Washington, DC 20590 

RE: Application to Amend Section 333 Exemption Regulatory Docket No. FAA-2015-0137 

Dear Sir or Madam: 

In December of 2014 lnnova Flight, LLC. dba: lnnova Flight Training and Systems ("lnnova Flight"), 

submitted a request for an exemption from the Federal Aviation Regulations ("FARs") to allow 

commercial operations of its Sandstorm unmanned aerial system ("Sandstorm") (i.e., "small unmanned 

aircraft" or "UAS") as part of lnnova Flight Instruction Program. The application was assigned Docket 

No. FAA-2015-0137. 

We respectfully request consideration to amend our application by the inclusion of three additional 

UAVs as described herein. lnnova Flight submits these supporting materials as confidential documents 

pursuant to 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and proprietary 

information that lnnova Flight has not and will not share with others. 

Additionally, these documents contain operating conditions and procedures that are not generally 

available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 

552 et seq., and any other requirements established by the FAA pursuant to Section 333 of the Reform 

Act. 

In accordance with 14 C.F.R. § 11.81, lnnova Flight provides the following information in support of its 

Petition for Amendment. 

The contact information for Petitioner is as follows: 

lnnova Flight LLC. 

Address: 1940 Airport Road, 

Great Falls, Montana 59404 

Attn: Douglas M. Forest 

Ph: (406) 799-0507 Email: Doug@ lnnovaFiight.com 

Attn: Bruce J. Determann 

Ph: (603) 472-3342 

Email: Bruce@ lnnovaFiight.com 

Innova Flight, LLC -- 1940 Airport Court- Great Falls, MT 59404 --406.799.0507 -- InnovaFlight.com 
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 

The lnnova Flights seeks to add for use small unmanned aerial system ("sUAS") to support a range 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. 

Innova Flight, LLC -- 1940 Airport Court - Great Falls, MT 59404 -- 406.799.0507 -- InnovaFlight.com 
• Twin Otter ARF 

• Delta Wing 

lnnova Flights is submitting amendment for the addition of ParkZone T-28 Trojan PNP, Twin Otter ARF 

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

by professionals. lnnova Flights has expertise and knowledge in the operations of this systems. lnnova 

Flights 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 with 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 

Steering: Steerable nose gear 

Wing Bolt Size: M3 x 25 

Control Surface Travel Information 

Low Rate High Rate 

Aileron: 3/8 inch (9.5mm) Aileron: 1/2 inch (13mm) 

Elevator: 1/2 inch (13mm) Elevator: 5/8 inch (16mm) 

Rudder: 5/8 inch (16mm) Rudder: 7/8 inch (22mm) 

Innova Flight, LLC -- 1940 Airport Court - Great Falls, MT 59404 -- 406.799.0507 -- InnovaFiight.com 
-

Product Specifications 

Wingspan: 82.0 in (2080mm) 

Overall Length: 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 

CG (center of gravity): The recommended CG location is 2 1/2 (64mm) to 3 inches (76mm) behind the 

leading edge of the wing. 

Inn ova Flight, LLC -- 1940 Airport Court - Great Falls, MT 59404 -- 406.799.0507 -- InnovaF!ight.com 
Product Specifications 

Wing span: 2122mm 

Wing area: 80dm2 

Valid payload: 1 000-2000g 

Servos: 3-wire servos (included) 

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 Flight, LLC -- 1940 Airport Court - Great Falls, MT 59404 -- 406.799.0507 -- InnovaFiight.com 
All supporting documentation provided within our original 333 Exemption Request (

oc

e

2015-0137) applies to the three additional UAVs for 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 safety 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 within visual line-of-sight and national security. The proposed UAS operations will benefit the 

public as a whole by fostering 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 for 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 support the requested 

amendme t, please contact the undersigned at: 

lnnova Fli ht, LLC 

Phone: 40 -799-0507 

ht.com 

Innova Flight, LLC -- 1940 Airport Court - Great Falls, MT 59404 -- 406.799.0507 -- InnovaFlight.com