May 5, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave SE 

Washington, DC 20590 

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

Dear Sir/Madam, 

This petition is being submitted on our own behalf without legal counsel or consulting services. 

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

C.F.R. Part 11, Aeroworks Productions LLC, a Wisconsin based limited liability company operating a Small 

Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and surveys for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration 

(FAA) so long as such operations are conducted with and under the conditions outlined herein or as may

be established by the FAA as required by Section 333. 

The requested exemption would permit Aeroworks Productions LLC to pursue its commercial interests 

in providing services to consumers interested in aerial data capture using a small advanced sUAS in the 

following areas: 

• Infrastructure Inspections 

• Real Estate Photography 

• Agricultural Surveying and Data Collection 

• sUAS Operator Training 

• Product Demonstrations 

• Research and Development 

Aeroworks Productions LLC states that all sUAS flights that will occur over private or controlled access 

property will do so with the property owner’s prior consent and knowledge and that only people who 

have consented or otherwise have agreed to be in the area where photography and videography will 

take place will be captured. 
Additionally, Aeroworks Productions LLC pilots hold FAA Commercial and Private Pilot Licenses with 

Class II and Class III Medical Certificates and if observers are not qualified pilots, they will be trained by 

AWP pilots to understand the proper roles of an observer, communication procedures, proper visual 

scan techniques, operations at non-towered airports, and appropriate sections of the Aeronautical 

Information Manual. 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401 – 91.417) 

Unmanned Aircraft System 

sUAS are a feasible method to obtain high quality imagery and data that can be used independently - or

in the case of surveying and modeling, can be combined to produce precision digital point clouds, 

triangle models, and contour maps of the surveyed area. Applications for these sUAS include inspection 

of sensitive infrastructure including oil and gas pipelines and flare stacks, power lines and towers, wind 

turbines, and surveying tasks such as precision agriculture, mining, transportation, and forestry. Use of 

the proposed sUAS for these inspection and surveying applications reduces the need to operate 

conventional aircraft, providing data more quickly, accurately, economically, safely, and with reduced

environmental impact. 

We are petitioning for exemption to enable Aeroworks Productions LLC to operate an Aeryon Labs Sky 

Ranger multi-rotor equipped with EO/IR and HD Zoom camera payloads, a DJI Inspire 1 multi-rotor 

equipped with a three-axis gimbaled camera, a Zero-Tech High One quadcopter with 3 axis stabilized 

camera gimbal and a 3D Robotics AERO fixed wing sUAS equipped with a fixed position multi-spectral 

camera. These sUAS all weigh less than 25 lbs; have a built-in capability to limit the height it flies above 

the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C 

and D airspace including a no fly zone feature. Each system also has the failsafe function of the 

autopilot system, which means when the communication between the Main Controller and the 

transmitter is lost; the system will automatically trigger Return to Home and will land safely. 

 

The above specifications meet standards listed below, some derived in accordance with Model Aircraft 

Operating Standards: 
• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will 

operate at sites that are a ‘sufficient distance’ from populated areas within the sterile area 

described in the operator’s manual. Such operations will insure that the sUAS will “not create a 

hazard to users of the national airspace system or the public.” 

• When flying sUAS within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 60 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 60 minute 

limit. 

• The sUAS will be programmed so that it will not be operated at an altitude of no more than 500 

feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 

• The sUAS PIC’s (Pilot in Command) will be an FAA licensed airman holding a FAA Private Pilot or 

Commercial Certificate and second Class FAA Medical Certificate. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbal). 

• The sUAS will operate at speeds of no more than 85 knots. 

• Given the small size of the sUAS and the restricted sterile environment within which they will 

operate, our sUAS operations adhere to the Reform Act’s safety requirements. 

Additionally, the fact that the Aeroworks Productions LLC pilots hold FAA Pilot certificates demonstrates 

that they have a high regard to safe operations with an understanding of FARs, pre-flight inspections,

maintenance and repair, operations within airspace, as well as being trained to high safety standards.

Under the requested exemption, Aeroworks Productions LLC ensures that all operators have completed 

a small unmanned aircraft systems (UAS) education and training program including all applicable 

regulations and guidance documents; including aeronautical background information such as charts, 

NOTAMS and Aircraft Circulars; Radio Communications and Procedures; Human Factors and Crew 

Resource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and Decisionmaking and Safe Operating Procedures. 

Aeroworks Productions LLC at all times will respect the space and privacy of citizens and property while 

keeping our skies safe. We respectfully request, without delay, an exemption under Section 333 to 

enable Aeroworks Productions LLC to operate safe, low-risk commercial sUAV operations for the 

activities stated. 

Sincerely, 

Adam S. Andrews 

Director of Operations 

Aeroworks Productions, LLC 

7740 29th Ave 

Kenosha, WI 53143 

262-455-5135 
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Aeroworks Productions, LLC. requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAS System: 

14 CFR Part 21, Airworthiness Certificates 

 This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the DJI Inspire 1, Aeryon Labs Sky Ranger, Zero-Tech High One 

and 3D Robotics AERO sUAS under either or both of the following provisions: 

21.191 Experimental certificates

 Experimental certificates are issued for the following purposes: 

(a) Research and development Testing new aircraft design concepts, new aircraft equipment, new 

aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance of type 

and supplemental type certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. Since the experimental 

certificate can be used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements. Combined with the UA's light weight, being constructed primarily of 

foam, carbon fiber, and/or plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an experimental airworthiness 

certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Sub 

part H, and the requirement for an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks 

 These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word “EXPERIMENTAL" 

in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAS does 

not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a 

registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by 

including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where 

the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will

provide the aircraft's registration information at the ground station. Finally, we will display at the ground 

station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in 

letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the 

banner should be visible to anyone that observes the aircraft and chooses to investigate its point of 

origin. 
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations 

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command 

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in 

command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or property 

for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot 

Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we 

meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a 

business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate 

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements 

 This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation; the documentation would 

not be available to the crew during flight operations. To obtain an equivalent level of safety and meet 

the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight. 

 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." The sUAS System ground-based control station 

consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", 

both the student and instructor can, and will, operate the single set of controls simultaneously. With

both student and instructor having "hands-on" the controls during flight, we feel that this technique 

meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated 

areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or 

structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only 

be flown over property or persons where permission has been obtained and careful pre-planned has 

been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we maintain 

that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption. 

14 CFR 91.121 Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes 

by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly

below 500 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with 

other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via

radio from the sUAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout. 
 14 CFR 91.151 Fuel requirements for flight in VFR conditions 

 The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The sUAS are battery operated and the maximum duration of flight from a single 

battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will 

never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to 

the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request 

exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of 

intended landing and have at least a 20% battery reserve after that. 

 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required 

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) 

provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew." With our largest vehicle, the 3D Robotics AERO, at a maximum gross 

weight of 13 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is 

not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent 

of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be colocated with the crew at the ground control station and available for inspection upon request. In order 

to identify the aircraft, we propose that the information found on airworthiness and registration 

certificates be permanently affixed to the aircraft via placard containing the following information plus 

the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the

aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections 

after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and firmware for the onboard computer. All other maintenance will be performed by the manufacturer or their designated 

repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to 

the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.