Atlanta AirWorX, Inc.,

Shawn Rolison

2285 Metropolitan Pkwy

Atlanta, GA 30315

Phone: 404-427-5322

December 12

th 2015

United States Department of Transportation

Federal Aviation Administration

Docket Operations

1200 New Jersey Avenue SE

Washington DC 20590

Re: Petition for an exemption seeking relief from specific sections of Title 14 CFR under Section 333 of 

the FAA Modernization and Reform Act of 2012 (Public Law 112-95)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11 

Atlanta AirWorX, Inc. hereby seeks an exemption from the Federal Aviation Regulations as 

detailed below for the purpose of conducting commercial Unmanned Aerial System (UAS) operations in 

the National Airspace System (NAS).
TABLE OF CONTENTS

 Page

NAME AND ADDRESS OF THE PETITIONER...............................................................4

BACKGROUND AND OPERATING DESCRIPTION.......................................................4

DESCRIPTION OF UAVs AND GCS...............................................................................5

SECTIONS OF 14 CFR FROM WHICH

Atlanta AirWorX, Inc., Inc. SEEKS EXEMPTION...............................................................8

PUBLIC INTEREST........................................................................................................12

SAFETY..........................................................................................................................12

SUMMARY SUITABLE FOR THE PUBLIC REGISTER..................................................13

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS.....................................13
NAME AND ADDRESS OF THE PETITIONER:

The name and address of the petitioner is:

Atlanta AirWorX, Inc.

Shawn Rolison

2285 Metropolitan Pkwy

Atlanta, GA 30315

Phone: 404-427-5322

BACKGROUND AND OPERATING DESCRIPTION

Atlanta AirWorX, Inc. seeks exemption from the requirements of 14 CFR FAR Parts 91.7 (a), 91.9 (b) 2, 

91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b) pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012. This exemption will permit Atlanta 

AirWorX, Inc.to obtain an appropriate Certificate of Authorization to operate the described UAV aircraft 

below within the NAS for the commercial purpose of collecting aerial photo and video information and 

data.

Atlanta AirWorX, Inc. was formed in 2015 by Shawn Rolison. Mr. Rolison has been flying and building RC 

aircraft recreationally for over 20 years and has 5 years of experience operating the type of UAVs that will 

be flown under the desired exemption. Atlanta AirWorX, Inc. seeks to provide aerial photo and video 

services for a variety of clients. Examples of services shall include but not be limited to; construction job 

site progression and mapping, search and rescue, golf course mapping, mining research, 

residential/commercial real estate brokers, insurance companies, roofing/construction contractors, 

filming/cinematic companies.

As set forth in this petition, Atlanta AirWorX, Inc. seeks to commercially operate its UAVs with the highest 

level of safety and professionalism. 
Skyhunter FPV UAV:

The Skyhunter 1.8M UAV is a professional FPV Fixed Wing UAV aircraft. The unit is hand launch and is 

belly recovery. It is powered by one (1) 3540 Electric Motor and 2 5000-10,000mAH battery packs. It is 

ready to fly with a gross weight of 6.61 pounds with a flight duration of 30 minutes on a fully charged 

battery. It has a maximum speed of 43.44 knots. The Skyhunter has the capability to have two operators, 

one flying the UAV while the other operates the cameras. The flight controller for the Skyhunter is a APM 

2.6, which is capable being fully autonomous. It works with Mission Planner Software and offers such 

modes as GPS Lock, auto landing, auto takeoff, as well as sophisticated mission planning and camera 

controls. The user can define maximum flight parameters such as altitude and/or lateral distance from 

the GCS. 

The Skyhunter uses a separate system to transmit live video feed that displays live video data and flight 

information to the operator and/or Visual Observer (VO).

Ground Control Station (GCS):

A ground station is typically a software application, running on a ground-based computer, that 

communicates with the Skyhunter UAV via wireless telemetry. It displays real-time data on the UAVs 

performance and position and serves as a “virtual cockpit”, showing many of the same instruments that 

you would have if you were flying a real plane. A GCS can also be used to control a UAV in flight, uploading 

new mission commands and setting parameters. It is often also use to monitor the live video stream from 

a UAV’s cameras.

DJI F550 UAV:

Atlanta AirWorX also plans on operating a DJI F550 Hexacopter. Operation is similar to a DJI Phatom 

and Inspire. The DJI Flamewheel 550 is a proven airframe used by many for professional aerial 

photography. It’s ready to fly with a gross weight is 5.3 pounds with a flight duration of 20 minutes on a 

fully charged battery. It has a maximum speed of 25 knots. 

The DJI F550 has a separate system to transmit live video feed that displays live video data and flight 

information to the operator and/or Visual Observer (VO).
SPECIFIC SECTIONS OF 14 CFR FROM WHICH Atlanta AirWorX, Inc., SEEKS EXEMPTION AND THE 

EXTENT OF RELIEF SOUGHT AND THE REASON THAT THE RELIEF IS SOUGHT

The petitioner believes that as per Section 333 of PL 112-95, and in consideration of the size, weight, 

speed, and limited operating area associated with the aircraft and its operation, that relief from 14 CFR 

Part 21 Subpart H regarding Airworthiness Certificates is not necessary and therefore relief is not sought.

FAR Part 91.7 (a) prescribes that;

No person may operate a civil aircraft unless it is in an airworthy condition.

Relief is requested to maintain an airworthy condition by compliance with the operating procedures and 

documents prescribed in this petition prior to every flight.

