March 24,2015 

US Department of Transportation 

Docket Operations · 

West Building, Ground Floor 

Room·W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Request for authorization to conduct unmanned aircraft systems operations allowed by 

Section 333 ofthe FAA Modernization and Reform Act of 2012 through the _exemption process 

identified under 14 C.FR. Section 11.81. 

Dear Sir/Madam;_ 

Located in the heart of America's "Ag belt," Flight Wink "tLC is a Kansas LLC founded by four members of 

the business, agriculture, and aviation community, Arman A. Miller, JohnS. Harkness, Cody L. Betsworth, 

and DeWitt M.Harkness. . 

Over the past year and one half we, as Flight Wink LLC, have amassed many hours of operational 

experience in unmanned aerial systems(UAS). We have conducted many practice non-commercial 

missions on our 160..:acre rural Wabaunsee County, Kansas, land. F 1 i g h tWin k L L C' s 

. commitment is unparalleled when it comes to UAS experi~nce, study, craft maintenance, safety 

practices, and safety instruction. 

DeWitt M. Harkness, has several decades of experience as a current private pilot with a current Class 3 

Medical (please_ see attached) and holds a VSO Line ofSight Operator Certification from the Unmanned 

Safety Institute (please-see attached). 

All FlightWink LLC's personnel and all business, agriculture, and aviation 

activities will be properly and fully insured. 

· ·flightWink LLC is poised to bring safety and experience to the United States civilian UAS 

operations industry. Our exemplary business and aviation experience plus our emphasis on the practice and 

teaching of UA V safety, we feel, makes us more than worthy for the Secretary to approve our exemption 

request. 

Pursuant to Section 333 ofPL 112-95 commonly known as the "FAA Modernization and Reform Act of 

2012" or "The Reform Act", FlightWink LLC, hereby applies for authorization to conduct commercial 

unmanned aerial systems (UAS) operations for the agriculture, oil and gas, aerial photography and 

wildlife preservation indtistries, within the United States National Airspace System (NAS) within Class G 

and occasionally E airspace, along with additional restrictions identified herein. 
We are submitting the attached detailed information specifically outlining why approval of 

thisrequest is in the best public interest and how this approval will provide a level of safety at 

I east equal to that provided by the rules Flight Wink LLC seeks exemption from. 

In addition, through our continued operational experience in the UAS field, Flight Wink LLC 

will show how the approval of this request will facilitate our _ability to ·work with the~ AA to 

safely accelerate the integration of civil unmrumed aircraft into the national airspace system as 

directed by Congress. 

By strictly adhering to the guidelines presented herein, FlightWink LLC will insure a safety level 

gr~ater than that directed by the rules for which we seek exemption.- This is especially true when 

· you compare the same operating procedures against a manned aircraft. SUAS are inherently safer 

due to the fact that they are much smaller, fly at much lower speeds with no human operators on 

board, and there is zero fuel to be concerned with in the event of a crash. 

As processes are further refined, FlightWink LLC's operations will only add to an already higher level 

of safety compared to manned flight operations which will serve the best public interest in the 

FAA's endeavor to integrate UAS into the NAS. 

We certainly look forward to gaining approval of commercial UA V operations for FlightWink 

LLC. 

7 

Sincer~ly t I 

~I , ~4( 

'Witt M. Harkness, Managing Partner/Pilot 

Flight Wink LLC 

3910 SW Friar Rd. 

Topeka, KS 6661 0 

dewitt2@wolfes.com 

785-640-3229 
Training & Operations 

Section 333 of "The. Reform Acf' states: 

" ... the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system ... ln making the determination under subsection (a), the Secretary 

shall determine, at a minimum- (I) 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 sec:Urity ... " · 

FlightWink LLC will utilize the Volantex Raptor (fixed. wing) and the Tarot 

T -1 8 (oCto copter) to conduct operations for the agriculture, oil and gas, aerial 

photography ·~d wildlife preservation industries. Both crafts meet the requirements for 

exemption per the "Performance and Specifications" section to follow . . ~ . . . 

Operating within visual line of sight (VLOS) and remaining belo~ 400 feet AGL are 

standard operating procedures-for· Flight Wink LLC, and will remain so until. further advances 

in safety of flight are introduced to the market and regulated by the FAA. · 

·As described below, all operations will be confined to those areas no closer than 5 statue 

miles of any airfield and the proper authorities will be notified with any operations within five 

statUe miles . 

