and 14 CFR Part 141.81. 

3. RELEVANT STATUTORY AUTHORITY 

This Petition for Exemption application for use of the Sandstorm (UAS) for flight training within FAA 

approved UAS airspace for any FAA approved UAS use pursuant to the exemption requested herein, 

will advance the Congressional mandate in Section 333 of the FAA Reform Act to accelerate the 

introduction of UASs into the NAS. Section 333 directs the Secretary of Transportation to consider 

whether certain UASs may operate safeiy in the NAS before completion of the ruiemaking required 

under Section 332 of the FAA Reform Act. To make that determination, the Secretary must evaluate 

which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to 

national security in light of several criteria: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

FAA Reform Act § 333(b)(1). Once the Secretary determines that such vehicles "may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." Id. § 333(c) (emphasis added). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 49 U.S.C. § 

44701(f). This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, from the requirements that all civil aircraft must have a current airworthiness 

certificate, 49 U.S.C. § 44711(a), and those used in commercial service must be piloted by private 

and/or commercial pilots. 14 C.F.R. §§ 61.113(a) and (b), 61.133. 

The grant of the requested exemption is in the public interest based on (i) the clear direction in Section 

333 of the FAA Reform Act; (ii) additional authority in the Federal Aviation Act, as amended; (iii) the 

strong equivalent level of safety surrounding the proposed operations; and (iv) the significant public 

benefit, including enhanced safety and cost savings associated with utilizing UASs for flight instruction 

for FAA approved operations. Accordingly, Innova Flight respectfully requests that the FAA grant the 

requested exemption without delay. 

A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the 

public as a whole, and (2) would not adversely afFect safety (or how it would provide a level of safety at 

least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

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4. INNOVA FLIGHT'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 

333 OF THE REFORM ACT 

Innova Flight`s proposed operations in this Petition for Exemption qualify for expedited approval 

pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are 

satisfied. 

Airworthiness 

The Sandstorm is safe and fit for operation in the NAS under the conditions listed herein. The FAA has 

deemed the Sandstorm safe by initiaily issuing a Special FAA Experimental Airworthiness Certificate for 

flight on September 14, 2011. Innova Flight has flown the Sandstorm since this date in 2011 and 

currently continues to operate near Columbia Falls, Montana under the FAA issued Experimental 

Airworthiness Certificate for Unmanned Aircraft with an initial assigned Registration Mark N441 KS, 

being the first tail number for Unmanned Systems Inc. Other Sandstorm aircraft certified by the FAA 

with Experimental Airworthiness Certificate are: 

• Sandstorm Electric Aircraft: N478PB, N441 NS, N478ZA, N478QD, N478RC 

• Sandstorm Gas Aircraft: N273JS, N478TU 

• Sandstorm Turbo-Prop Aircraft: N478LU, N496ZC 

• Sandstorm Reserved Numbers: N416SG, N453RS 

In support of this application, Innova Flight can provide with a request for confidential documents 

pursuant to 14 C.F.R. § 11.35(b), confidentiality, the following documents: the Combined Sandstorm 

Aircrew Operating Handbook ("AOH"); the Local Pilot Initial Qualification Syllabus; the Observer Initial 

Qualification Syllabus; the Safety Pilot Initial Qualification Syllabus; and the Flight log books. 

Mandatory Operating Conditions 

Innova Flight proposes that the grant of the exemption be subject to the following mandatory conditions, 

which are based upon operating conditions set forth for operation of UAS by public entities pursuant to 

Certificates of Waiver or Authorization, with additional restrictions: 

• Operations to be conducted within FAA approved UAS Airspace 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Aircraft to remain within Visual Line of Sight (VLOS). 

• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet and below. 

• Operator will file a NOTAM 24 hours prior to each daily flight. 

• Operator will call the control tower prior to each daily flight schedule. 

• AII required authorizations and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other governmental agencies. 

Operator Requirements 

Innova Flight respectfully proposes that operator requirements should take into account the 

characteristics of the particuiar UAS. The Sandstorm is an inherently stable, light-weight aircraft that 

weighs less than 40 pounds without payload, has a proven safety flight safety record. Our Flight 

program has nearly 850 UAV flight hours and more than 7200 takeoffs and landings with no accidents 

or incidents. 

