1

March	04,	2016

Attn:

U.	S.	Department	of	Transportation	Docket	Operations	

West	Building	Ground	Floor,	Room	w12-140	

1200	New	Jersey	Ave,	SE	Washington,	DC	20590

RE:	HELIX	DRONES,	LLC

REQUEST	AN	EXEMPTION	FROM	THE	REQUIREMENTS	OF	TITLE	14	OF	THE	CODE	OF	FEDERAL	

REGULATIONS

SECTIONS	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	

(a)(2),	AND	91.417(a)	&	(b)	CONCERNING	COMMERCIAL	OPERATION	OF	DJI	PHANTOM 4

UNMANNED	AIRCRAFT	SYSTEMS PURSUANT	TO	SECTION	333	OF

THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012	(PUBLIC	LAW	112-95)

Scotty	Runyan

President	

Helix	Drones,	LLC

2025	Flightway	Dr.

Chamblee,	GA	30341

678-232-0090
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GLOSSARY	OF	ABBREVIATIONS

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial	Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation	

GCS Ground	Control	Station	

GPS Global	Positioning	System

LOL Loss	of	Link	

NAS National	Airspace	System

NOTAM Notice	to	Airman

PIC Pilot	In	Command

Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	

SO Safety	Observer

SOP Standard	Operating	Procedures

UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

VFR Visual	Flight	Rules

VLOS Visual	Line	of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Takeoff	and	Landing
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SUMMARY

Helix	Drones,	LLC hereafter	referred	to	as	HELIX	DRONES	seeks	exemption	from	the	

requirements	of	14	C.F.R	§§	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	to	operate	an	Unmanned	Aircraft	Systems (DJI	

Phantom	3 and	DGI	S1000+) pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	

of	2012	(FMRA).	This	exemption	will	permit	The	HELIX	DRONES to	operate	an	Unmanned	

Aircraft	System	(UAS)	for	the	commercial	purpose	of	conducting	utility	line	inspections,	aerial	

video	and	photography.

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

HELIX	DRONES	is	a	subsidiary	of	Helicopter	Express,	Inc.	a	14	CFR	135	Air	Carrier	(Certificate	

Number	H11A981I).	Helicopter	Express	has	for	20	years	provided	their	clients	(including	private	

sector	businesses,	state,	and	federal	agencies)	with	expertise	in	flying	critical	missions	

effectively	and	safely.	Helicopter	Express	has	flown	approximately	27,500	accident	free	hours	in	

the	previous	5	years.	Much	of	that	flight	time	has	been	in	the	low	level	environment	where	we	

intend	on	operating	our	UASs.	The	mission	of	HELIX	DRONES	will	be	to	extend	the	same	

professionalism	and	safety	culture	in	our	manned	missions	into	our	UAS	venture. Multiple	pilots	

on	staff	have	been	flying	the	DJI	Phantom	series	as	a	hobby	for	more	than	16	months.

BACKGROUND

Unmanned	Aircraft	Systems:	DJI	Phantom	3,	UAS

HELIX	DRONES seeks	an	exemption	to	operate	DJI	Phantom	3	system for	compensation	or	hire	

within	the	NAS.	The	DJI	Phantom	3 is vertical	takeoff	and	landing	(VTOL)	Unmanned	Aircraft	

(UA)	with	a	Ground	Control	Station	(GCS)	utilizing	electronic	tablet	or	smart	phone	systems.	The	

DJI	Phantom	3 has	a	maximum	gross	weight	of	approximately	2.8 lb. while	having	a	diagonal	

dimension	of	23.2”,	a	maximum	speed	of	approximately	16.4’fps and	a	maximum	flying height

of	400'.	The	DJI	Phantom	3	is	equipped with	four	main	rotors;	driven	by	Lithium	Polymer	

battery	powered	electric	motors.	

The	DJI	Phantom	3 that	will	be	operated	by	HELIX	DRONES will	be	registered	in	accordance	with	

49	U.S.C.	44103,	Registration	of	Aircraft,	as	well	as	14	C.F.R	Part	47,	Aircraft	Registration,	and	

marked	in	accordance	with	14	C.F.R.	Part	45,	Identification	and	Registration	Marking.

Unmanned	Aircraft	Systems:	DJI	S1000+
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The	DJI-S1000+	is	comprised	of	a	multi-rotor	unmanned	aircraft	and	two	handheld	ground	

control	stations.	The	DJI-S1000	has	a	maximum	gross	weight	of	approximately	24	pounds,	

diagonal	wheelbase	of	41.4	inches,	and	height	of	approximately	18	inches.	The	DJI- S1000	is	

equipped	with	eight	rotors	driven	by	eight	lithium	polymer	battery	powered	electric	motors.

The	DJI	S1000+	that	will	be	operated	by	HELIX	DRONES	will	be	registered	in	accordance	with	49	

U.S.C.	44103,	Registration	of	Aircraft,	as	well	as	14	C.F.R	Part	47,	Aircraft	Registration,	and	

marked	in	accordance	with	14	C.F.R.	Part	45,	Identification	and	Registration	Marking.

BASIS	FOR	PETITION

Petitioner,	HELIX	DRONES,	pursuant	to	the	provisions	of	the	Federal	Aviation	Regulations	(14	

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

Rules	for	Certain	Unmanned	Aircraft	Systems,	hereby	petitions	the	Administrator	to	

commercially	operate	the	DJI	Phantom	3 and	DGI	S1000+ UAS in	the	National	Airspace	System	

(NAS),	and	for	an	exemption	from	the	requirements	of	14	C.F.R	§§	61.113(a)	&	(b),	91.7(a),	

91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	

In	consideration	of	the	speed,	weight,	size,	and	limited	operating	area	associated	with	the	

unmanned	aircraft	and	its	operation,	HELIX	DRONES operation	of	DJI	Phantom	3 and	DGI	

S1000+	UAS meets	the	conditions	of	FMRA	Section	333	and	therefore,	will	not	require	an	

airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	

Accordingly,	HELIX	DRONES requests	relief	from	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	

(a)(2),	and	91.417(a)	&	(b),	as	these	sections	set	forth	requirements	for	maintenance	that	only	

apply	to	aircraft	with	an	airworthiness	certificate.	

HELIX	DRONES submits	that	the	requested	relief	is	proper	since	an	equivalent	level	of	safety	will	

be	ensured.	HELIX	DRONES will	use	experienced	personnel	or	technicians	to	perform	

maintenance,	alterations,	or	preventive	maintenance	on	the	UAS	using	the	methods,	

techniques,	and	practices	prescribed	in	the	operating	documents	(i.e.,	Monthly	Maintenance	

Log,	and	DJI	Instruction	Manual).	Furthermore,	HELIX	DRONES will	document	and	maintain	all	

maintenance	records	for	the	DJI	Phantom	3 UAS and	DGI	S1000+.	