FAR Part 91.9 (b) 2 prescribes that;

(b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter unless there is 

available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided 

for in § 121.141(b); and

(2) (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.

Relief is requested to comply by keeping all relevant company operating procedures, limitations, 

logbooks, and checklists in a location accessible to the PIC.

Far Part 91.119 prescribes in part that;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes:

(c) Over other than congested areas. 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.
Relief is sought for FAR 91.119 (c) because that UAV aircraft will be operated below 400 feet AGL and 

would not be able to comply with this subparagraph. Petitioner would operate in accordance with the 

limitations described in this petition or by any other limitations the FAA deems necessary.

Far Part 91.121 prescribes in part that;

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station;

or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure;

or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

Relief is sought because the UAV aircraft does not have a typical barometric altimeter on board, and all 

reported altitudes will be reported in feet AGL.

Far Part 91.151 (a) prescribes that;

(a) No person may begin 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.

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.
Relief is sought to operate at less than the prescribed minimums because UAV will never be flown more 

than 1/2 mile from the point of intended landing, and that safety will be maintained by monitoring the 

elapsed time in flight, real time battery voltage condition, and the 2 level low battery warnings detailed 

above in the UAV description. The PIC will never begin a flight unless there is enough power to fly to the 

intended point of landing at normal cruising speed and still land with 20% battery power remaining.

Far Part 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b) prescribe that -

91.405 (a)

Each owner or operator of an aircraft—

(a) 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;

91.407 (a) 1

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and

91.409 (a) 1 and 2

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

91.417 (a) and (b)

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, 

the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service.

Relief from these sections is sought because it is our intention to perform any maintenance and 

inspections as described in the operations manual of either UAV above and that this will ensure a high 

level of safety. The PIC will be responsible for ensuring that the aircraft is in airworthy condition prior to 

every flight. The PIC will document any work performed in the aircraft logbook as well as cumulative flight 

time.

SIMILAR EXEMPTIONS They are similar in all/or many material respects to relief previously requested in 

Grant of Exemption Nos. 11062, 11109, 11112, and 11213 
PUBLIC INTEREST

The use of sUASs can significantly promote safe and effective Construction Jobsite inspection and tracking. 

The use of sUASs can reduce the risk to workers while inspecting, surveying, or monitoring installation of 

work that requires ladders, scaffolds or other potentially hazardous means of elevated access. sUASs can 

inspect, photograph, video and collect data on inaccessible areas that otherwise would require worker 

inspection, in addition to providing facility security and emergency response reconnaissance. sUASs can 

also provide high resolution aerial imagery, elevation measurement, mapping, and thermal imagery data. 

Reducing manned flight and human inspection of such sites through sUAS use for site imaging will reduce 

risk to workers and ground personnel and create an improved safety operating environment. Manned 

aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The sUASs that will be 

used carry no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is 

eliminated.

THE REASONS WHY GRANTING THE REQUEST WOULD NOT ADVERSELY AFFECT SAFETY

Because of the speed, weight, size, and limited operating area associated with the proposed UAV aircraft operations, 

the Petitioner submits that our proposed flights would not create a hazard to other users of the NAS or to the public 

or otherwise pose a threat to national security. 

I also submit that Atlanta AirWorX, Inc. can safely operate in the NAS pursuant to FMRA Section 333 because:

➢ The PIC is qualified and has an abundance of operational experience.

➢ Flights will be operated within line of sight of a pilot and/or observer. 

➢ Flights will be terminated at 20% battery power reserve. 

➢ Flights will be operated at an altitude of no more than 400ft AGL 

➢ Flights will only be operated in reasonably safe environments that are strictly controlled, are away from airports 

and actively populated areas. 

➢ A briefing will be conducted for planned UAS operations prior to each flight. 

➢ Consent will be obtained from all persons involved in the operation. 

➢ If the UAS loses communications, the UAS will be placed in "Return to Home" mode and will return to its point of 

takeoff. 

➢ The UAS flight will be aborted should circumstances arise that would create a potential hazard to person or 

property.

➢ Atlanta AirWorX, Inc. will operate to ensure the highest level of safety to ourselves, our clients, and the public.
SUMMARY SUITABLE FOR THE PUBLIC REGISTER

Atlanta AirWorX, Inc. seeks exemption from the requirements of 14 CFR Parts 91.7 (a), 91.9 (b) 2, 91.119, 91.121, 

91.151 (a), 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b). This exemption will permit Atlanta AirWorx, 

Inc.to commercially operate a UAV aircraft for the purpose of collecting aerial photo and video assets for a variety a 

clients.

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 Section 333. As stated above, 

Atlanta AirWorX, Inc., Will operate safely in the NAS without creating an undue hazard to other users of the NAS, 

the general public, or by posing a threat to national security. Atlanta AirWorX, Inc., operation will also provide a 

benefit to the public interest as detailed in this petition.

In Conclusion: Atlanta AirWorX, Inc., the Petitioner request for exemption from the above mentioned 

Federal Aviation Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the 

National Airspace System in order to perform the Applications and Operations pertaining to my business

in a safe and controlled environment. The Petitioner hopes for a timely consideration as I have made a 

considerable investment in time and finances on this project.

Sincerely,

Atlanta AirWorx, Inc.

Shawn Rolison, President

2285 Metropolitan Pkwy

Atlanta, Georgia 30315

404-427-5322

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