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Sandstorm is configured to give the Local Pilot ("LP") or Remote Pilot ("RP") full control of the aircraft 

during all phases of flight. Certain aircraft will be equipped with an advanced autopilot that can be used 

to fiy the aircraft in one of four modes: Stabilized, Return to Home ("RTH"), Circle or Nav. Stabilized 

mode commands the aircraft to fly straight and level with no input from the pilot. RTH mode commands 

the aircraft to fly to a"return to home point" designated by the pilot and then circle until transitioned to 

manual control by the pilot. Circle mode commands the aircraft to circle around its current position until 

the pilot takes control manually or activates another autopilot mode. Engaging Nav mode commands 

the aircraft to fly to pre-programmed waypoints designated by the pilot on the GCS Map screen. Each 

of these autopilot modes creates a predictable aircraft flight pattern that allows Sandstorm to operate 

within the intended flight envelope with minimal input from the pilot. Flight limits are coded into the 

autopilot and define the aircraft's normal flight operating envelope. Manual flight modes that do not use 

the autopilot require the operator to provide control input to maintain heading, altitude and airspeed. 

Pitch, roll and throttle inputs are accomplished by the LP using the handheld radio controller/transmitter 

or by the RP using GCS RP Control Stick station via the 900 MHz or 2.4 GHz link respectively. 

The GCS is the primary control station; providing the RP situational awareness and command and 

control interFace for the UA. The flight controls consist of a control stick, throttle, and rudder pedals. The 

LP will always have the capability to take control of the aircraft with the handheld transmitter if 

necessary for safety of flight in all phases of flight while maintaining VLOS. 

In the event of a Total Lost-Link ("TLL") the autopilot shall navigate the UAS back to a designated 

Return to Home ("RTH") point. Standard operating procedures will have a designated RTH point prior to 

every flight. While in circle mode around the RTH point, recovery of control should be possible. In the 

event that recovery of control link is not possible, the UAS will spiral down to a controlled landing 

around the designated RTH point. If the motor batteries have been depleted, the avionics and flight 

control surfaces are powered independently to allow for continued control by the LP to conduct a pilot 

controlled landing of the aircraft. 

S. REGULATIONS FROM WHICH EXEMPTION IS SOUCHT 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined U.S. Department of 

Transportation under § 40101 of the Act, including UASs, from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public interest. 

Innova Flight seeks an exemption from several interrelated provisions of 14 C.F.R Parts 21, 61 and 91 

for purposes of conducting the requested operations using UAS. Listed below are: (1) the specific 

sections of 14 C.F.R. forwhich exemption is sought, and; (2) the operating procedures and safeguards 

that Petitioner has established which will ensure a level of safety better than or equal to the rules from 

which exemption is sought. 

A. 14 C.F.R. 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). 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 (fl) 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 

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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. 

Sandstorm aircraft has already been certified as airworthy via a Special Airworthiness certificate of the 

Experimental class and has been recertified as such on four separate occasions. The exemption 

Innova Flight seeks at this time is to be able to conduct flight instruction operations while only having an 

Experimental certification. 

Operations conducted under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety requirements, to provide security for the 

area of operation. Innova Flight will also provide the FAA with advance notice of all operations via 

NOTAMS. In all cases, the UAS are operated under the following regulations: 

1 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716). 

2 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you seek 

exemption. Proposed conditions will be at least as safe as, or safer than conventional aircraft operating 

with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations. 

See Grant of Exemption, Docket FAA-2014-0352 at 13. In addition, the UAS wiil be operated at all 

times in visual line-of-sight and in VFR conditions. 

B. 14 C.F.R. § 91.109(a): Flight Instruction 

Innova Flight seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 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 and remotely piloted aircraft, by their design, do not 

have functional dual controls. Instead, flight control is accomplished through the use of a device that 

communicates with the aircraft via radio communications. Accordingly, an exemption will be required for 

the flight instruction requirements of 14 C.F_R. § 91.109(a). 