Relief	from	certain	requirements	of	Section	61.113(a)	and	(b),	entitled	Private	pilot	privileges	

and	limitations:	Pilot	in	command,	is	requested	by	HELIX	DRONES to	the	extent	necessary	to	

allow	a	Pilot	in	Command	(PIC)	holding	a	private	pilot	or	higher	level	certificate,	as	well	as	an	

airman	medical	certificate,	and	who	has	demonstrated,	by	meeting	minimum	flight- hour	and	

currency	requirements,	that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner	consistent	

with	this	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	

distances	from	people,	vessels,	vehicles	and	structures.	
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HELIX	DRONES seeks	relief	from	Section	91.7(a),	entitled	Civil	aircraft	airworthiness,	because	

the	UAS	do	not	require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	

Subpart	H.	As	such,	HELIX	DRONES submits	that	they will	ensure	that	the	UAS is in	an	airworthy	

condition,	prior	to	every	flight,	by	determining	that	the	UAS are	in	compliance with	the	

operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	DJI	Instruction	Manual),	and	that	the	

aircraft	are	in	a	condition	for	safe	flight.	

HELIX	DRONES also	seeks	an	exemption	from	the	requirements	of	Section	91.121,	entitled	

Altimeter	Settings, as	the	UAS will	not	have	a	typical	barometric	altimeter	onboard.	However,	

altitude	information	of	the	UAS will	be	provided	to	the	PIC	via	Global	Positioning	System	(GPS)	

equipment	and	radio	communications	telemetry	data	link,	which	downlinks	from	the	UA	to	the	

GCS	for	active	monitoring	of	the	flight	path.	This	altitude	information,	combined	with	HELIX	

DRONES’s	operation	of	the	UAS	within	visual	line	of	sight,	at	or	below	400	feet	AGL,	will	ensure	

a	level	of	safety	equivalent	to	Section	91.121.	

Additionally,	HELIX	DRONES seeks	an	exemption	from	the	requirements	of	Section	91.151(b),	

entitled	Fuel	requirements	for	flight	in	VFR	conditions.	HELIX	DRONES submits	that	safety	will	

not	be	affected	by	operation	of	the	UAS during	daylight	hours	in	visual	meteorological	

conditions	(VMC)	under	visual	flight	rules	(VFR),	with	enough	battery	power	to	fly	for	a	total	

duration	of	approximately	23 minutes.		Battery	power	indicators	are	also	able	to	show	exactly	

how	much	battery	power	is	left,	as	well	as	how	much	time	is	needed	to	return	safely	back	to	

point	of	take	off.

In	accordance	with	14	C.F.R.	§	11.81,	HELIX	DRONES 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	and	point	of	contact	is:

Scotty	Runyan

President

Helix	Drones,	LLC

2025	Flightway	Dr.

Chamblee,	GA	30341

678-232-0090

B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	HELIX	DRONES Seeks	Exemption.	

1.	HELIX	DRONES Seeks	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	(b).	
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Section	61.113,	entitled	Private	pilot	privileges	and	limitations:	Pilot	in	command,	subsections	

(a)	and	(b)	prescribe	the	following,	in	relevant	part:	

(a)	No	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	(PIC)	of	

an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire;	nor	may	

that	person,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft.	

(b)	A	private	pilot	may,	for	compensation	or	hire,	act	as	PIC	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.	

2.	HELIX	DRONES Seeks Exemption	From	The	Requirements	Of	Section	91.7(a).

Section	91.7,	entitled	Civil	aircraft	airworthiness,	subsection	(a),	states	the	following:	

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

3. HELIX	DRONES Seeks	Exemption	From	The	Requirements	Of	Section	91.121.	

Section	91.121,	entitled	Altimeter	settings,	subsection	(a),	states	the	following,	in	part:	

(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.	

4. HELIX	DRONES Seeks	Exemption	From	The	Requirements	Of	Section	91.151(b).

Section	91.151,	entitled	Fuel	requirements	for	flight	in	VFR	conditions,	subsection (b),	states	the	

following:	
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(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.	

5. HELIX	DRONES Seeks	Exemption	From	The	Requirement	Of	Section	91.405(a).

Section	91.405,	entitled	Maintenance	required,	subsection	(a),	states	the	following:	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[.]	

6.	HELIX	DRONES Seeks	Exemption	From	The	Requirements	Of	Section	91.407(a)(1)	

Section	91.407,	entitled	Operation	after	maintenance,	preventive	maintenance,	rebuilding,	or	

alteration, subsection	(a)(1),	states	the	following:	

(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[.]	

7.	HELIX	DRONES Seeks	Exemption	From	The	Requirements	Of	Sections	91.409(a)(1)	And	

91.409(a)(2).	

Section	91.409,	entitled	Inspections,	subsection	(a),	states	the	following:

(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.	

8.	HELIX	DRONES Seeks	Exemption	From	The	Requirements	Of	Sections	91.417(a)	And	

91.417(b).	

Section	91.417,	entitled	Maintenance	records,	subsections	(a)	and	(b),	state	the	following:	
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(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:	
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(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.	

C.	The	Extent	Of	Relief	HELIX	DRONES Seeks	And	The	Reason	HELIX	DRONES Seeks	The	Relief.	

1.	Extent	Of	Relief	HELIX	DRONES Seeks	And	The	Reason	HELIX	DRONES Seeks	Relief	From	

Section	61.113(a)	And	(b).	

Relief	from	Section	61.113(a)	and	(b)	entitled	Private	pilot	privileges	and	limitations:	Pilot	in	

command,	is	requested	to	the	extent	necessary	to	allow	a	PIC	holding	a	private	pilot	or	higher	

level	certificate,	as	well	as	a	current	and	valid	airman	medical	certificate,	and	who	has	met	

certain	flight-hour	and	currency	requirements,	to	conduct	the	proposed	UAS	flight	operations	

for	compensation	or	hire.	

This	relief	is	requested	since	the	limitations	set	forth	in	Section	61.113(a)	and	(b)	state	that	a	

private	pilot	may,	for	compensation	or	hire,	act	as	PIC	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.	

As	set	forth	more	fully	below,	HELIX	DRONES submits	that	an	equivalent	level	of	safety	will	be	

maintained	because	no	PIC	will	be	allowed	to	operate	the	UAS	unless	that	PIC	has	met	certain	

flight-hour	and	currency	requirements,	demonstrating	that the	PIC	is	able	to	safely	operate	

either	the	UAS	in	a	manner	consistent	with	the	operations	specifications	as	described	in	this	

exemption,	including	evasive	and	emergency	maneuvers,	as	well	as	maintaining	appropriate	

distances	from	people,	vessels,	vehicles	and	structures.

