INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC.

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

INTERNATIONAL-WIND, INC.

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 June 3, 2015

International-Wind, Inc.

Cory Arendt (Pro Se.)

1540 Gaylord Street

Long Beach, CA 90813

Phone: (562) 472-1500

Email: CArendt@International-Wind.com
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 2

TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS ...........................................................................3

SUMMARY ...................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER .....................................4

BACKGROUND ..........................................................................................................5

BASIS FOR PETITION ...............................................................................................7

NAME AND ADDRESS OF PETITIONER ................................................7

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

 INTERNATIONAL-WIND, SEEKS EXEMPTION ......................7

THE EXTENT OF RELIEF INTERNATIONAL-WIND SEEKS 

AND THE REASON INTERNATIONAL-WIND, SEEKS RELIEF........12 

REASONS WHY GRANTING INTERNATIONAL-WIND, 

REQUEST WOULD BE IN THE PUBLIC INTEREST ............................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD

 NOT ADVERSELY AFFECT SAFETY...........................................13

FLIGHT OPERATIONS ...............................................................................15

CONCLUSION ...........................................................................................................18
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 3

GLOSSARY OF ABREVIATIONS

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

VMC Visual Meteorological Conditions

VTOL Vertical Take Off and Landing 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 4

SUMMARY

International-Wind, Inc., 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 International-Wind, Inc. to operate its various Unmanned 

Aircraft Vehicles (“UAV”) at or above wind power generation facilities, wind turbines, wind turbine blades, wind turbine nacelles and other remote/uninhabited locations, while keeping the 

documents required by the regulations at the ground control station and immediately accessible to 

the pilot in command. Furthermore, the exemption will relieve International-Wind, Inc. 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

International-Wind, Inc. is a 7 year old wind power plant inspection firm with a long and 

well-recognized history in 3rd party inspections, Operations & Maintenance, Expert Witness 

Services and Root Cause Analysis of failures in the power generation and composites industry. 

International-Wind, Inc. has an extensive history of utilizing multi-rotor Vertical Take Off and 

Landing Unmanned Aerial Vehicles, (VTOL) (UAV’s), for the purpose of making highly accurate 

aerial inspections of wind turbine rotor blades and onshore pipelines for a range of clients and 

various similar applications. 

Since 2008, International-Wind, Inc. has been operating a variety of VTOL aircraft for 

wind power plant aerial inspections and will continue to acquire additional UAV’s all under 55 

lbs in weight. As set forth in this Petition, International-Wind, Inc. seeks to operate its UAV’s for 

the special purpose of aerial inspections of its legacy power generation customers and to expand 

to support the growth of new customers in the onshore and offshore regions of the United States. 

International-Wind, Inc. plans to do this with a continued focus on safety and the highest standards of quality, maintenance and reliability.
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 5

BACKGROUND

Unmanned Aircraft Vehicle: Inspire 1 UAV

International-Wind, Inc. seeks an exemption to operate its existing 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: 300°/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

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438 x 451 x 301 mm

For more information on DJI Inspire 1 user manual, visit: 

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 6

FIGURE 1: INTERNATIONAL-WIND’S INSPIRE 1 WITH BUILT IN VIDEO/CAMERA SYSTEM

International-Wind, Inc. will submit an Aircraft Registration Application for each UAV upon the grant 

of the exemptions sought by this Petition. 

Proven Operational History of: Inspire 1 UAV in the NAS

The DJI Inspire 1 UAV’s are currently operating safely within the NAS. International-Wind, 

Inc. has been operating UAV’s under 55lbs for the past 5 years without any recorded incident, accident 

or failure. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 7

In accordance with 14 C.F.R. § 11.81, International-Wind, Inc. 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: 

 International-Wind, Inc.

 Mailing Office: 1540 Gaylord Street; Long Beach, CA 90813

 General Office: 1540 Gaylord Street; Long Beach, CA 90813

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

 Cory Arendt

 International-Wind, Inc.

 Mailing Office: 1540 Gaylord Street; Long Beach, CA 90813

 Phone: (562) 472-1500

 Email: CArendt@International-Wind.com

The Specific Sections of 14 C.F.R. From Which International-Wind, Inc. 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 International-Wind, Inc., 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. 

BASIS FOR PETITION

Petitioner, International-Wind, Inc., 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. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 8

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 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 at least a 

sports or recreational 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, International-Wind, Inc.’ 

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 InternationalWind, Inc. Operations Manual IWI-006 Rev. 3 (Manual). The level of safety provided by the

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 International-Wind, Inc. Operations Manual. 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 than 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.
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 9

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 ...