Given the size and speed of the Sandstorm UAS that Innova Flight intends to use, an equivalent level 

of safe training can still be performed without dual controls because no pilot or passengers are aboard 

the Sandstorm UAS, and as required by Innova Flight Safety Procedures, all persons will be a safe 

distance away in the event that the Sandstorm UAS experiences any difficulties during flight instruction. 

Moreover, Petitioner will conduct training in a controlled and sterile environment. As required by Innova 

Flight Manuals, training and instruction will be conducted in FAA approved UAS Airspace and comply 

with any associated restrictions. These facilities will not be open to the public during Sandstorm UAS 

operations, and access will be restricted to authorized Innova Flight personnel and students enrolled in 

the UAS course. 

As required by Innova Flight Manuals, the Flight Training Team will be composed of a PIC, Visual 

Observer, Student, Instructor, and Flight Examiner. Designated Instructors and Examiners are required 

to be an FAA licensed airman with at least a private pilot's certificate and have a Class II Medical 

Certificate. Further, all Instructors and Examiners must have successfully passed a written and/or oral 

exam covering Innova Flight's UAS operations per Innova Flight Manuals. Instructors and Examiners 

are also required to pass a practical exam covering operations of the aircraft being used to perform the 

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proposed operations in this Petition for Exemption. As a whole, the safety procedures provided for in 

Innova Flight Manuals ensure that the proposed Sandstorm UAS operations provide an equivalent or 

higher level of safety than the flight instruction regulations. 

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

Innova Flight requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas_ Section 14 C.F.R. § 91.119(c). limits aircraft flying over areas other than congested 

areas to 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. 

As set forth herein, the Sandstorm will never operate at higher than 400 feet AGL. It will, however, be 

operated in a manner that avoids congested or populated areas that are depicted in yellow on VFR 

sectional charts. Because flight instruction will be taught for FAA Aviation Safety Inspectors, 

commercial film production, agriculture, aerial survey photography, public service, pipeline patrol, 

search and rescue, disaster recovery, utilities, and patrolling must be accomplished at relatively low 

altitudes, i.e., less than 500 feet AGL, an exemption from Section 91.119(c) is required. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with which 

the Sandstorm is built. Compared to similar operations conducted with conventional aircraft or 

rotorcraft, which weigh thousands of pounds and carry flammable fuel, any risk associated with these 

operations will be significantly reduced from those currently allowed for conventional aircraft operating 

at or below 500 feet AGL. Waivers have been granted to other UAS operators for such operations. 

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

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation 

of the departure airport or barometric pressure. An exemption is required to the extent that the UASs do 

not have a barometric altimeter, but rather a GPS altitude read out. 

The FAA has stated that an equivalent ievel of safety to the requirements of 14 C.F.R. § 91.121 can be 

achieved in circumstances where: (1) the UASs will be operated at 400 feet AGL or below, (2) within 

visual line-of-sight, (3) where GPS based altitude information is relayed in real time to the operator at a 

ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS. 

See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352 at 21 

As the attached Innova Flight Manuals and Manufacturer's Manuals demonstrate, the UASs Innova 

Fiight intends to use meet these requirements. Moreover, Innova Flight's Aircraft Flight Manual includes 

GPS compass calibration procedures that must be performed prior to each flight. Like Astraeus Aerial's 

petition for exemption, the UASs Innova Flight intends to use, and the safety procedures contained in 

Innova Flight Safety Procedures, ensure that an equivaient level of safety will be achieved, and a grant 

of exemption to the requirements of § 191.121 is therefore appropriate. 

E. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Innova Flight requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements prohibits an 

individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and 

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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." 14 C.F.R. § 91.151(a). 

All Sandstorm's UAS provide between one and three hours of powered flight. Without an exemption 

from 14 C.F.R. § 91.151, the Sandstorm's flights could be limited to approximately thirty minutes in 

length. Given the limitations on its proposed operations and the location of those proposed operations, 

a longer duration for flight in daylight VFR conditions is reasonable. 