Further,	HELIX	DRONES submits	that	all	flights	of	the	UAS,	conducted	by	the	PIC	pursuant	to	the	

grant	of	this	Petition:	(1)	will	be	incidental	to	HELIX	DRONES’s	business;	and	(2)	will	not	carry	

passengers	or	property	for	compensation	or	hire.	

2.	Extent	Of	Relief	HELIX	DRONES Seeks	And	The	Reason	HELIX	DRONES Seeks	Relief	From	

Section	91.7(a).	
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Relief	from	Section	91.7(a)	entitled	Civil	aircraft	airworthiness,	is	requested	to	the	extent	

required	to	allow	HELIX	DRONES to	determine	that	the	UAS are	in	airworthy	condition	prior	to	

every	flight	by	ensuring	that	the	UAS	is	in	compliance	with	the	operating	documents	(i.e.,	HELIX	

DRONES Aerial	Operations	Manual,	Monthly	Maintenance	Log,	and	DJI	Instruction	Manual).	

HELIX	DRONES seeks	the	requested	relief	because	the	DJI	Phantom	3	and	DGI	S1000+	UAS do	

not	require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	

Therefore,	HELIX	DRONES will	ensure	that	the	UAS are	in	airworthy	condition	based	upon	its	

compliance	with	the	operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	DJI Instruction	

Manual)	prior	to	every	flight,	and	further,	determine	that	the	aircraft	are	in	condition	for	safe	

flight,	as	stated	in	the	conditions	and	limitations	below.

3.	Extent	Of	Relief	HELIX	DRONES Seeks	And	The	Reason	HELIX	DRONES Seeks	Relief	From	

Section	91.121.	

Relief	from	Section	91.121,	entitled	Altimeter	settings,	may	be	required	to allow	flight	

operations	of	the	UAS,	which	utilize	a	barometric	pressure	sensor,	GPS	equipment,	and	a	radio	

communications	telemetry	data	link	to	downlink	altitude	information	from	the	UA	to	the	PIC	at	

the	ground	control	station	(GCS).	Since	the	FAA	requires	that	any	altitude	information

concerning	UAS	operations	be	reported	to	air	traffic	control	(ATC)	in	feet	above	ground	level	

(AGL),	HELIX	DRONES seeks	the	requested	relief	because	the	UAS’s	altimeter	may	be	set	on	the	

ground	to	zero	feet	AGL,	rather	than	the	local	barometric	pressure	or	field	altitude,	before	each	

flight.	

Considering	the	limited	altitude	of	the	proposed	operations,	relief	from	14	CFR	91.121	is	sought	

to	the	extent	necessary	to	comply	with	the	applicable	conditions	and	limitations	stated	below.	

As	more	fully	set	forth	herein,	an	equivalent	level	of	safety	will	be	maintained	since	the	are	

equipped	with	a	barometric	pressure	sensor	and	GPS	equipment,	which	automatically	ensures	

that	a	ground	level	pressure	setting	will	be	established	prior	to	each	flight,	and	provides	the	PIC	

with	altitude	information	of	the	UA	on	the	heads-up	display	of	the	GCS.	

4.	Extent	Of	Relief	HELIX	DRONES Seeks	And	The	Reason	HELIX	DRONES Seeks	Relief	From	

Section	91.151(b).	

Relief	from	Section	91.151(b)	entitled	Fuel	requirements	for	flight	in	VFR	conditions,	is	

requested	to	the	extent	required	to	allow	flights	of	the	battery	powered	UAS during	daylight	

hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight	rules	(VFR),	for	a	total	

duration	of	23 minutes. HELIX	DRONES seeks	the	requested	relief	because	without	an	

exemption	from	Section	91.151(b),	the	flight	time	duration	of	the	battery	powered	UAS will	

severely	constrain	the	practicality	of	any	aerial	video	or	still	photo	flight	operations	that	HELIX	

DRONES proposes	to	conduct	pursuant	to	this	Petition.	
11

Significantly,	as	set	forth	below,	the	technical	specifications	of	the	UAS,	the	DJI	operating	

documents,	and	HELIX	DRONES’s	proposed	operating	limitations,	ensure	that	HELIX	DRONES

will	safely	operate	the	battery	powered UAS during	daylight	hours	in	visual	meteorological	

conditions	(VMC),	under	visual	flight	rules	(VFR),	with	enough	battery	power	to	fly	for	a	total	

duration	of	23 minutes.

5.	Extent	Of	Relief	HELIX	DRONES Seeks	And	The	Reason	HELIX	DRONES Seeks	Relief	From	

Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b).	

Since	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	only	apply	to	

aircraft	with	an	airworthiness	certificate,	HELIX	DRONES requests	relief	from	these	Sections	

because	the	UAS do	not	require	airworthiness	certificates.	As	set	forth	more	fully	below,	the	

UAS meet	the	conditions	of	FMRA	Section	333	for	operation	without	an	airworthiness	

certificate.	Accordingly,	HELIX	DRONES will	use	trained	technicians	to	perform	maintenance,	

alterations,	or	preventive	maintenance	on	the	UAS using	the	methods,	techniques,	and	

practices	prescribed	in	the	UAS	operating	documents	(i.e.,	the	HELIX	DRONES Aerial	Operations	

Manual,	Monthly	Maintenance	Log,	and	DJI	Instruction	Manual).	Furthermore,	HELIX	DRONES

will	document	and	maintain	all	maintenance	records	for	the	DJI	Phantom	3	UAS and	DGI	

S1000+.	

D.	The	Reasons	Why	Granting	HELIX	DRONES Request	Would	Be	In	The	Public	Interest;	That	

Is,	How	It	Would	Benefit	The	Public	As	A	Whole.	

Granting	the	present	Petition	will	further	the	public	interest	by	allowing	HELIX	DRONES to	

safely,	efficiently,	and	economically	perform	utility	line	inspections as	well	as	aerial	video	and	

photography. Utility	line	inspection	is	a	required	task	that	is	currently	accomplished	by	either	

rotorwing	or	fixed	wing	aircraft.	These	aircraft	must	fly	low	and	slow	over	the	work	area	in	

order	to	accomplish	the	job	successfully.	The	use	of	UAS	will	greatly	reduce	the	risk	of	these	

operations.	Since	no	pilots	are	actually	onboard	the	UAS,	the	potential	for	injury	or	death	is	

greatly	reduced.	Also,	the	lightweight	nature	of	the	UAS	greatly	reduces	the	risk	of	property	

damage.	With	the	size,	weight,	and	speed	of	the	proposed	UAS,	the	operations	carried	out	by	

the	Petitioner	will	be	as	safe	or	safer	than	current	similar	manned	operations.