. Safety is of the utmost priority in_any and all FlightWink LLC operations. 

. . 
The Airctaft; 

. Design: Both ·crafts are built from a variety of durable, lightweight, and modular 

components that aid intheir capability to safely conduct flights in a variety of conditions. The 

modularity of construction allows. for easy exchange of structural, propulsion, and sensor 

components in the field as per each manufacturer's specifications and repair/maintenance 

instruction manuals. · 

Aircraft Performance/Specifications: 

• 

• 

• 

• 

• 

Cnift Composition: Raptor--Thermoplastic; Tarot--Carbon Fiber 

Flight Controls: (both craft) 

o Primary: GPS Guided Autopilot (Ground Control Station) 

o Backup: Standard Flight Controls (RC Transmitter) 

Power Supply: (both craft) Electric Motor/Next-Gen Battery Technology 

Wingspan: Raptor--72"/6 ft . 

Diameter: Taroi--Q0"/5 ft. with Sea. IS" props . 

• ·Speed in knots: Raptor-- Max: 45/Cruise: 25/Stall: 1 0; Tarot-Max: 25 

• Empty Weight: Raptor--5.5 lbs.; Tarot-IS lbs . 

· • . Max Payload: Raptor--5 lbs.; Tarot-15 lbs. 

• 

• 

Launch (Take Oft): Raptor--Hand-launch or catapult; Tarot"--(}round launch 

Recovery (Landing): · Raptor--Skid Recoverable (belly landing); Tarot"--(}round 

landing 

Opetator Training: All initi~l flight operations and maintenance training will be conducted 

in accordance with each manufacturer's training manuals. Opct: operator candidates have 

met.FlightWink LLC's management's requirements, they wilrenter into FlightWink 

LLC's qualification training program· which includes FAA authorized ground school 

training and a. Class III medical examination. Upon successful completion, the operator will 

earn their Co-Operator/Observer rating. Co-Operators/Observers will be required to conduct 50 

operational hours aiid complete the Visual Line of Sight Operator's course through the . 

·Unmanned Safety Institute to be considered for Operator in Command qualification testing. 

The operator candidate will then be required to complete an o r a l test and "check ride" 

upon successful completion of which, the operator will receive their Operator in Command 

rating. 

· NOTE: King Schools will conduct Ground school training on-line. DeWitt M Harkness will, in the future, 

conduct the VSO training. · · 

Initial certification training requirements instructed by each include: 

Pre-Flight Training: 

• Unpacking artd assembly 

• Power requirements, set-up arid connectivity 

• System end-to-end set-up and test inspections 

• Preflight, run-up and system .checks 

Flight Operations Training: 

• · Proper Handling 

• Motor Operations 
• GCS Flight Programming and Test 

• Launch 

• Basic Flight (climb, cruise, descent, landing) 

• Maneuvering 

• Airspace and Landing Zone OJ?erations 

• Flight Reprogramming 

• Flight Monitoring 

• In-Flight Em_ergency Procedures 

. Post Flight: 

• Shut Down Procedures 

• Data Retrieval and Storage 

• . End-to-End Test and Maintenance Logs 

• Disassembly . 

• Packing, Storage and Transportation 

Co-Oper~tor/Observer qualification training requirements instructed by FlightWink LLC: 

• 

• 

• 

• 

• 

• 

• 

Understanding FAA Rules I Regulations 

Collection Requirements 

Operational Planning 

Flight Planning 

Area of Operations - Hazard Mitigation 

Daily Flight and Inspection Log Completion 

Proper Authority Notification Process 

Operator in Command qualification testing require~ents instructed by FlightWink LLC: 

• 

.. 