Innova Flight believes that an exemption from 14 C.F.R. § 91.151(a) is safe and consistent with the 

scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with 91.151(a)). Operating the Sandstorm, a small UAS, without 30 minutes of 

reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent. The fact 

that the Sandstorm carries neither pilot, passenger, nor cargo aiso enhances the reduced risk to overall 

safety. Additionally, limiting Sandstorm flights to thirty minutes would greatly reduce the operational 

utility of the platform. In the unlikely event that any Sandstorm does lose power, it would glide under 

pilot control to its landing zone, which will at all times be reached within 2 minutes. 

Innova Flight believes that an equivalent level of safety can be achieved by maintaining 10 minutes of 

reserve fuel, which would be more than adequate to return the UAS to its planned landing zone from 

anywhere in its planned operating area. 

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, and 

10808. 

F. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 

Innova Flight will require its flight instructors to have a private pilot certificate. However, as set forth in 

the accompanying manuals, flight instruction will also be provided to students who will not have a 

private pilot's certificate. Accordingly, Innova Flight seeks exemption from 14 CFR Part 61, including 14 

CFR § 61.3 to the extent that these regulations are interpreted as requiring a student receiving UAS 

pilot instruction to have a private pilot's certificate. AII student instruction flights will be conducted under 

closely controlled circumstances, in FAA approved UAS airspace and away from persons or property 

not invoived in the instruction. In addition, the student instruction flights will be conducted under the 

close supervision of a flight instructor, who will have a private pilot certificate. 

In addition, to the extent that Innova Flight will be employing persons with a private certificate from 14 

C.F.R § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or 

hire, and which would also require a second class medical certificate. The purpose of this section is to 

ensure the skill and competency of any PIC where the aircraft is carrying passengers or cargo for hire. 

In this case, while Instructors or Flight Examiners acting as PIC of the Flight Training Team will be 

operating UASs for a commercial purpose as part of Innova Flight's Flight Instruction Program, the 

UASs carry neither passengers nor cargo. Additionally, in the Astraeus Aerial Grant of Exemption (FAA 

Docket No. FAA-2014-0352), the FAA determined that the unique characteristics of UAS operation 

outside of controlled airspace did not warrant the additional cost and restrictions attendant with 

requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. 

Innova Flight will ensure an equivalent level of safety to the regulatory requirements of 14 C.F.R. Part 

61, including 14 C.F.R. §§ 61.3 and 61.113 by following the safety procedures provided in Innova Flight 

Safety Procedures. Specifically, the sUAS lnnova Flight Safety Procedures include numerous 

conditions and limitations which ensure the proposed UAS operations can be conducted safely. These 

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include a minimum of a Class II Medical Certificate for all flight personnel, including students, a 

demonstration of proficiency through written/oral examination covering all flight operations. 

In addition to these training and experience requirements, Innova Flight has placed additional 

restrictions on its proposed UAS operations to ensure an extra margin of safety. The UAS will only 

operate in FAA approved UAS airspace, and in a controlled and sterile area away from persons and 

property not involved in the operation. As required in Innova Flight Safety Procedures, the general 

operating procedures will include weather briefings, maintenance inspections, preflight inspections and 

air and ground emergency procedures. Innova Flight will also file a NUTAM with the appropriate ATC 

facility 24 hours before the flight is to occur. Innova Flight Safety Procedures also include its 

qualification, currency and training requirements for members of Innova Flight Training, ensure that 

UAS operators are competent and proficient in the UAS they are operating. Collectively, these 

procedures ensure that the proposed UAS operations can be conducted safely. 

6. PUBLIC INTEREST 

Student operators participating in Innova Flight's Flight Instruction Program will not operate UAS for 

compensation or hire. 

The public interest will be served by granting Innova Flight's Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the National Airspace System 

("NAS") in controlled, safe working environments such as those proposed in this Petition. Granting this 

Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform 

Act, namely; the FAA Administrator's assessment of whether certain UAS may operate safely in the 

NAS before completion of the rulemaking required under Section 332 of the Reform Act. 

The proposed UAS operations in this Petition for Exemption will benefit students, federal, state, and 

local governments, and the aviation industry as a whole by pioneering UAS academic programs that 

focus on the safe integration of UAS into the NAS. This Petition for Exemption offers the FAA an 

opportunity to collaborate with solid and respected flight company (Innova Flight Training and Systems) 

that has decades of experience and a solid reputation for excellence throughout all facets of the 

aviation industry. The public as a whole will benefit from a collaborative relationship between the FAA 

and Innova Flight that focuses on the safe promotion of best practices for training and qualification 

needs specific to the UAS industry. 

The proposed UAS operations in this Petition for Exemption will also improve safety and reduce risk by 

alleviating the public's exposure to danger associated with student flight training utilizing fuil size fixedwing aircraft and rotorcraft. The Petitioner will operate all Sandstorm aircraft outside navigable manned 

airspace, posing no risk to manned aircraft. 

7. PRIVACY 

AII Innova Fiight UAS operations shall be conducted in accordance with appiicable federal, state, or 

local laws regarding privacy. lnnova Flight wili not conduct flight operations over property that it does 

not own or control without the prior consent and knowledge of the property owner. 

Innova Flight's mission is to provide flight instruction, not capture or use images from neighboring 

properties within the vicinity of UAS flight operations. AII flights will occur in airspace that is approved by 

the FAA for UAS flights. 

Innova Flight, LLC -- 1940 Airport Court — Great Falls, MT 59404 -- 406.799.0507 -- InnovaFlight.com 
(Ln ko va ~LIG~~ ning & Systems 

Page 11 of 12 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation with is VLOS and 

national security. Provided in the above documentation is adequate justification for the grant of the 

requested exemptions allowing flight instruction operation of applicant's UAS in training. 

8. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal 

Register, should the FAA determine that publication is needed: 

Petitioner: Innova Flight Training and Systems, LLC. 

Section of 14 C.F.R.: 14 C.F.R. § 21(h), 14 C.F.R. § 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113(a)(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). 

Innova Flight training program will help coordinate training for ASI's in certification standards and 

surveillance, training for air traffic control personnel for UAS operations in the national airspace 

systems and help develop standards for UAS simuiation and testing standards utilizing sandstorm 

Longshot Technology. Most importantly, showing and teaching the public the rules and regulations to 

fly a UAS in the NAS. The UAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than 70 pounds, conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile 

environment and, as a result, are far safer than conventional operations conducted with turbine aircraft 

operating in close proximity to the ground and people. 

The exemption will enhance flight instruction safety by reducing risk to the general public and property 

owners from the substantial hazards associated with perForming equivalent flight training with 

conventional fixed-wing aircraft, rotorcraft, or other methods. 

9. CONCLUSION 

Innova Flight's Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act 

of 2012 inciuding weight, speed, operating capabiiities, proximity to airports and populated areas, 

operation within visual line-of-sight and national security. The proposed UAS operations will benefit the 

public as a whole by fostering a collaborative relationship between the FAA and Innova Flight which 

focuses on UAS training, qualifications, and processes involving the safe and efficient operation of UAS 

in the NAS. 

In consideration of the foregoing, lnnova Flight's Petition for Exemption provides the FAA with more 

than adequate justification for granting of the requested exemptions allowing Innova Flight to perForm 

flight instruction as part of Innova Flight's Flight Instruction Program. 

Innova Flight, LLC -- 1940 Airport Court — Great Falls, MT 59404 -- 406.799.0507 -- InnovaFlight.com 
C kovaFLIGHT 

ninq & Systems 

Page 12 of 12 

Shoulq you have any questions, or if you need additional information to support the requested 

exem ions, please contact the undersigned at: 

Flight, LLC 

406-799-0507 

ly, 

nts: 

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file 

pursuant to 14 C.F.R. § 11.35(b)). 

Attachment A: Innova Flight Enhanced Private Pilot Airplane/UAS Ground Training Course 

Attachment B: Innova Flight Enhanced Private Pilot Airplane/UAS Flight Training Course 

Attachment C: Innova Flight Safety Procedures Unmanned Aerial Vehicle 

Attachment D: Sandstorm Pilot Operating Manual 

Attachment E: Sandstorm Maintenance Instructions UAS E, G and T Series 

Innova Flight, LLC -- 1940 Airport Court — Great Falls, MT 59404 -- 406.799.0507 -- InnovaFlight.com