E.	The	Reasons	Why	Granting	The	Exemption	Would	Not	Adversely	Affect	Safety,	Or	How	The	

Exemption	Would	Provide	A	Level	Of	Safety	At	Least	Equal	To	That	Provided	By	The	Rule	

From	Which	HELIX	DRONES Seeks	Exemption.	

1.	Reasons	Why	UAS Meet	The	Conditions	Of	The	FAA	Modernization	and	Reform	Act	of	2012	

(FMRA)	Section	333.	
12

In	consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the	

unmanned	aircraft	and	its	operation,	HELIX	DRONES’s	operation	of	the	DJI	Phantom	3 and	DGI	

S1000+	UAS meet	the	conditions	of	FMRA	Section	333,	and	will	not	require an	airworthiness	

certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	

Section	333	provides	authority	for	a	UAS	to	operate	without	airworthiness	certification	and	sets	

forth	requirements	for	considering	whether	a	UAS	will	create	a	hazard	to	users	of	the	NAS	or	

the	public,	or	otherwise	pose	a	threat	to	national	security.	Specifically,	FMRA	Section	333	states	

the	following,	in	part:	

(a)	In	General.--Notwithstanding	any	other	requirement	of	this	subtitle,	and	not	later	than	180	

days	after	the	date	of enactment	of	this	Act,	the	Secretary	of	Transportation	shall	determine	if	

certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	airspace	system	before	

completion	of	the	plan	and	rulemaking	required	by	section	332	of	this	Act	or	the	guidance

required	by	section	334	of	this	Act.	

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

(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	(1).	

(c)	Requirements	for	Safe	Operation.--If	the	Secretary	determines	under	this	section	that	certain	

unmanned	aircraft	systems	may	operate	safely	in	the	national	airspace	system,	the	Secretary	

shall	establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in	the national	

airspace	system.	

In	seeking	this	exemption,	HELIX	DRONES submits	that	the	DJI	Phantom	3 and	S1000+ UAS can	

operate	safely	in	the	NAS	pursuant	to	FMRA	Section	333,	as	demonstrated	by:	(a)	the	

characteristics	of	the	DJI	Phantom	3	and	S1000+	UAS;	(b)	the	pilot	certification	requirement;	

and	(c)	the	specific	operating	limitations.	

a.	The	Specifications	Of	The	UAS Demonstrate	Its	Safe	Characteristics.

The	DJI	Phantom	3	and	S100+	UAS do	not	create	a	hazard	to	users	of	the	NAS	or	the	public,	or	

otherwise	pose	a	threat	to	national	security	considering	its	size,	weight,	speed,	and	operational	

capability.	

i.	Technical	Specifications	
13

The	technical	specifications	of	the	DJI	Phantom	3	UAS are	set	forth	by	the	DJI	Phantom	3	User	

Manual.	The	technical	specifications	of	the	DJI	S1000+	are	set	forth	by	the	DJI	S1000+	User	

Manual.

ii.	The	UAS Global	Positioning	Modes	Enable	The	UAS To	Remain	Within	A	Defined	

Operational	Area.	

Both	the	DJI	Phantom	3	and	DGI	S1000+	UAS may	be	operated	in	both	manual	and	global	

positioning	flight	modes.	

iii.	The	UAS Are	Designed	For	Automatic	Return	To	Home	Point	Or	Hover	In	The	Event	Of	Loss	

Of	The	Control	Link	Or	Navigation.	

When	the	Control	Link	is	lost,	both UAS will	remain	stationary,	in	flight,	for	3	seconds	or	more.	

If,	after	3	seconds,	the	UAS does not	reacquire	control link	data	from	the	GCS,	the	UAS will	

assume	that	the	Control	Link	is	lost	and	the will	return	to	the	home	position	(i.e.,	failsafe	mode)	

via	GPS,	and	will	descend	to	the	takeoff	position	and	shutdown.

b.	Flight	Operations	Of	UAS Is Limited	To	The	Line	Of	Sight	Of	A	Certificated	Pilot	in	Command	

With	A	Safety	Observer.	

HELIX	DRONES staff	will	be	the	only	persons to	act	as	a	pilot	in	command	(PIC)	of	the UAS.	

Additionally,	a	safety	observer	will	assist	him	at	all	times	during	flight	time.	

c.	Flights	Of	The	UAS Will	Be	Conducted	Pursuant	To	Specific	Operating	Limitations.	

In	seeking	this	exemption,	HELIX	DRONES proposes	to	commercially	operate	the	pursuant	to	

the	following	specific	operating	limitations.

1.	Operations	authorized	by	this	grant	of	exemption	will	be	limited	to	the	following	aircraft	

described	in	the	operating	documents,	rotorcraft	UAS weighing	less	than	55	pounds	maximum	

gross	weight:

2.	UAS	operations	under	this	exemption	will	be	limited	to	conducting	operations	for	the	

purpose	of	utility	line	inspection,	aerial	video	and	photography

3.	The	UAS may	not	be	flown	at	an	indicated	airspeed	exceeding	30	knots.

4.	The	UA	must	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL),	

as	indicated	by	the	procedures	specified	in	the	operating	documents	unless	a	special	request	is	

made	and	approved	by	ATC.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL.	

5.	The	UAS must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all	times.	This	

requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any	device	other	than	corrective	

lenses,	as	specified	on	the	PIC’s	FAA-issued	airman	medical	certificate.	

6.	The	use	of	first	person	view	(FPV)	by	the	PIC	or	safety	observer	(SO)	is	not	permitted.	
14

7.	All	operations	must	utilize	a	safety	observer	(SO).	The	SO	may	be	used	to	satisfy	the	VLOS	

requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	SO	and	PIC	must	be	able	

to	communicate	verbally	at	all	times.	Electronic	messaging	or	texting	is	not	permitted	during	

flight	operations.	The	PIC	must	be	designated	before	the	flight	and	cannot	transfer	his	or	her	

designation	for	the	duration	of	the	flight.	The	PIC	must	ensure	that	the	SO	can	perform	the	

functions	prescribed	in	the	operating	documents.	

8.	The	SO	must	not	perform	any	other	duties	beyond	assisting	the	PIC	with	seeing	and	avoiding	

other	air	traffic	and	other	ground	based	obstacles/obstructions	and	is	not	permitted	to	operate	

the	camera	or	other	instruments.	