Visual Line of Sight VSO written e xarn consisting of 30 questions with a pass 

rate of 80% following the guideline~ set forth by the Unmanned Safety Institute 

"Check Ride" and Oral exam consisting of: 

o Airport Operations 

o Maintenance Inspections 

o Flight Plan Development 

o Area of Operations Hazard Mitigation 

o Weather Hazard Mitigation 

o Emergency Procedures 

o Pre-Flight Operations 

o Flight Operations 

o Post-Flight Oper:ations 
Flight Wink LLC's Operations Execution:· 

Given the fact commercial UAS operations are restricted due to the lack of regulations, a 

. logical and safe solution is to utilize the safety guidance provided for hobbyist use of 

sUAS and other model aircraft as identified by Advisory Circular 91-57 and Section 

336 of the "Reform Act". FlightWink LLC operations will be conducted in a 

methodical, efficient, and most importantly, safe manner adhering_ to strict guidelines· 

which addresses safety concerns with proximity to airports arid populated areas in the 

interim of official guidance from the FAA as the rules and regulations are being further · 

developed. 

The following list provides specific rules and guidelines all FlightWink LLC 

operations will adhere to ensuring at least an equivalent or higher level of safety 

when compared to manned aircraft performing the same functions as outlined within 14 

C.P.R. . 

All FlightWink LLC's crews will: 

Be comprised of a minimum of two certified operators with one serving as Operator in 

Command (OIC) and the other(s) as Co-Operator/Observer(s). 

Consist of one certified air vehicle maintenance techniciag:;to conduct pre and post flight 

inspections. 

NOTE: 0/C/Observer may also jill the role of the maintenance technician 

Attend pre and post flight mission briefs which will consist of ~eather information, flight 

information to include operational area and mission objectives, hazard mitigation 

actions and most importantly emergency and abort procedures; also included will be 

any NOTAMs or improvements to standard operating procedures through further 

refinements in operations. 

Sign applicable documentation verifying their attendance to ·mandatory briefs as well as 

produce daily pre and post flight inspections and flight logs. 

All FlightWink LLC's operations will: 

At no time fly within 5 statute miles of any operational airfield. 

Provide prior notification to airfield operator and airfield air traffic control tower 

(when applicable) when operating within five statute miles of any active airfield no later 

than 24 hours prior to air ·operations. 

Provide prior written notification to local/county sheriff and fire departments in the 

event· assistance is require<;{ to include: flight plans, type and capabilities of air vehicle(s) 

operated and operator's contact information no later than 24 hours prior to operations. 

Be conducted using sUAS as defiried by the FAA weighing less than 55 lbs. All 

operations authorized through this exemption request will be done with our Raptor and/or 

Tarot with all future aircraft presented to FAA for approval prior to operational use. 

Be conducted in Class G and ·o~casionally E airspace and shall not exceed 400 feet 

above ground level (AGL). 

.. 
Be conducted within visual line of sight (VLOS) of the qualified OIC and Co-· 

Operator/Observers. 

Give right-of-way to and avoid flying near manned aircraft at all times. 

Be conducted in rural environments and outside of city limits. 

Be conducted with prior written consent from landowner. 

Ensure air vehicles do not encroach within 250 feet of any improved road, person, 

vehicle or structure that is not associated with operations. 

Abort/Cancel in the event of detrimental weather to include wind speeds exceeding the 

allowable limits as defmed within operations manuals. 

FlightWink LLC's Emergency Procedures: 

• lri the event the air vehicle losses GPS signal~ automated landing will 

immediately commence. The flight plan is built in such a way that hazards are 

identified prior to launch and an immediate landing within the flight plan will 

ensure all hazards are avoided. (This safety feature is inherent to sUAS and 

no further assistance from the 0/C is necessary; however, the 0/C will 

retain option for manual control at all times.) 

• In the event the OIC loses signal with the air vehicle, automated landing will 

immediately commence._The flight plan is built in such a way that hazards are 

identified prior to launch and an immediate landing within the flight plan \\~II 

ensure all hazards are avoided. (This safety feature is inherent to the sUAS 

and with operations being conducted in the rural environment as previously 

stated, there are no concerns to personnel, vehicles or structures with an 

autonomous landing.) 

• In the event hazardous weather unexpectedly approaches and may affect 

operations, the OIC will immediately abort the operation and conduct landing 

activities. 

• 

• 

In the event an in:-flight emergency occurs, (ie. air vehicle maintenance 

issues), the OIC will immediately abort flight and conduct landing activities; 

air vehicle inspection will immediately be achieved and the air vehicle will 

not return to service without proper authorization from certified maintenance 

technicians. 

In a "significant" event (ie. air vehicle crashes and outside assistance is 

needed), OIC will conduct notification procedures to include county sheriff 

and fire departments, airfield operator/tower if applicable and any other 

authority required to mitigate situation. 

o A "significant" event report will be generated by the OIC, verified by 

the Co/Observer and maintenance technician and immediately 

provided to the OIC and FlightWink LLC management. 

NOTE: Notification can be made to the FAA to assist in future prevention 

techniques 
As stated in the cover letter, FlightWink LLC, by following our many strict self-imposed 

guidelines, will achieve a safety level greater than that directed by the rules from which we seek 

exemption. T h i s w i II b e especially true when you compare the same operating · 

procedures against a manned aircraft. Again, sUAS are inherently safer due to the fact that they 

are much smaller, fly at much lower speeds with no human operators on board, and there is zero 

fuel to be concerned with in the event of a crash. As processes are further refined, Flight Wink 

LLC's continued extremely conscientious operations will only add to an already higher level of 

safety compared to manned flight. FlightWink LLC's operations will serve the public's best · 

interests as they relate to the FAA's endeavor to integrate VAS i.nto the NAS. 

Re~latiOns- Exemption Requested by FlightWink LLC; 

Pursuant to 14 C.FR. § 11.81(e), FlightWink LLC seeks exemption from the below mentioned 

regulations and provides reason as to why the exemption should be approved based on the level 

of safety at least equal to that of which the rules require·. 

• 14 C.FR. Part 21 Subpart H- Ainvorthiness Certificates: 

-~ Establishes: The procedural requirements for the issuance of ainvorthiness certificates as 

required by 14 C.F.R. § 91.203(a)(l) 

Given the small size of the UAS, the limited operating areas and meticulous procedures defined 

within the training and operations section, 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" with consideration "of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS." 

NOTE: The FAA has recently set precedence to this regulation within like given parameters and an 

exemption should be approved on this basis. See exemption approvals for Blue Chip, Astraeus Aerial, 

Aerial MOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media, and Pictorvision. 
• 14 CF.R. § 45.23(b)- Aircraft Marking and Identification Requirements: 

>- 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

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. · 

Flight\yink LLC will ensure compliance with§ 45.29(/) to meenhe intent of the . 

regulation by placing the word "Experimental," for all to see, on each craft plus a unique 

·FlightWink LLC identification number in the event several craft of the identical like and 

type are acquired. 

NOTE: The FAA has set precedence to this regulation within like given parameters and an exemption 

should be approved on this basis along with previous exemptions: Nos. 10700, 10167 and 10167 A. Also, 

see most recent exemption approvals for Blue Chip, Astraeus Aerial, Aerial MOB, HeliVideo Productions, 

RC Pro Productions, Snapro/1 Media, and Pictorvisionfor forther justification of approval. 

• 14 CF.R. 61.113 (a)(b) and 61.133(a)(l)(ii)- Private a~d Commercial Pilot Privilege 

and Limitations: 

~- 14 C.F.R. § 61.113: "(a) Except as provided in paragraphs (b) through (g) of this section, no· 

person who holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation· 

or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, 

act as pilot in command of an aircraft in connection with any business or employment if 

>- 14 C.F.R. § 61.133: (a) Privileges - (1) General. A person who holds a commercia~ pilot 

certificate may act as pilot in command of an aircraft- (ii) ·For compensation or hire, provided 

ihe person is qualified in accordance with this part and with the applicable parts of this chapter 

that apply to the operation. 

Currently, there are no applicable areas identified for sUAS in either the private or 

commercial sector and therefore an exemption is required to conduct commercial 

operations. As flight operations Will be conducted in a restricted environment as 

described in the operations section, these strict guidelines will achieve an equivalent level 

of safety for. each individual flight especially when compared to commercial flights 

identified in Part 61 when originally developed .. In addition, each craft's primary 

control system will utilize GPS waypoints for guidance and control, FlightWink LLC's 

flight operations will be conducted by qualified 0 perators with ground school 

certification, a Class III medical, and a VSO Operator's Certification. 

NOTE: Operators may or may not hold a private pilot license. 

Due to the fact not all operators will be rated pilots, all flight operations will be overseen 

and directed by, DeWitt M. Harkness, a current FAA certified private pilot with 

current FAA ground school certification. a current Class 3 medical, and holding a ~ . current VSO Operator's certification from the Unmanned Safety Institute. This wi!I give 

all FlightWink LLC's operations an equivalent level of safety. 
• 14 C.F.R. 91. l(a)- Civil Aircraft Ainvorthiness: 

• 

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

Currently there is no airworthiness certificate for either of the craft. Flight Wink LLC 

will submit same to the FAA as soon as the manufacturer's supply one. In the interim, 

daily pre and post flight inspections will be accomplished in accordance with 

manufactures maintenance martual(s) and guidance. During flight, the OIC will adhere 

to§ 9 I. 7(b) and abort air operations immediately upon identification of an in flight 

emergency. A II ·maintenance performed will be conducted by our maintenance 

technicians and/or by the manufacturer's themselves. By applying the prescribed 

operations, inspection, and maintenance procedures within the operations section, an 

equivalent level of safety will be achieved. 

. . 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91.7(a): Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, /0167, 10167A, 10602, 32827, and 10700. Also, see most recent 

exemption approvals for Blue Chip, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro 

Productions, Snaproll Media and Pictorvisionfor forther justification of approval. 

I4 C.F.R. 9I.I03-PreflightAction: 

> States: Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include- (paragraphs a, b, I and 2) 

A "Pre-flight Mission" brief must be attended by all crewrnembers. This "PMB" 

will contain weather and all flight information including emergency and abort 

procedures. A signature will be required by all crew members indicating they have 

received the PMB and have read any NOT AMs or other procedural updates which 

may have an impact on standard operating procedures. In addition, the OIC will 

verify the craft is ready for flight by coordinating with the maintenance technician 

during pre-flight inspection. 

The exemption requested for this section is specifically addressed toward the 

requirements that do. not apply to sUAS operations such as runways and air traffic 

control integration. 

NOTE: As previously stated, air traffic. control and airport operator will be notified prior to any 

operations being executed within [lve statute miles 

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Blue Chip, Astraeus 

Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media, and 

Pictorvision. 

• I 4 C.F.R. 9 I. I09(a) ._ FlightJnstruction: 

> States: No person may operate a civil aircraft (except a manned free balloon) that is being used 

for flight instruction unless that aircraft has folly fUnctioning dual controls. 

The majority of sUAS by design are developed with single operational control through 

the use of pre-determined GPS enabled waypoints programmed before or during flight in 

addition to. the use of a single hand held transmitter or control station controlled by the 
OIC. The design does not allow for dual controls during flight training and therefore 

the exemption is requested to qualify/certify operators as required by the manufacturer 

along with specific operations training and proce~ures identified above within section II.· 

An equivalent level of safety will be ensured during training operations by utilizing the 

same flight planning process for normal operations. As identified in the flightplanning document, all ground hazards will be identified and mitigation· techniques will 

be enacted to ensure flights stay outside of 250 feet of any improved roads; · 

vehicles,_ persons or structures. Training operations will be conducted within a 

confined space-on our 160-acre private land ·in rural Wabaunsee County, Kansas. 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91.1 09( a): Exemption 

Nos. 5778K and 9862A. Also, see most recent exemption approvals for Blue Chip, Astraeus 

Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, ·Snapro/1 Media, and 

Pictorvisionfor fUrther justification of approval. 

• 14 C:F.R. 91.119 (c)- Minimum Safe Altitudes: 

• 

);> States: Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: (c) Over other than congested areas. An altitude of 400 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 400 feet to any person, vessel, vehicle, or structure. 

FlightWink LLC operations will be conducted at 400 feet AGL or below in uncontrolled 

Class G and occasionally. E airspace. As sUAS are inherently safet tha,n traditional 

aircraft d~e to their small size, light weight, battery operated vice fuel and no human onboard; FlightWink LLC will not operate within 250 feet to any improved roads, 

vehicles persons or structures (other than those being inspected as part of the flight 

· operation). In addition, objects/hazards will be identified and geo-located prior to 

flight. 

NOTE: See Flight Planning Document 

14 C.F.R. 91.121- Altimeter Settings: . 

);> States: 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 ... 

