1 | Page 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).

CONCERN ING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on January 9 , 201 6

Northern Drone Works LLC

Eric Munson 4525 Airport Approach Rd

Duluth MN 55811

Tel: (218) 461

- 2857

Email: em unson@lakesuperiorhelicopters.com2 | Page 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

.......................................................................................................................... 1 5

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

.................. 16

FLIGHT OPERATIONS........................................................................................................................................... 1 7

CONCLUSION........................................................................................................................................................ 1 8

Northern Drone Worx LLC F l ight 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

N AS 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 Rules3 | Page VMC Visual Meteorological Conditions VTOL Vertical Take Off and Landing



## SUMMA RY

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 Wor x , LLC. to operat e 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 regulation s 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 t he 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 L LC 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

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

meet s all safety and certification requirement designated by the FAA.

Northern Drone Worx LLC includes direction and supervision from Dennis O’Hara/Nor thern Images, who currently operates under an existing 333 Exemption holder. Exemption No. 12431, Regulatory Docket
No. FAA

– 2015

– 2247. Th is request is for a new 333 under Northern Drone Worx LLC.

As set forth in this Petition, Northern Drone Worx LLC w ill be operat ing its UAV's for the purpose of aerial inspections of its existing electric and gas customers and to expand to support the growth o f new
customers in the Midwest wind farms and other infrastructure rel ated facilities

. In addition, Northern

D rone Worx LLC will provide aerial photography and videography as a service to other customers as the opportunity arise s

. Northern Drone Worx LLC plans to do this with a continued focus on safety wh i ch has been developed thro u gh its aviation culture dev elop e d in manned flight operations and the highest standards of quality, maintenance and reliability.4 | Page 

## BACKGROUND

Unmanned Aircraft Vehicle: DJI PHANTOM 3

Northern D rone 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 U AV has a maximum gross weight of approximately two ( 2 ) pound s and the following technical and operational specifications:

Weight (Battery & Propellers included)

- 1 2 8 0g

Hover Accuracy (Ready to Fly)

- Vertical: 0. 1 m; Horizontal: .5m Max Yaw Angular Velocity

- 2 00°/s

Max Tilt Angle

- 35°

Max Ascent / Descent Speed

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

- 15m/s

Diagonal Length

- 350mm Power Consumption

- 5.6W Flight Time

- 25mins

Take

- off Weight

- ?1300g

Operating Temperature

- - 0 °C ~ 4 0°C Supported Battery

- DJI Intellige nt Battery Type

- 4 S LiPo

Capacity

- 4 480 mAh, 1 5.2 V

Operating Frequency

- 2.4GHz ISM L ightbridge

Receiver Sensitivity (1%PER)

-- 97dBm

Working Current/V oltage

- 100 mA@6V Battery

- 6 s Lipo

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

Four (4) Lithium Polymer battery powered electric motors.5 | Page FIGURE 1: Northern Drone Worx LLC, DJI PHANTOM 3 Professional

Nort hern Drone Worx LLC will submit an Aircraft Registration Application for each UAV upon the grant of the exemptions sought by this Petition.6 | Page 

### 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) pound s and the following technical and operational specifications:



### Aircraft Model T 600
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 4500 m

Max Wind Speed Resistance 10 m/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 mm7 | Page 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 ha s been operating UAV's under 55lbs for the past 5 years without any recorded incident,
accident or failure.8 | Page 

### Unmanned Aircraft Vehicle: D JI S900 UAV

Northern Drone Worx LLC seeks an exemption to operate a DJI Spreadi ng Wings s900 , UAV, for compensation or hire within the national airspace system ("NAS").

The Inspire s 900 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) pound s and the following technical and operational specifications:

Takeoff Weight 6 Kg (17 lbs)

Total Weight 6 Kg

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) 35g9 | Page 

### Unmanned Aircraft Vehicle: Y uneek 500 H UAV

Northern Drone Worx LLC seeks an exemption to operate an Y uneek 500 H UAV, for compensation or hire within the national airspace system ("NAS").

The Y uneek 500H UAV is comprised of a VTOL unmanned aircraft and a transportable ground station.
The Y uneek 500H UAV has a maximum gross weight of approximately e ight and one half ( 8 .5) pound s 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

Geofenc ing

15.5 Volts Lipo 4 C

Intel Sense and Av oid

4k Camera10 | Page 

## BASIS FOR PETITION

Petitioner, Northern Drone Worx LLC, pursuant to the provisions o f 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 spe cified 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, N orthern Drone Worx LLC provides the following information in support of its petit ion for exemption:

A) Name and Address of t he Petitioner.

The name and address of th e 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.com11 | Page 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 cap ability, 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 propos ed 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. f ully 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 t his 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 pub lic 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.

Co mmunications with all Infrastructure operating personnel and auth orities is required by Northern

D r one Works LLC SOP ’ s and appropriate no tams and COA ’ s will be filed.

2. 14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requir es: 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 aircraf t 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 each12 | Page 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 require d 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 p assengers, 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 N orthern Drone Worx LLC Opera tions 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 UA Vs 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 fo rth 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, 9 299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.13 | Page 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 takeo ff 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 u nless 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. Sect ion 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

- ro tor 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 pr e

- 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. Be cause 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 weight ing 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 regulati on 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 baro metric altimeter, but instead a GPS altitude14 | Page 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 alt itude 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 N orthern Drone Worx LLC ’ s UAV's provide approximately 3 5 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 limi tation would prohibit the flight of the UAV's a longer time frame for flight in daylight or night VFR conditions is reasonable.

N orthern Drone Works LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exe mption 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 a llowed, 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 util ity for which the exemption will be granted.

N orthern 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 planne d 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 Registr ation

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 c ivil 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 N orthe r n 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.15 | Page 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 representa tive 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 o r 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

o thers 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 accompli shed by Northern
Drone Worx LLC pursuant to i ts 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, N orthern Drone Worx L LC 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 airwor thy condition to provide the equivalent level of safety.

13. The Extent of Relief Northern Drone Worx LLC Seeks a nd The Reason Northern Drone Worx LLC
Seeks Relief f rom 14 C.F.R. § 21.185.

Northern Drone Worx LLC seeks relief from the airworthiness ce rtificate requirements of the Federal Aviation Regulations and proposes to commercially operate the DJI PHANTOM 3

, Inspire 1

, Spr eading Wings s900 and Yuneek 500H Typhoon UAV ’ s , without an airworthiness certificate, for the special purpose of conducting aerial inspection services for its customers, p ursuant to specific operating limitations and a Safety Management System ("SMS"). N orthern Drone Worx L LC seeks relief from the airworthiness certificate requirements of 14 C.F.R. § 21.185 to the extent that the DJI PHANTOM 3
, Inspire 1

, Spr eading Wings s900 and Yuneek 500H Typhoon UAV ’ s , which hav e 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"), N orthern
Drone Worx L LC seeks relief from the airworthiness certificate requirements of the FAR because operation of the DJI PHANTOM 3
, Inspire 1

, Spr eading 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 thre at 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

--16 | Page (1) W hich types o f 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 t he 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 s ystems identified under paragraph (1set forth below, numerous factors, including the proven safe operational history of the DJI PHANTOM 3
, Inspire 1

, Spr eading Wings s900 and Yuneek 500H Typhoon UAV ’ s in the NAS, as well as the specific parameters of Lake Superior Helicopters intended operation pursu ant to this exemption, demonstrate that the DJI PHANTOM 3 Inspire 1

, Spr eading 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 approv e 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 t o 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:

N orthern 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 certificat ion 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 N orthern 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

r equested herein, including exempting the N orthern 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, a re far safer than conventional operations conducted by humans dangling from ropes.

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

Granting the present Petition will further the public interest by allowing N orthern 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 N orthern Drone
Worx LLC UAV's will increase worker safety by reducing human exposure to rope access work at extreme17 | Page 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

N orthern 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. N orthern 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 o perations 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 with in 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.

N o rthern 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 N orthe rn Drone Worx UAV's will be operated utilizing Category "A" No Fly Zon e 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 r esult 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, N orthern Drone Worx LLC seeks to operate its UAV's only under c ontrolled conditions

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

Operation of Northern Drone Worx LLC UAV's w ill b e Conducted Pursuant To " N DW UAS Operations
Manual (Attachement A) ."

N orthern Drone Worx LLC Operations Manual N DW

- 00 1 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 N o rthern 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 Continued18 | Page Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator. Each person shall u se 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
incl uded in attachment A and is proprietary , and is a separate file pu rsuant to 14 C.F.R. § 11.35(b).

Flight Operations of N o rthern Drone Worx LLC UAV's Are Limited to Line of Sight o f 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 N orthern 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 capabilit ies, 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 f iel d of operation as described within.

Eric Munson

Northern Drone Worx LLC

Duluth, MN 55811

(218) 461

- 2857

Email: emunson@lakesuperiorhelicopters.com