9.	The	operating	documents	and	the	grant	of	exemption	must	be	accessible	during	UAS	

operations	and	made	available	to	the	Administrator	upon	request.	If	a	discrepancy	exists	

between	the	conditions	and	limitations	contained	in	the	grant	of	exemption	and	the	

procedures	outlined	in	the	operating	documents,	the	conditions	and	limitations	contained	in	

the	grant	of	exemption	take	precedence	and	must	be	followed.	Otherwise,	the	operator must	

follow	the	procedures	as	outlined	in	its	operating	documents.	The	operator	may	update	or	

revise	its	operating	documents.	It	is	the	operator’s	responsibility	to	track	such	revisions	and	

present	updated	and	revised	documents	to	the	Administrator	upon	request.	The	operator	must	

also	present	updated	and	revised	documents	if	it	petitions	for	extension	or	amendment	to	the	

grant	of	exemption.	If	the	operator	determines	that	any	update	or	revision	would	affect	the	

basis	upon	which	the	FAA	granted	the	exemption,	then	the	operator	must	petition	for	

amendment	to	its	grant	of	exemption.	The	FAA’s	UAS	Integration	Office	(AFS-80)	may	be	

contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents.	

10.	Prior	to	each	flight	the	PIC	must	inspect	the	UAS	to	ensure	that	it	is	in	a	condition	for	safe	

flight.	If	the	inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the	

aircraft	is	prohibited	from	operating	until	the	necessary	maintenance	has	been	performed	and	

the	UAS	is	found	to	be	in	a	condition	for	safe	flight.	The	Ground	Control	Station	must	be	

included	in	the	preflight	inspection.	All	maintenance	and	alterations	must	be	properly	

documented	in	the	aircraft	records.

11.	Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	operation	or	

flight	characteristics,	e.g.	replacement	of	a	flight	critical	component,	must	undergo	a	functional	

test	flight.	The	PIC	who	conducts	the	functional	test	flight	must	make	an	entry	in	the	aircraft	

records.	

12.	The	pre-flight	inspection	must	account	for	all	potential	discrepancies,	e.g.	inoperable	

components,	items,	or	equipment,	not	already	covered	in	the	relevant	sections	of	the	operating	

documents.	

13.	The	operator	must	follow	the	UAS	manufacturer’s	aircraft/component, maintenance,	

overhaul,	replacement,	inspection,	and	life	limit	requirements.	
15

14.	The	operator	must	carry	out	its	maintenance,	inspections,	and	record	keeping	

requirements,	in	accordance	with	the	operating	documents.	Maintenance,	inspection,	

alterations,	and	status	of	replacement/overhaul	component	parts	must	be	noted	in	the	aircraft	

records,	including	total	time	in	service,	description	of	work	accomplished,	and	the	signature	of	

the	authorized	person	returning	the	UAS	to	service.	

15.	Each	UAS operated	under	this	exemption	must	comply	with	all	manufacturer	Safety	

Bulletins.	

16.	The	authorized	person	must	make	an	entry	in	the	aircraft	record	of	the	corrective	action	

taken	against	discrepancies	discovered	between	inspections.	

17.	The	PIC	must	possess	at	least	a	private	pilot	certificate	and	at	least	a	current	third- class	

medical	certificate.	

18.	The	operator	may	not	permit	any	PIC	to	operate	unless	the	PIC	meets	the	operator’s	

qualification	criteria	and	demonstrates	the	ability	to	safely	operate	the	UAS	in a	manner	

consistent	with	how	the	UAS	will	be	operated	under	the	exemption,	including	evasive	and	

emergency	maneuvers	and	maintaining	appropriate	distances	from	persons,	vessels,	vehicles	

and	structures.	PIC	qualification	flight	hours	must	be	logged	in	a	manner	consistent	with	14	

C.F.R.	§	61.51(b).	Flights	for	the	purposes	of	training	the	operator’s	PICs	are	permitted	under	

the	terms	of	the	exemption.	However,	training	operations	may	only	be	conducted	during	

dedicated	training	sessions.	During	training,	proficiency,	and	experience-building	flights,	all	

persons	not	essential	for	flight	operations	are	considered	nonparticipants,	and	the	PIC	must	

operate	the	UA	with	appropriate	distance	from	nonparticipants	in	accordance	with	14	C.F.R.	§	

91.119.	

19.	UAS	operations	may	not	be	conducted	during	night,	as	defined	in	14	C.F.R.	§	1.1.	All	

operations	must	be	conducted	under	visual	meteorological	conditions	(VMC).	If	flight	at	night	is	

required,	a	special	request	will	be	made	at	the	FAA	office	closest	to	proposed	area	of	

operations.	Flights	under	special	visual	flight	rules	(SVFR)	are	not	authorized.	

20.	The	UA	may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	as	denoted	on	

a	current	FAA-published	aeronautical	chart	unless	a	letter	of	agreement	with that	airport’s	

management	is	obtained,	and	the	operation	is	conducted	in	accordance	with	a	NOTAM	as	

required	by	the	operator’s	COA.	The	letter	of	agreement	with	the	airport	management	must	be	

made	available	to	the	Administrator	upon	request.	

21.	The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	horizontally	

from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.	

22.	If	the	UA	loses	communications	or	loses	its	GPS	signal,	it	must	return	to	a	pre- determined	

location	within	the	planned	operating	area	and	land	or	be	recovered	in	accordance	with	the	

operating	documents.	
16

23.	The	PIC	must	abort	the	flight	in	the	event	of	unpredicted	obstacles	or	emergencies	in	

accordance	with	the	operating	documents.	

24.	The	PIC	is prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast	weather	

conditions)	there	is	enough	power	to	fly	at	normal	cruising	speed	to	the	intended	landing	point	

and	land	the	UA	with	25%	battery	power	remaining.	

25.	The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate	of	Waiver	or	

Authorization	(COA)	prior	to	conducting	any	operations	under	the	grant	of	exemption.	This	COA	

will	also	require	the	operator	to	request	a	Notice	to	Airman	(NOTAM)	not	more	than	72	hours	

in advance,	but	not	less	than	48	hours	prior	to	the	operation.	All	operations	shall	be	conducted	

in	accordance	with	airspace	requirements	in	the	ATO	issued	COA	including	class	of	airspace,	

altitude	level	and	potential	transponder	requirements.	

26.	All	aircraft	operated	in	accordance	with	the	exemption	must	be	identified	by	serial	number,	

registered	in	accordance	with	14	C.F.R.	part	47,	and	have	identification	(N- Number)	markings	

in	accordance	with	14	C.F.R.	part	45,	Subpart	C.	Markings	must	be	as	large	as	practicable.	

