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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC.

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Northern Drone Worx LLC,

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS (14 CFR) PART 21 SECTIONS; §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 

91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a)

and (b).

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on January 9, 2016

Northern Drone Works LLC

Eric Munson 4525 Airport Approach Rd

Duluth MN 55811

Tel: (218) 461-2857

Email: emunson@lakesuperiorhelicopters.com
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS ...................................................................................................................... 2

SUMMARY............................................................................................................................................................. 3

INTRODUCTION AND INTERESTS OF PETITIONER ........................................................................................... 3

BACKGROUND .................................................................................................................................................... 4

BASIS FOR PETITION .................................................................................................................................. 10

NAME AND ADDRESS OF PETITIONER ................................................................................................... 10

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH NORTHERN DRONE WORX LLC, SEEKS EXEMPTION 11

THE EXTENT OF RELIEF NORTHERN DRONE WORX LLC SEEKS AND THE REASON NORTHERN DRONE 

WORX LLC, SEEKS RELIEF & REASONS WHY GRANTING NORTHERN DRONE WORX LLC, REQUEST WOULD 

BE IN THE PUBLIC INTEREST.......................................................................................................................... 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.................. 16

FLIGHT OPERATIONS........................................................................................................................................... 17

CONCLUSION........................................................................................................................................................ 18

Northern Drone Worx LLC Flight Operations Manual NDW-001 Attachment A

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

NAS National Airspace System

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SMS Safety Management System

UAV Unmanned Aircraft System

VFR Visual Flight Rules
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VMC Visual Meteorological Conditions VTOL Vertical Take Off and Landing

SUMMARY

Northern Drone Worx LLC., seeks exemption from the requirements of 14 C.F.R. §§ 45.23(b), 61.113(a) 

and (b), 91.7(a), 91.9(b) (2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and(b), 91.405(a), 

1.407(a)(1), 91.409(a)(2), and 91.417(a) and (b)., as well as the restricted category airworthiness 

certification standards specified in 14 C.F.R. § 21.185, including the requirement to have a certificate of 

airworthiness as contemplated by 14 C.F.R. Part 21.

This exemption will permit Northern Drone Worx, LLC. to operate various Unmanned Aircraft Vehicles 

("UAV’s") at or above wind power generation facilities, electric transmission towers, substations and 

other industrial/commercial locations, while keeping the documents required by the regulations at the 

ground control station and immediately accessible to the pilot in command. 

Northern Drone Worx, LLC also requests to provide a UAS Pilot Training program in its services.

Furthermore, the exemption will relieve Northern Drone Worx, LLC. from the airworthiness certificate 

standards and the requirement to have a certificate of airworthiness issued for its UAV. This exemption 

will also permit any required markings concerning the operational status of its UAV to be displayed on 

the main section of the unmanned aircraft.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Northern Drone Worx LLC is associated with Lake Superior Helicopters, LLC, a 7-year-old manned 

helicopter company in the Midwest that provides pilot training, aerial inspections services and 

transport. Lake Superior Helicopters has an extensive history of safely utilizing manned helicopters that 

meets all safety and certification requirement designated by the FAA.

Northern Drone Worx LLC includes direction and supervision from Dennis O’Hara/Northern Images, who 

currently operates under an existing 333 Exemption holder. Exemption No. 12431, Regulatory Docket 

No. FAA–2015–2247. This request is for a new 333 under Northern Drone Worx LLC.

As set forth in this Petition, Northern Drone Worx LLC will be operating its UAV's for the purpose of 

aerial inspections of its existing electric and gas customers and to expand to support the growth of new 

customers in the Midwest wind farms and other infrastructure related facilities. In addition, Northern 

Drone Worx LLC will provide aerial photography and videography as a service to other customers as the 

opportunity arises. Northern Drone Worx LLC plans to do this with a continued focus on safety which 

has been developed through its aviation culture developed in manned flight operations and the highest 

standards of quality, maintenance and reliability.
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BACKGROUND

Unmanned Aircraft Vehicle: DJI PHANTOM 3

Northern Drone Worx LLC seeks an exemption to operate its DJI PHANTOM 3 UAV, for compensation or 

hire within the national airspace system ("NAS").

The DJI PHANTOM 3 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. 