SUAS are equipped with Global Positioning System (GPS), which provide altitude 

and geo-location data to the operator. Due to this fact, an exemption is required for 

this system to be utilized in flight. GPS's are precise within a few feet and therefore 

meet a safety level equal to if _not higher than regulatory guidance. 

As described in the emergency procedures section, in the event the air vehicle losses GPS 

signal, automated landing will immediately commence. The flight plan is built in such a 

way that hazards are identified prior to launch and an immediate landing within the flight 

plan will ensure all hazards are avoided. 

--- -~---- ---------
• 

• 

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Blue Chip, 

Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media, 

and Pictorvision. · 

14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR Conditions: 

~ States: No person may begin a flight in ·an airplane under VFR conditions unless (considering 

. wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed- (1) During the day, to fly after that for atleast30 

minutes; 

This regulation is written based on the capabilities of a traditional aircraft which have 

flight times of several hours or greater. Since our crafts have flight times of only an 

hour. or less, this regulation would effectiv~ly deny the ability of the air vehicle to 

oper_ate. 

Using our Cessna 172 as an example, approximately 8% remaining fuel is required to 

meet the 30-minute flight time. To meet this regulation's intent, FlightWink LLC will 

operate its air vehjcles to no less than 10% remaining battery power to ensure safe 

landing and retrieval. This 10% buffer is greater than the Cessna 172. Our ability to 

quickly and safely land our crafts in non-traditional environments ensures at least an 

equal level of safety. 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91.151 (a): Exemption 

Nos. 10673, 2689F, 5745, 10673 and 10808. Also, see most recent exemption approvals for Blue· 

Chip, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media and 

Pictorvisionfor further justification of approval. · . 

14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)- Maintenance 

Inspections: 

~ 91.405(a) States: 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. 

~ 9/.407(a)(l) States: (a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless-(/) It has been approved for return to 

service by a person authorized under§ 43.7 of this chapter. 

~ 91.409(a)(2) States: (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-(2) An inspection . 

for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No 

inspection performed under paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a· person authorized to perform annual 

inspections and is entered as an ''annual'' inspection in the required maintenance records. 

~ 91.417(a) & (b) States:( 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: (paragraphs I (i- iii), 2 (i- vi)); (b) The owner or operator shall 

retain the following records for the periods prescribed: (paragraphs I - 3). 
Due to the fact our crafts at present do not have an airworthiness certificates, these 

regulations do not apply and therefore an exemption is required. Pre/Post and 

routine inspections ·(not to exceed 50 flight hours) and maintenance will be conducted in 

accordance with the manufacturer's guidance as stated in the operations manual. In 

addition, to meet the intent of these regulations, FlightWink LLC, will maintain daily logs 

of pre and post flight inspections and have maintenance performed by certified 

technicians and/or the manufacturer themselves. In the event maintenance is 

required, certified technicians will verify the air vehicle is in flight readiness status prior 

to . releasing to OIC for use in operation.s. · 

Unscheduled maintenance will be accomplished in the event of a mechanical or structural 

failure during flight. Upon completion of unscheduled maintenance, documentation 

will be provided to the OIC to sign off and verify that the air vehicle is once again ready 

for flight and accept the level of risk associated with returning the air vehicle to flight 

status. · At no time will there be changes made to any craft that would impact the 

structurai integrity of the airframe without the. manufacturer making such changes 

and verifying the craft is airworthy. · 

All inspection and maintenance will be documented and maintained in-house. These 

actions will meet the intent of the regulation exemption is being requested and lead to an 

equivalent level of safety. 

Public Interest: 

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Blue Chip, 

Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media and 

Pictorvision. 

The public's best interest is achieved by the safe integration of UAS into the NAS. With the 

ongoing exemption process, the FAA has to identify those exemption requests with the public's 

best interest in mind and select the companies who· will be able to achieve this in a safe and 

responsible manner. 

Two of the main problems the public has with UAS are the fear of what they will be used for 

and whether or not they are safe to fly within the same airspace as commercial airliners. 

FlightWink LLC is more than willing to help with public education and that starts with 

conducting operations within strict operating environmentS and then providing the results to the 

public to start to sway opinion in a positive light. 

With the U A V experience this team has built over the past year and one half, the FAA will 

provide a great service to the American public by approving FlightWink LLC's exemption · 

request. 

FlightWink LLC will provide any additional information. requested and will diligently work 

with to make this approval a reality as it is in the best interests of and safety of the public as 

directed by Congress. 
Privacy Concerns; 

Another concern the. public has with the integration of UAS into the NAS is privacy and 

spying especially recently with the disclosure of the NSA's communication programs. 

The media has also placed a negative light on UAS when it comes to privacy by showing how 

the military has used this technology to conduct combat operations through the use of the . . 

visual and infrared sensors they carry. 

Fortunately with this matter, FlightWink LLC is well versed in the privacy and oversight 

concerns which are addressed by federal government regulations: Executive Order 12333, DOD 

Directive 5240.1-R and AFI 14-104. Although the regulations do not apply to private 

c_ommercial entities, our knowledge and experience in working within these regulations will 

assist and ensure any and all privacy concerns will be minimal and immediately mitigated. 

In addition, the most efficient and successful avenue to combat these concerns is to educate the 

public in how UAS technology will be used to exponentially improve all of otir lives and place 

emphasize on how we should embrace the technology instead of fearing it. 

With this constantly in mind, Flight Wink LLC will look at actions we can take to move 

forward with this endeavor and assist the FAA and all UAS employment companies as a 

whole to better public perception and create a cohesive environment we all can operate in 

safely.-

FAA Collaboration: 

FlightWink LLC is and will always be committed to the safe integration of UAS into the 

NAS and will provide any requested information on its flight operations to the FAA to 

assist in the rules making process. 

As stated in the operations· section, post flight logs will be required to be completed to 

produce monthly flight summaries which will include both positive and negative reporting 

placing emphasize on any issues which may arise during any segment of the operations. 
Federal Register: 

Pursuant to Section 333 of PL 112-95 commonly known as the "FAA Modernization and Reform 

Act of 20 12" or "The Reform Act", Flight Wink LLC hereby applies for authorization to conduct 

commercial unmanned aerial systems (UAS) operations for the agriculture, oil and gas, aerial 

photography and wildlife preservation industries, within the United States National Airspace 

System (NAS); within Class G and occasionally·E airspace. 

Rules from which FlightWink LLC seeks exemption: 

• 14 C.P.R. Part 21·subpart H 

• 14C.F.R.§91.7(a) 

• 14 C.P.R.§ 45.23(b) 

• 14 C.P.R. §.61.113 and 61.133(a)(l)(i_i) 

• 14 C.P.R.§ 91. l(a) 

• 14 C.P.R.§ 91.103 

• 14 C.P.R.§ 91.109(a)-

• 14 C.P.R.§ 91.119 

• 14 C. F. R. § 91.121 

• 14 C.F.R. § 91.151 (a) 

• 14 C.P.R.§ 91.405(a) 

• 14 c_.FR. § 9~.407(a)(1) 

• 14 C.P.R.§ 91.409(a)(2) 

• 14 C.P.R.§ 91.417(a) & (b) 

Throughout this exemption request, FlightWink LLC has shown how our expertise and 

knowledge witJ:l UAS safety and technology will ensure the public's best interest is always 

strictly adhered to. We wi 11 assist the FAA with their charge to "safo/y accelerate the 

integration of civil unmanned aircraft systems into the national airspace system" as directed 

· by Cong~ess. 

We have also shown how the approval of our request will meet and exceed the FAA's 

requirement for. "at least an equivalent/eve/ of safoty" from the regulations we seek exemption. 

At each level through process refinement, FlightWink LLC, will.capture and document the best 

practices to develop proven tactics, techniques, and procedures for each and every UAS 

operation .. 

. . 

When it comes to· the public and what is in their best interest, yo·u will be hard pressed to find a 

tearri more qualified for an exemption under Section 333 than FlightWink LLC. 

It will be a great service to the country and in ·the ''public's best interest" to include our 

team in the UAS integration endeavor. 
')_/ . ;, 

C() 

(X) 

UNMANNED SAFETY INSTITUT

VISUAL LINE OF SIGI-IT 

DeWitt M. Harkness Jr. 

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by the Umnal'med .lnstllute'1'M as a J'llsual 

Opera/or 'I'M on this the 2'"1 day of.lr:muttry 20 1.5. 

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President 

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