27.	Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	and	control	

of	the	UA	must	comply	with	the	Federal	Communications	Commission	(FCC)	or	other	

appropriate	government	oversight	agency	requirements.	

28.	The	documents	required	fewer	than	14	C.F.R.	91.9	and	91.203	must	be	available	to	the	PIC	

at	the	Ground	Control	Station	of	the	UAS	any	time	the	UAS	is	operating.	These	documents	must	

be	made	available	to	the	Administrator	or	any	law	enforcement	official	upon	request.

29.	The	UA	must	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation	operations	and	

activities	at	all	times.	

30.	The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.

31.	Flight	operations	must	be	conducted	at	least	500	feet	from	all	nonparticipating	persons	

(persons	other	than	the	PIC,	SO,	operator	trainees	or	essential	persons),	vessels,	vehicles,	and	

structures	unless:	

a.	Barriers	or	structures	are	present	that	sufficiently	protect	nonparticipating	persons	

from	the	UA	and/or	debris	in	the	event	of	an	accident.	The	operator	must	ensure	that	

nonparticipating	persons	remain	under	such	protection.	If	a	situation	arises	where	

nonparticipating	persons	leave	such	protection and	are	within	500	feet	of	the	UA,	flight	

operations	must	cease	immediately	and/or;	

b.	The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the	

owner/controller	of	such	vessels,	vehicles	or	structures	has	granted	permission	and	the	

PIC	has made	a	safety	assessment	of	the	risk	of	operating	closer	to	those	objects	and	

determined	that	it	does	not	present	an	undue	hazard,	and;	
17

c.	Operations	nearer	to	the	PIC,	SO,	operator	trainees	or	essential	persons	do	not	

present	an	undue	hazard	to	those	persons	per	§	91.119(a).	

32.	All	operations	shall	be	conducted	over	private	or	controlled-access	property	with	

permission	from	the	land	owner/controller	or	authorized	representative.	Permission	from	land	

owner/controller	or	authorized	representative	will	be obtained	for	each	flight	to	be	conducted.

33.	Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	

boundaries	of	the	operational	area	as	defined	by	the	applicable	COA	must	be	reported	to	the	

FAA's	UAS	Integration	Office	(AFS-80)	within	24	hours.	Accidents	must	be	reported	to	the	

National	Transportation	Safety	Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site:	

www.ntsb.gov.	

2.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	(b)	Would	

Not Adversely	Affect	Safety.

HELIX	DRONES submits	that	the	equivalent	level	of	safety	established	by	Section	61.113(a)	and	

(b)	will	be	maintained	because	no	PIC	will	be	allowed	to	operate	the	UAS unless	that	PIC	has	

demonstrated,	by	meeting	minimum	flight-hour	and	currency	requirements,	that	the	PIC	is	able	

to	safely	operate	the	UAS	in	a	manner	consistent	with	the	exemption,	including	evasive	and	

emergency	maneuvers	and	maintaining	appropriate	distances	from	people,	vessels,	vehicles	

and	structures.	

Considering	HELIX	DRONES’ proposed	area	of	operations,	and	the	operating	limitations	set	

forth-above;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to	those	

of	commercial	pilot	requirements	(See	Exemption	No.	11062);	and	the	airmanship	skills	

necessary	to	safely	operate	the	UAS,	HELIX	DRONES submits	that	the	additional	manned	

airmanship	experience	of	a	commercially	certificated	pilot	would	not	correlate	to	the	

airmanship	skills	necessary	for	HELIX	DRONES’ specific	proposed	flight	operations.	

The	FAA	has	previously	granted	relief	from	Section	61.113(a)	and	(b)	specific	to	UAS,	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	

11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	11112,	11136,	11138,	11150,	

11153,	11156,	11158,	11159,	11160,	11161).	

HELIX	DRONES will	not	allow	any	PIC	to	operate	the	UAS	unless	that	PIC	has	demonstrated,	by	

meeting	minimum	flight-hour	requirements	or	the	UAS	training	and	currency	requirements,	

that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner	consistent	with	this	exemption,	

including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	from	

people,	vessels,	vehicles	and	structures.	

Specifically,	the	PIC	must	have	accumulated	and	logged,	in	a	manner	consistent	with	14	C.F.R.	§	

61.51(b),	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	(with	a	minimum	of	5	hours	of	those	
18

hours	as	a	UAS	pilot	operating	the	same	make	and	model	of	UAS	to	be	used	for	operations	

under	the	exemption).	In	addition	to	the	hour	requirements,	the	PIC	must	accomplish	3	

takeoffs	and	landings	in	the	preceding	90	days	(for	currency	purposes).	

As	in	Exemption	Nos.	11062,	11138,	and	11153,	prior	documented	flight	experience	that	was	

obtained	in	compliance	with	applicable	regulations	will	ensure	an	equivalent	level	of	safety	

during	HELIX	DRONES’s	proposed	operations.	The	Administrator	has	held	that	prior	

documented	flight	experience	that	was	obtained in	compliance	with	applicable	regulations	

would	ensure	safe	operations,	stating	as	follows:	

In	Exemption	No.	11062,	the	FAA	required	that	prior	to	conducting	operations	for	the	purpose	

of	motion	picture	filming	(or	similar	operations),	the	PIC	must	have	accumulated	and	logged,	in	

a	manner	consistent	with	14	CFR	61.51(b),	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	

including	at	least	10	hours	logged	as	a	UAS	pilot	with	a	multi-rotor	UAS.	Prior	to	operations	

under	Exemption	No.	11062,	the	PIC	must	also have	accumulated	and	logged	a	minimum	of	5	

hours	as	a	UAS	pilot	operating	the	same	make	and	model	of	UAS	to	be	used	for	operations	

under	the	exemption.	For	clarification,	the	FAA	considers	these	minimum	hour	requirements	to	

be	inclusive	rather	than	additive;	i.e.	5	hours	make	and	model	time	may	be	included	in	the	10	

hours	of	multi-rotor	time	and	the	10	hours	may	be	included	in	the	total	25	hours	of	UAS	

rotorcraft	time.	In	addition	to	the	hour	requirements,	the	PIC	must	accomplish	3	takeoffs	and	

landings	in the	preceding	90	days	(for	currency	purposes).	The	FAA	finds	that	at	a	minimum,	the	

flight-hour	requirements	in	Exemption	No.	11062	are	appropriate	to	practice	and	build	

proficiency	in	the	skills	necessary	to	safely	conduct	the	petitioner’s	proposed	operations.	The	

FAA	also	finds	that	prior	documented	flight	experience	that	was	obtained	in	compliance	with	

applicable	regulations	would	satisfy	this	requirement.	Training,	proficiency,	and	experiencebuilding	flights	can	also	be	conducted	under	the	grant	of	exemption	to	accomplish	the	required	

flight	time.	During	training,	proficiency,	and	experience-building	flights	the	PIC	is	required	to	

operate	the	UA	with	appropriate	distances	in	accordance	with	14	C.F.R	91.119.	

