October23rd,2015U.S.DepartmentofTransportationDocketManagementSystem1200NewJerseyAve.,SEWashington,DC20590Training&SystemsPage1of6RE:ApplicationtoAmendSection333ExemptionRegulatoryDocketNo.FAA-2015-0137DearSirorMadam:InDecemberof2014lnnovaFlight,LLC.dba:lnnovaFlightTrainingandSystems("lnnovaFlight"),submittedarequestforanexemptionfromtheFederalAviationRegulations("FARs")toallowcommercialoperationsofitsSandstormunmannedaerialsystem("Sandstorm")(i.e.,"smallunmannedaircraft"or"UAS")aspartoflnnovaFlightInstructionProgram.TheapplicationwasassignedDocketNo.FAA-2015-0137.WerespectfullyrequestconsiderationtoamendourapplicationbytheinclusionofthreeadditionalUAVsasdescribedherein.lnnovaFlightsubmitsthesesupportingmaterialsasconfidentialdocumentspursuantto14C.F.R.§11.35(b),asthematerialscontainconfidentialcommercialandproprietaryinformationthatlnnovaFlighthasnotandwillnotsharewithothers.Additionally,thesedocumentscontainoperatingconditionsandproceduresthatarenotgenerallyavailabletothepublicandareprotectedfromreleaseundertheFreedomofInformationAct,5U.S.C.§552etseq.,andanyotherrequirementsestablishedbytheFAApursuanttoSection333oftheReformAct.Inaccordancewith14C.F.R.§11.81,lnnovaFlightprovidesthefollowinginformationinsupportofitsPetitionforAmendment.ThecontactinformationforPetitionerisasfollows:lnnovaFlightLLC.Address:1940AirportRoad,GreatFalls,Montana59404Attn:DouglasM.ForestPh:(406)799-0507Email:Doug@lnnovaFiight.comAttn:BruceJ.DetermannPh:(603)472-3342Email:Bruce@lnnovaFiight.comInnovaFlight,LLC--1940AirportCourt-GreatFalls,MT59404--406.799.0507--InnovaFlight.comTraining

& Systems

Page

2 of 6 RELEVANT STATUTORY AUTHORITY This Petition for Amendment application
for use of the Aircraft (UAS) for flight training within FAA approved UAS airspace for any FAA approved UAS use pursuant

to the amendment requested herein, will advance the Congressional mandate

in Section 333 of the FAA Reform Act to accelerate the introduction

of UASs into the NAS. Section 333 directs the Secretary

of Transportation

to consider whether certain UASs may operate safely
in the NAS before completion

of the rulemaking required under Section 332 of the FAA Reform Act. To make that determination,
the Secretary must evaluate which types of UASs do not create

a hazard
to users of the NAS or the public or pose

a threat to national security

in light of several criteria: • The UAS's size, weight, speed, and operational capability; • Operation

of the UAS in close proximity

to airports and populated areas; and • Operation

of the UAS within visual line of sight of the operator. FAA Reform Act§ 333{b)(1

). Once the Secretary determines that such vehicles

" may operate safely
in the national airspace system

, the Secretary shall establish requirements

for the safe operation

of such aircraft

in the national airspace system.

" 

### /d. § 333(c) (emphasis added). The Federal Aviation Act expressly grants the FAA the authority
to issue exemptions.

49 U.S.C.

§ 44701 (f). This statutory authority,
by its terms, includes exempting civil aircraft

, as the term
is defined under §401 01 of the Act, from the requirements that all civil aircraft must

- have
a current airworthiness certificate

, 49 U.S.C.

§ 44711 (a), and those used in commercial service must be piloted by private and/or commercial pilots. 14 C.F.R. §§ 61.113(a) and (b)

, 61.133. The grant of the requested exemption

is in the public interest based on (i) the clear direction

in Section 333 of the FAA Reform Act; (ii) additional authority

in the Federal Aviation Act

, as amended

; (iii) the strong equivalent level of safety surrounding
the proposed operations; and (iv) the significant public benefit, including enhanced safety and cost savings associated with utilizing UASs for flight instruction for FAA approved operations. Accordingly, lnnova Flight respectfully requests that the FAA grant the requested amendment without delay. A party requesting
an amendment must explain the reasons why the amendment:

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how

it would provide

a level of safety at least equal to the existing rules). See 14 C

. F.R.
§ 11.81 (petitions for amendment). 2. INNOVA FLIGHT'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS

OF SECTION 333 OF THE REFORM ACT lnnova Flight's proposed operations

in this Petition for Amendment qualify for expedited approval pursuant

to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied. Airworthiness Th e lnnov
a F lights

s ee ks to a dd for u se sm a ll unm
a nn e d a e ri a
l syst
e m ("sUAS")

to support

a r a nge of flight instruction: Park Zone T-28 Trojan PNP

, Twin Otter ARF and Delta Wing unmanned aerial system (all of these are referred
to as "aircraft" from here on). lnnova Flights will continue with the recommended factory

' s maintenance plan for these aircraft through authorized service contractors. Innov a F li g ht
, LLC

- - 1 940 A irport Co u rt - Great Fa ll s, M T 59404

-- 406

. 799

. 050 7 -- I n nov aF
l i g h t.comTraining

& Systems

Page

3 of 6 

### lnnova Flight has flown these aircraft since this date in 2011 and currently continues

to operate near Columbia Falls, Montana. The aircraft for this amendment are: • Park Zone T-28 Trojan PNP • Twin Otter ARF • Delta Wing lnnova Flights

is submitting amendment
for the addition
of ParkZone T-28 Trojan PNP, Twin Otte

r ARF and Delta Wing Airplanes; these platforms are commercially reliable and are popular products

u ti lized by professionals. lnnova Flights has expertise and knowledge

in the operations

of this systems.

l nnova F li ghts will utilize training and operational procedures that follow the guidelines presented

in N 8900.227. 

## ParkZone

T -28 Trojan PNP Airplane Wingspan:

44 in (1118mm) Overall Length: 36 in (914mm) Flying Weight:
30 oz (875 g) Motor Size: PKZ 480 960Kv outrunner brush less motor Radio: Minimum 4-channel recommended
(not included) Servos: 3-wire servos (included) Trim Scheme Colors: White
w

i th black

, red

, and blue Prop Size

: 9.5 x 7.5 Speed Control: E-flite 30A Pro Brush less ESC with Switch Mode BEC EFLA

1 030) Recommended Battery: Minimum 3-cell 1800mAh Li-Po battery (not included) Scale: Warbird Landing Gear: Wire nose gear and main gear

, foam wheels St ee ring: Steerabl

e nos e g ea
r Wing Bolt Size: M3 x 25 Control Surface Travel Information Low Rate

High Rate Aileron

: 3/8 inch (9 .5 mm)

A ileron

: 1 / 2 inch (13mm) E levator: 1/2 inch (13mm)

E levator: 5/8 inch (16mm) Rudder

: 5/8 inch (16mm) Rudder

: 7/8 inch (22mm) Inn o va F li g ht
, LL C --
1 94 0 A i rpor

t Co urt

- Grea

t Fa ll s, MT 594 0 4 -- 4 0 6.799.

0 5 0 7 -- I nn ovaF

i i g ht. co mTraining

& Systems 

## T win Otter ARF 

# - Product Specifications Wingspan: 82.0 in (2080mm) Overall

L ength: 65.0 in (1650mm) Wing Area: 738 sq. in (47

. 61 sq. dm) Flying Weight: 11.5-13.2

lb. (5.2-6

. 0 kg) Engine Size: 36-.40 2-stroke



# - Motor Size: Power 25 BL Outrunner Motor Radio

: 6+ channel with 8-1 0 servos Page

4 of 6 CG (center of gravity): The recommended

CG location

is 2 1/2 (64mm)
to 3 inches (76mm) behi
n d the leading edge of the wing. I nn o v a F

l ig ht
, LLC

- - 1 94 0 A i rpor

t Co u r t - Grea

t Fa ll s, M T 594 0 4 -- 4 0 6

. 799

. 05 0 7 -- I nn ovaF

!i g ht. comTraining

& Systems 

## Gowe white flying Delta Wing Product Specifications Wing span: 2122mm Wing area: 80dm2 Valid payload:

1 000

- 2000g Servos: 3-wire servos (included)

Page

5 of 6 Folder able prop: 12 * 6 or 12 * 8; 2 * 20g servos (the size of servo hole on the plane
is 40*40mm); 60A ESC or bigger; 4s 6000---1 OOOOmah lipo Speed Control: E-flite 30A Pro Brush less ESC with Switch Mode BEC EFLA

1 030) Recommended Battery: Minimum 3-cell 1800mAh Li-Po battery (not included) In support
of this amendment, lnnova Flight can provide with
a request for confidential documents pursuant
to 14 C.F

. R. 

### § 11.35(b), confidentiality,
the following documents: Aircrew Operating Handbook ("AOH"); the Local Pilot Initial Qualification Syllabus; the Observer Initial Qualification Syllabus; the Safety Pilot Initial Qualification Syllabus; and the Flight log books. Innova

F li gh t , LLC

- - 1 940 Airport Co urt

- Great Fa ll s , MT 59404

- - 406

. 7 99.050

7 -- InnovaFiight.comTraining

& Systems

Page

6 of 6 Mandatory Operating Conditions lnnova Flight proposes that the grant of the amendment

be subject
to all conditions, restrictions and requirements

as proposed

in our original 333 Exemption Request

( Docket No. FAA-2015-0137) All supporting documentation provided within our original 333 Exemption Request (Docket No.FAA2015-0137) applies
to the three additional UAVs fo r which we are requesting approval herein

, including but not limited to 14 C.F.R.



### § 11

. 81, supporting statements
for how our operations:(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how
it would provide

a level of sa
f ety at least equal to the existing rules). 3 . CONCLUSION lnnova Flight's Petition for Amendment satisfies the criteria articulated

in Section 333 of the Reform Act of 2012 including weight

, speed

, operating capabilities, proximity

to airports and populated areas

, operation

wi
t hin visual line-of-sight and national security. The proposed UAS operations will benefit the public as a whole by foster

i ng a collaborative relationship between the FAA and In nova Flight which focuses on UAS training

, qualifications

, and processes involving the safe and efficient operation

of UAS in the NAS. In consideration

of the foregoing

, lnnova Flight's Petition for Amendment provides the FAA with more than adequate justification

f or granting

of the requested amendments allowing lnnova Flight to perform flight instruction

as part of lnnova Flight's Flight Instruction Program. Should yo have any questions

, or if you need additional information

to suppor

t the requested amendme

t, please contact the undersigned

at: lnnova Fli ht, LLC Phone: 40 -799-0507 ht.com Inn ova Fl i g ht
, L L C
- - 1 94 0 A i r p or t Co u r t - Grea

t Fa ll s, M T 594 0 4 -- 4 0 6

. 7 99. 0 5 0 7 -- Inn o v aFl

i g ht. co m