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.

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. 

(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 

Rotor craft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof.

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. 

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 competent trained and experienced Remote Controller 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. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 10

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 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 International-Wind, Inc.’ 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.

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. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 11

11. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

All of International-Wind, Inc.’ 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. 

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.

(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.

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 International-Wind, Inc. Maintenance will be accomplished by 

International-Wind, Inc. pursuant to the flight manual and operating handbook as referenced in the 

Manual.(See Sections L and Q) 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, International-Wind, Inc. 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.

International-Wind, Inc. 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.

International-Wind, Inc. 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.
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 12

Pursuant to the FAA Modernization and Reform Act of 2012, Section 333 (“Section 333”), 

International-Wind, Inc. seeks relief from the airworthiness certificate requirements of the FAR 

because operation of the Inspire 1 UAV 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 sub 

section (a), the Secretary shall determine, at a minimum--

(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 Inspire 1 UAV in the NAS, as well as the 

specific parameters of International-Wind, Inc.’ intended operation pursuant to this exemption, demonstrate that the Inspire 1 UAV 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 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.

13. The Extent Of Relief International-Wind, Inc. Seeks And The Reason International-Wind, 

Inc. Seeks Relief From 14 C.F.R. § 21.185. 

International-Wind, Inc. seeks relief from the airworthiness certificate requirements of the 

Federal Aviation Regulations and proposes to commercially operate the Inspire 1 UAV, 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”). 

International-Wind, Inc. seeks relief from the airworthiness certificate requirements of 14 C.F.R. § 

21.185 to the extent that the Inspire 1 UAV, 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). 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 13

********* 

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:

International-Wind, Inc. 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, an International-Wind, Inc. 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 International-Wind, Inc. 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 International-Wind, Inc. 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 International-Wind, Inc.’s Request Would Be In The Public Interest

Granting the present Petition will further the public interest by allowing International-Wind, Inc. to 

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

wind turbines, wind turbine blades, wind turbine nacelles and land development. Additionally, use 

of the International-Wind, Inc. UAV’s will increase worker safety by reducing human exposure to 

rope access work at extreme 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 International-Wind, Inc. UAV will be realized without implicating any 

privacy issues. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 14

Figures 2 & 3: Photos of Current Rope Access Inspection Techniques

Figures 4: Hypothetical Experience Utilizing DJI Inspire 1 for Inspections

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. 

Set forth below are pictures of aerial inspections conducted in the day environment, as performed today using humans on ropes. The grant of this exemption request will provide improved 

safety in day operations.
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 15

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. International-Wind, Inc. proposes to only conduct aerial inspection flight operations over private land, in rural areas of the United States that are 

not near populated areas, airports, helipads, or state roads.

Specifically, International-Wind, Inc.’ proposed areas of aerial inspections 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.

International-Wind, Inc. 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 InternationalWind, Inc.’ UAV’s will be operated utilizing Category “A” No Fly Zone restrictions. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 16

For more information on DJI flysafe zone settings for the Inspire 1, visit: 

https://youtu.be/YoXAMRQoIAA

Figure 5 - 8: Example of Category “A” No Fly Zone for International-Wind, Inc.

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, International-Wind, Inc. seeks to operate its UAV’s only over rural 

areas, while maintaining safe distances from any populated areas, airports, helipads, or roadways. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 17

Operation Of International-Wind, Inc.’ UAV’s Will Be Conducted Pursuant To “IWI-006 UAS 

Operations Manual (For UAS’s under 55 lbs).” 

International-Wind, Inc.’ Operations Manual IWI-006 will control operation UAV’s and will 

significantly contribute to maintaining the level of safety contemplated by the airworthiness certificate requirements from which International-Wind, Inc. 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 International-Wind, Inc.’ 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 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, to International-Wind, Inc., is attached hereto as Exhibit 

B, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).3 

Flight Operations Of International-Wind, Inc.’ UAV’s Are Limited To Line Of Sight Of The PIC 

With A Safety Observer. 

International-Wind, Inc. will only utilize PIC’s with a valid competent trained and 

experienced Remote Controller Pilot 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 International-Wind, Inc. for flight operations of the UAV’s. 
INTERNATIONAL-WIND SECTION 333 PETITION 1540 West Gaylord Street Long Beach,CA 90813 Page 18

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 in the power generation 

industry pursuant to the Manual appended hereto. 

Submitted on June 3, 2015

Cory Arendt (Pro Se.)

1540 Gaylord Street

Long Beach, CA 90813

Phone: (562) 472-1500

Email: CArendt@International-Wind.com