Exemption	No.	11138	at	page	15.	

Accordingly,	HELIX	DRONES will	ensure	safe	operations	by	not	allowing	any	PIC	to	operate	the	

UAS	unless	that	PIC	has	demonstrated,	by	meeting	minimum	flight-hour	and	currency	

requirements,	that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner	consistent	with	the	

exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	

from	people,	vessels,	vehicles	and	structures.	

3.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.7(a)	Would	Not	

Adversely	Affect	Safety.	
19

The	equivalent	level	of	safety	established	by	Section	91.7(a)	will	be	maintained	because	prior	to	

every	flight,	HELIX	DRONES will	ensure	that	the	UAS	is	in	an	airworthy	condition	based	upon	the	

UAS’s	compliance	with	its	operating	documents	and	as	stated	in	the	conditions	and	limitations	

herein.	

Additionally,	the	FAA	has	previously	granted	relief	from	Section	91.7(a)	specific	to UAS,	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	

11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	11112,	11136,	11138,	11150,	

11153,	11156,	11157,	11158,	11159,	11160,	11161).	

4.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.121	Would	Not	

Adversely	Affect	Safety.

The	equivalent	level	of	safety	established	by	Section	91.121	will	be	maintained	because	the	

altitude	information	of	the	UAS will	be	provided	to	the	PIC	via	GPS	equipment	and	a	radio	

communications	telemetry	data	link,	which	downlinks	from	the	UA	to	the	GCS	for	active	

monitoring	of	the	flight	path	and	altitude.	This	altitude	information,	combined	with	HELIX	

DRONES’s	operation	of	the	UAS within	visual	line	of	sight, at	or	below	500	feet	AGL,	will	ensure	

a	level	of	safety	equivalent	to	Section	91.121.	The	altitude	information	will	be	generated	by	GPS	

equipment	installed	onboard	the	aircraft.	Prior	to	each	flight,	a	zero	altitude	initiation	point	is	

automatically	established	by	the	UAS at	ground	level.	

The	FAA	has	previously	granted	relief	from	Section	91.121	specific	to	UAS,	in	circumstances	

similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	

11064,	11065,	11066,	11067,	11080,	11109,	11112,	11136,	11138,	11150,	11153,	11156,	11157,	

11158,	11159,	11160,	11161).	

5.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.151(b)	Would	Not	

Adversely	Affect	Safety.

A	grant	of	this	exemption	would	ensure	an	equivalent	level	of	safety	established	by	14	C.F.R.	

Section	91.151(b)	as	a	result	of	(1)	the	technical	specifications	of	the	UAS;	(2)	the	limitations	on	

the	proposed	flight	operations;	and	(3)	the	location	of	the	proposed	flight	operations.	

Accordingly,	HELIX	DRONES will	ensure	that	it	will	safely	operate	the	battery	powered	UAS

during	daylight	hours	in	VFR	conditions,	with	enough	battery	power	to	fly	for	a	total	duration	of	

23 minutes.	

Here,	as	in	Exemption	No.	11109,	the	technical	specifications	of	the	UAS;	the	limitations	on	the	

proposed	flight	operations;	and	the	location	of	the	proposed	operations,	will	ensure	an	

equivalent	level	of	safety	established	by	14	C.F.R.	Section	91.151(b).	Furthermore,	safety	will	be	

ensured	as	the	UAS provide	audible	and	visual	warnings	to the	PIC	at	the	GCS	when	the	UAS
20

experiences	low	battery	voltage,	the	first	warning	occurring	at	approximately	33%	remaining	

battery	power,	and	again	at	approximately	10%	remaining	battery	power.	At	the	critically	low

battery	level,	the	UAS	will	descend	and	land	automatically.	

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Section	91.151	establish	that	

safety	is	not	adversely	affected	when	the	technical	characteristics	and	operating limitations	of	

the	UAS	are	considered.	Relief	has	been	granted	for	manned	aircraft	to	operate	at	less	than	the	

minimums	prescribed	in	Section	91.151,	including	Exemption	Nos.	2689,	5745,	and	10650.	

Moreover,	the	FAA	has	previously	granted	relief	from	Section	91.151	specific	to	UAS,	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	

8811,	10808,	10673,	11042,	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	

11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161).	

6.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Sections

91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b)	Would	Not	Adversely	Affect	

Safety.	

In	seeking	this	exemption,	HELIX	DRONES submits	that	the equivalent	level	of	safety	with	

regard	to	the	regulatory	maintenance	and	alteration	requirements	established	by	Sections	

91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	will	be	met	because	HELIX	

DRONES will	use	trained	technicians	to	perform	maintenance,	alterations,	or	preventive	

maintenance	on	the	UAS using	the	methods,	techniques,	and	practices	prescribed	in	the	

operating	documents	(i.e.,	HELIX	DRONES Aerial	Operations	Manual,	Monthly	Maintenance	Log,	

and	DJI	Instruction	Manual).	Furthermore,	HELIX	DRONES will	document	and	maintain	all	

maintenance	records	for	the	DJI	Phantom	3	UAS and	DGI	S1000+	UAS.	

Since	the	UAS will	be	inspected	as	prescribed	by	the	operating	documents,	HELIX	DRONES will	

maintain	the	equivalent	level	of	safety	established	by	Sections	91.405(a), 91.409(a)(1),	and	

91.409(a)(2).	

Likewise,	the	exemption	sought	will	not	adversely	affect	safety	because	HELIX	DRONES will	use	

trained	technicians	to	perform	maintenance,	alterations	or	preventive	maintenance	on	the	UAS	

using	the	methods,	techniques,	and	practices	prescribed	by	the	operating	documents.	

Furthermore,	the	exemption	sought	would	maintain	an	equivalent	level	of	safety	established	by	

Sections	91.407,	91.417(a)	and	91.417(b),	because	all	maintenance	of	the	UAS will	be	

performed	by	trained	technicians.	Maintenance	will	be	documented	and	maintained	utilizing	

the	monthly	maintenance	log.	