The DJI PHANTOM I3 UAV has a maximum gross weight of approximately two (2) pounds and the 

following technical and operational specifications:

Weight (Battery & Propellers included)-1280g

Hover Accuracy (Ready to Fly)-Vertical: 0.1m; Horizontal: .5m Max Yaw Angular Velocity-200°/s

Max Tilt Angle-35°

Max Ascent / Descent Speed-Ascent: 5m/s; Descent: 3m/s Max Flight Speed-15m/s

Diagonal Length-350mm Power Consumption-5.6W Flight Time-25mins

Take-off Weight-?1300g

Operating Temperature- -0°C ~ 40°C Supported Battery-DJI Intelligent Battery Type-4S LiPo

Capacity-4480mAh, 15.2V

Operating Frequency-2.4GHz ISM Lightbridge

Receiver Sensitivity (1%PER)--97dBm 

Working Current/Voltage-100 mA@6V Battery-6s Lipo

The DJI PHANTOM 3 unmanned aircraft is equipped with four (4) propellers driven by 

Four (4) Lithium Polymer battery powered electric motors.
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FIGURE 1: Northern Drone Worx LLC, DJI PHANTOM 3 Professional

Northern Drone Worx LLC will submit an Aircraft Registration Application for each UAV upon the grant 

of the exemptions sought by this Petition.
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Unmanned Aircraft Vehicle: Inspire 1 UAV

Northern Drone Worx LLC seeks an exemption to operate an Inspire 1, UAV, for compensation or hire 

within the national airspace system ("NAS").

The Inspire 1 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. The 

Inspire 1 UAV has a maximum gross weight of approximately six and one half (6.5) pounds and the 

following technical and operational specifications:

Aircraft Model T600

Weight (Battery Included) 2935 g 

Hovering Accuracy (GPS mode)

 Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 00°/s Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500m

Max Wind Speed Resistance 10m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by

default Temperature Range -10° to 40° C 

Diagonal Distance 559 to 581 mm

Dimensions 438 x 451 x 301 mm
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FIGURE 2: INSPIRE 1 WITH BUILT IN VIDEO/CAMERA SYSTEM

Northern Drone Worx LLC will submit an Aircraft Registration Application for each UAV upon the grant 

of the exemptions sought by this Petition.

Proven Operational History of: DJI PHANTOM 3, and Inspire 1 UAV in the NAS

The DJI PHANTOM 3 and Inspire 1 UAV's are currently operating safely within the NAS. Lake Superior 

Helicopters has been operating UAV's under 55lbs for the past 5 years without any recorded incident, 

accident or failure.
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Unmanned Aircraft Vehicle: DJI S900 UAV

Northern Drone Worx LLC seeks an exemption to operate a DJI Spreading Wings s900, UAV, for 

compensation or hire within the national airspace system ("NAS").

The Inspire s900 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. The 

Inspire 1 UAV has a maximum gross weight of approximately six and one half (6.5) pounds and the 

following technical and operational specifications:

Takeoff Weight 6Kg (17 lbs)

Total Weight 6Kg

Power Battery LiPo (6S、10000mAh~15000mAh、15C(Min))

Max Power Consumption 3000W

Hover Power Consumption 1000W (@6.8Kg Takeoff Weight)

Hover Time 18min (@12000mAh& 6.8Kg Takeoff Weight)

Working Environment Temperature -10 °C ~ +40 °C

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight(with Radiators) 35g
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Unmanned Aircraft Vehicle: Yuneek 500H UAV

Northern Drone Worx LLC seeks an exemption to operate an Yuneek 500H UAV, for compensation or 

hire within the national airspace system ("NAS").

The Yuneek 500H UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. 

The Yuneek 500H UAV has a maximum gross weight of approximately eight and one half (8.5) pounds 

and the following technical and operational specifications are estimated as they were not available at 

the time of the petition:

8.5 lbs (est)

6 rotors

Geofencing

15.5 Volts Lipo 4 C

Intel Sense and Avoid

4k Camera
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BASIS FOR PETITION

Petitioner, Northern Drone Worx LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator for an exemption from the 

requirements of 14 C.F.R. §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b) (2), 91.103, 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 1.407(a)(1), 91.409(a)(2), and 91.417(a) and (b)., as well 

as the restricted category airworthiness certification standards specified in 14 C.F.R. § 21.185, including 

the requirement to have a certificate of airworthiness as contemplated by 14 C.F.R. Part 21.

In accordance with 14 C.F.R. § 11.81, Northern Drone Worx LLC provides the following information in 

support of its petition for exemption:

A) Name and Address of the Petitioner.

The name and address of the Petitioner is: 

Northern Drone Worx LLC.

Mailing Address: 4525 Airport Road, Duluth, MN 55811 

The point of contact for this Petition and specific contact information is as follows: 

Eric Munson

Northern Drone Worx LLC

Mailing Address: 4525 Airport Road, Duluth, MN 55811 

Tel: (218) 461-2857

Email: emunson@lakesuperiorhelicopters.com
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The Specific Sections of 14 C.F.R. From Which Northern Drone Worx LLC Seeks Exemption.

1. 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 Northern Drone Worx LLC, 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 UAV. In all cases, an analysis of these criteria demonstrates that 

the UAV 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.

All of the UAV's to be operated hereunder are less than 55 lbs. fully loaded, carry neither a pilot nor 

passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively within a 

secured area as set out in the Northern Drone Worx LLC’s UAS Flight Operations Manual (Attachment A). 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the Manual's requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of operation as is now 

done with conventional inspections. The FAA will have advance notice of all operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with power generation 

inspections, provide a greater degree of safety to the public and property owners then 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 UAV's, due to their size, speed of operation, location of operation, lack of explosive 

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

Communications with all Infrastructure operating personnel and authorities is required by Northern 

Drone Works LLC SOP’s and appropriate notams and COA’s will be filed.

2. 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 UAV will have no airworthiness certificate, an exemption may be needed as the UAV 

will have no entrance to the cabin, cockpit or pilot station on which the words "limited," "restricted," 

"light-sport," "experimental," or "provisional," can be placed. Given the size of the UAV, two-inch 

lettering will be impossible. The word "experimental," may be placed on one of the rotor arms of each 
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UAV, in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAVs 

marked on their rotor arm as required by §45.29 (f) where the pilot, observer and others working with 

the UAV will see the identification of the UAV as "experimental,".

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A.

3. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAVs will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a 

commercial pilot's license to operate these small UAVs. Unlike a conventional aircraft that carries the 

pilot and passengers, Lake Superior Helicopters' UAVs are remotely controlled with no living thing on 

board. The area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Northern Drone Worx LLC Operations Manual. The level of safety provided by 

the requirements included in the Manual exceeds that provided by a single individual holding a 

commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation 

of the UAVs are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of these UAVs as requested with a 

private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

4. 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 and the requirements contained in the Manual for maintenance and use of 

safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will 

be provided.

5. 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 UAVs, given their size and configuration have 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 UAV will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 32827, and 10700.
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6. 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. An equivalent level of safety will be provided as set forth in the Manual. The PIC will take 

all actions including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight.

7. 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.

UAVs 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. See Exemption 

Nos.5778K & 9862A. 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.

8. 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 UAV that is a multi-rotor VTOL and the exemption requests authority to operate at altitudes up 

to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which operations are planned, 

an exemption may be needed to allow such operations. As set forth herein, except for the limited 

conditions stated in the Manual, the UAV will never operate at higher than 400 ft. AGL. It will however 

be operated in a restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre-obtained consent.

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

location where they will be 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 as set forth in the 

Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 

55 lbs. 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 400 ft. AGL in the 

power generation industry. In addition, the low-altitude operations of the UAVs will ensure separation 

between these small UAV operations and the operations of conventional aircraft that must comply with 

Section 91.119.

9. 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 UAV may not have a barometric altimeter, but instead a GPS altitude 
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read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the 

GPS altitude indicator before flight.

10. 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 batteries powering all of Northern Drone Worx LLC’s UAV's provide approximately 35 minutes of 

powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, UAV flights would be 

limited to approximately five (5) minutes in length. Given that this limitation would prohibit the flight of 

the UAV's a longer time frame for flight in daylight or night VFR conditions is reasonable.

Northern Drone Works LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAV, 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 UAV.

Additionally, limiting UAV flights to 5 minutes would greatly reduce the utility for which the exemption 

will be granted.

Northern Drone Worx LLC believes that an equivalent level of safety can be achieved by limiting flights 

to 25% of battery power. This restriction would be more than adequate to return the UAV's to their 

planned landing zone from anywhere in their limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808.

11. 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.

All of Northern Drone Worx LLC’s UAV's fully loaded weigh no more than 55 lbs and are 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 UAV's.
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An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAV will have immediate access to them, to the extent they are applicable to 

the UAV. The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

12. 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 sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Northern Drone Worx LLC. Maintenance will be accomplished by Northern 

Drone Worx LLC pursuant to its flight manual and operating handbook as referenced in the Manual. (See 

Sections Attachment A) An equivalent level of safety will be achieved because these small UAVs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited periods of 

time. If mechanical issues arise the UAV can land immediately and will be operating from no higher than 

400 feet AGL. As provided in the Manual, Northern Drone Worx LLC will ensure that every UAV 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.

13. The Extent of Relief Northern Drone Worx LLC Seeks and The Reason Northern Drone Worx LLC 

Seeks Relief from 14 C.F.R. § 21.185.

Northern Drone Worx LLC seeks relief from the airworthiness certificate requirements of the Federal 

Aviation Regulations and proposes to commercially operate the DJI PHANTOM 3, Inspire 1, Spreading 

Wings s900 and Yuneek 500H Typhoon UAV’s, without an airworthiness certificate, for the special 

purpose of conducting aerial inspection services for its customers, pursuant to specific operating 

limitations and a Safety Management System ("SMS"). Northern Drone Worx LLC seeks relief from the 

airworthiness certificate requirements of 14 C.F.R. § 21.185 to the extent that the DJI PHANTOM 3,

Inspire 1, Spreading Wings s900 and Yuneek 500H Typhoon UAV’s, which have not yet been type 

certificated by the FAA, may be operated as if they were a restricted category aircraft for a single, 

defined, special purpose operation (i.e., aerial inspection).

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

Drone Worx LLC seeks relief from the airworthiness certificate requirements of the FAR because 

operation of the DJI PHANTOM 3, Inspire 1, Spreading Wings s900 and Yuneek 500H Typhoon UAV’s will 

not create a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

Section 333 sets forth the requirements for considering whether a UAV will create a hazard to users of 

the NAS or the public or pose a threat to national security. Further, Section 333 provides the authority 

for such UAV to operate without airworthiness certification.

Specifically, Section 333 states the following, in part:

(b) Assessment of Unmanned Aircraft Systems. -- In making the determination under subsection (a), 

the Secretary shall determine, at a minimum--
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(1) Which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system or the public or pose a threat to 

national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1set forth below, numerous factors, including the proven safe operational 

history of the DJI PHANTOM 3, Inspire 1, Spreading Wings s900 and Yuneek 500H Typhoon UAV’s in the 

NAS, as well as the specific parameters of Lake Superior Helicopters intended operation pursuant to this 

exemption, demonstrate that the DJI PHANTOM 3 Inspire 1, Spreading Wings s900 and Yuneek 500H 

Typhoon UAV’s have in the past, and will continue in the future, to operate safely in the NAS without 

creating a hazard to other aircraft or people on the ground. Accordingly, the FAA may approve operation 

of the DJI PHANTOM 3 and Inspire 1 UAV, without an airworthiness certificate, by setting forth specific 

operating limitations to ensure a level of safety equivalent to what would be provided by airworthiness 

certification.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed:

Northern Drone Worx LLC seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); §§ 61.113(a) & (b); 91.7(a); 91.9 (b) (2); 91.103 (b);91.109; 

91.119; 91.121; 91.151 (a); 91.203(a) and (b); 91.405(a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2), 

91.417 (a) & (b), as well as the restricted category airworthiness certification standards specified in 14 

C.F.R. § 21.185 to operate commercially unmanned vehicle (55lbs or less) for aerial inspections.

Approval of exemptions allowing commercial operations of UAVs in the power generation inspection 

industry will enhance safety by reducing risk. Conventional power generation inspections, using persons 

dangling from ropes at altitudes of 300 to 450 feet are potential cause for falls, death or injury. In 

contrast, a Northern Drone Worx LLC UAV weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all human risk to serious falls given that the PIC is on the ground.

Every Northern Drone Worx LLC UAV is carried to the inspection site and not flown. The UAV's will carry 

no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights. The operation of small UAVs, weighting less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an improved level of safety supporting the grant of the exemptions 

requested herein, including exempting the Northern Drone Worx LLC 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 by humans dangling from ropes.

Reasons Why Granting Northern Drone Worx LLC Request Would Be in The Public Interest

Granting the present Petition will further the public interest by allowing Northern Drone Worx LLC to 

safely, efficiently, and economically perform aerial inspection services of power generation facilities, 

onshore oil and gas platforms, pipelines and land developers Additionally, use of the Northern Drone 

Worx LLC UAV's will increase worker safety by reducing human exposure to rope access work at extreme 
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heights, increase the frequency of power generation inspections being performed thereby increase 

power plant safety and provide significant benefits to the reduction in costs associated with the 

maintenance of power generation facilities. Notably, the benefits of the proposed operation of the 

Northern Drone Worx LLC UAV will be realized without implicating any privacy issues.

Privacy

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. Aerial inspections will be of power generation equipment, production facilities or 

buildings in remote or uninhabited areas.

Flight Operations

Flight Operations pursuant to the exemption sought would be limited to areas that are not in the 

proximity of airports or over populated areas. Northern Drone Worx LLC proposes to only conduct aerial 

flight operations over private land, in rural areas of the United States that are not near populated areas, 

airports, helipads, or state roads. All appropriate FAA notifications and contacts will be made when 

needed.

Specifically, Northern Drone Worx LLC, proposed areas of aerial operations include rural areas that are:

1. Not populated areas as depicted on VFR Sectional Aeronautical Charts;

2. Not within five (5) miles of any airport or helipad;

3. Not within one hundred (100) meters of state roads having more than two lanes; and

4. Not within fifty (50) meters of state roads having two lanes or less.

Northern Drone Worx LLC has been operating all of its UAV's by regulations such as the ICAO 

(International Civil Aviation Organization) and the FAA's own national airspace regulations. In order to 

increase flight safety and prevent accidental flights in restricted areas, all of Northern Drone Worx UAV's 

will be operated utilizing Category "A" No Fly Zone restrictions.

A buffer or exclusion zone for flight operations will also be implemented around state roads. Since the 

roads are represented geometrically as lines, the buffers result as a one hundred (100m) corridor 

around state roads with more than two lanes, and fifty (50) meters around state roads with two lanes or 

less. In summary, Northern Drone Worx LLC seeks to operate its UAV's only under controlled conditions, 

while maintaining safe distances from any populated areas, airports, helipads, or roadways.

Operation of Northern Drone Worx LLC UAV's will be Conducted Pursuant To "NDW UAS Operations 

Manual (Attachement A)."

Northern Drone Worx LLC Operations Manual NDW-001 will control operation of UAV's and will 

significantly contribute to maintaining the level of safety contemplated by the airworthiness certificate 

requirements from which Northern Drone Worx LLC now seeks relief. Pursuant to the Operations 

Manual and 14 C.F.R. § 43.13, entitled Performance Rules (general), each person performing 

maintenance, alteration, or preventive maintenance on any of Northern Drone Works LLC’s UAV's, 

motors, propellers, hardware, guidance systems or appliances shall use the methods, techniques, and 

practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued 
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Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to 

the Administrator. Each person shall use the tools, equipment, and test apparatus necessary to assure 

completion of the work in accordance with accepted industry practices.

A copy of the Operations Manual, which is proprietary information to Northern Drone Worx LLC, is 

included in attachment A and is proprietary, and is a separate file pursuant to 14 C.F.R. § 11.35(b).

Flight Operations of Northern Drone Worx LLC UAV's Are Limited to Line of Sight of The PIC with A 

Safety Observer.

Northern Drone Worx LLC will only utilize PIC's with a valid Recreational or Private Pilot rating certificate 

issued by the FAA for operation of all UAV's and a Class II Medical Certificate. Additionally, all pilots will 

be assisted by a safety observer. The pilot in command and safety observer must meet the requirements 

as set forth by the Operations Manual adopted by Northern Drone Works for flight operations of the 

UAV's.

CONLUSION:

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 within visual line of sight 

and national security - provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant's UAS field of operation as described within.

Eric Munson

Northern Drone Worx LLC 

Duluth, MN 55811

(218) 461-2857

Email: emunson@lakesuperiorhelicopters.com