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Sections	91.405(a),	

91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	establish	that	safety	is	not	adversely	

affected	when	the	technical	characteristics	and	operating	limitations	of	the	UAS	are	considered.	
21

In	consideration	of	HELIX	DRONES’s	proposed	operating	limitations,	the	operating	documents,	

and	the	technical	aspects	of	the	UAS,	HELIX	DRONES submits	that	safety	will	not	be	adversely	

affected	by	granting	exemption	from	14	C.F.R.	Sections	91.405(a),	91.407(a)(1)	and	(a)(2),	

91.409(a)(2),	and	91.417(a)	and	(b).	The	FAA	has	previously	granted	relief	specific	to UAS	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	

11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	11112,	11136,	11138,	11150,	

11153,	11156,	11157,	11158,	11159,	11160,	11161).	

7.	The	FAA May	Prescribe	Any	Other	Conditions	For	Safe	Operation.	

In	accordance	with	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	and	

14	C.F.R.	§	21.16	entitled	Special	Conditions,	HELIX	DRONES requests	that	the	FAA	prescribe	

special	conditions	for	the	intended	operation	of	the	UAS,	which	contain	such	safety	standards	

that	the	Administrator	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	

established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14	C.F.R	§§	61.113(a)	& (b),	91.7	(a),	91.121,	

91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	Such	special	

conditions	will	permit	safe	operation	of	the	UAS for	the	limited	purpose	of	conducting	aerial	

video	and	photography	over	certain	areas	of	the	United	States	for	compensation	or	hire.	FMRA	

Section	333	sets	forth	the	requirements	for	considering	whether	a	UAS	will	create	a	hazard	to	

users	of	the	NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security;	and	further,	

provides	the	authority	for	such	UAS	to	operate	without	airworthiness	certification	in	

accordance	with	any	requirements	that	must	be	established	for	the	safe	operation	of	the	UAS	

in	the	NAS.	

Likewise,	the	Administrator	may	prescribe	special	conditions	pursuant	to	14	C.F.R.

§	21.16,	for	operation	of	the	UAS,	since	the	airworthiness	regulations	of	14	C.F.R.	Part	21	do	not	

contain	adequate	or	appropriate	safety	standards,	due	to	the	novel	or	unusual	design	features	

of	the	aircraft.	Section	21.16,	entitled	Special	Conditions,	states	the	following:	

If	the	FAA	finds	that	the	airworthiness	regulations	of	this	subchapter	do	not	contain	adequate	

or	appropriate	safety	standards	for	an	aircraft,	aircraft	engine,	or	propeller	because	of	a	novel	

or	unusual	design	feature	of	the	aircraft,	aircraft	engine	or	propeller,	he	prescribes	special	

conditions	and	amendments	thereto	for	the	product.	The	special	conditions	are	issued	in	

accordance	with	Part	11	of	this	chapter	and	contain	such	safety	standards	for	the	aircraft,	

aircraft	engine	or	propeller	as	the	FAA	finds	necessary	to	establish	a	level	of	safety	equivalent	

to	that	established	in	the	regulations.	

See	14	C.F.R.	§	21.16.

Therefore,	in	accordance	with	FMRA	Section	333	and	14	C.F.R.	§	21.16,	the	FAA	may	prescribe	

special	conditions	for	Leading	Edge’s	intended	operation	of	the	UAS,	which	contain	such	safety	

standards	that	the	Administrator	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	

established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14	C.F.R	Sections	61.113(a)	&	(b),	91.7(a),	

91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).
22

A	Summary	That	Can	Be	Published	In	The	Federal	Register,	stating:	The	Rules	From	Which	

HELIX	DRONES Seeks	Exemption:	

HELIX	DRONES seeks	exemption	from	the	requirements	of	14	C.F.R	Sections	61.113(a)&(b),	

91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	

A	Brief	Description	Of	The	Nature	Of	The	Exemption	HELIX	DRONES Seeks:	

This	exemption	will	permit	HELIX	DRONES to	commercially	operate	an	Unmanned	Aircraft	

System	(UAS)	for	the	purpose	of	conducting utility	line	inspections, aerial	video	and	photography	

over	certain	areas	of	the	United	States.

Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support	HELIX DRONES’s

Request.	

This	Petition	is	made	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012	

(FMRA)	Section	333,	which	directs	the	Secretary	of	Transportation	to	determine	if	certain	UAS	

may	operate	safely	in	the	NAS.	As	such,	HELIX	DRONES’s	request for	exemption	may	be	granted	

pursuant	to	the	authority	of	FMRA	Section	333	and	14	C.F.R.	Part	11,	as	set	forth	above.	

FMRA	Section	333	sets	forth	the	requirements	for	considering	whether	a	UAS	will	create	a	

hazard	to	users	of	the	NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security;	and	

further,	provides	the	authority	for	such	UAS	to	operate	without	airworthiness	certification.	

As	discussed	in	detail	above,	HELIX	DRONES will	operate	the	DJI	Phantom	3	and	DGI	S1000+	

UAS safely	in	the	NAS,	without	creating	a	hazard	to	users	of	the	NAS,	or	the	public,	or	otherwise	

pose	a	threat	to	national	security.	

CONCLUSION

As	set	forth	herein,	HELIX	DRONES seeks	an	exemption	pursuant	to	14	C.F.R.	§	11.61	and	

Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	which	will	permit	safe	

operation	of	the	DJI	Phantom	3	and	DGI	S1000+	UAS commercially,	without	an	airworthiness	

certificate,	for	the	limited	purpose	of	conducting	utility	line	inspections,	aerial	video	and	

photography	over	certain	areas	of	the	United	States.	By	granting	this	Petition,	the	FAA	

Administrator	will	be	fulfilling	the	Congressional	mandate	of	the	FAA	Modernization	and	

Reform	Act	of	2012,	while	also	advancing	the	interests	of	the	public,	by	allowing	HELIX	DRONES

to	safely,	efficiently,	and	economically	operate	the	UAS commercially	within	the	NAS.	

WHEREFORE,	in	accordance	with	the	Federal	Aviation	Regulations	and	the	FAA	Modernization	

and	Reform	Act	of	2012,	Section	333,	HELIX	DRONES respectfully	requests	that	the	

Administrator	grant	this	Petition	for	an	exemption	from	the	requirements	of	14	C.F.R	Sections	

61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	
23

91.417(a)	&	(b),	and	permit	HELIX	DRONES	to	operate	the	DJI	Phantom	3 UAS and	DJI	S1000+	

commercially	for	the	purpose	of	conducting	utility	line	inspection,	aerial	video	and	photography	

over	certain	areas	of	the	United	States.

Dated:	March	04,	2016

Sincerely,

Scotty	Runyan

President	

Helix	Drones,	LLC

2025	Flightway	Dr.

Chamblee,	GA	30341

678-232-0090

Appendices:

A	– Link	to	DJI	Phantom	3 Manual:	 Click	on	link	below

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.

pdf

B	– Link	to	DJI	S1000+	Manual:		Click	on	link	below

http://dl.djicdn.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf