U.	S.	Department	of	Transportation

Docket	Management	System

West	Building	Ground	Floor,	Room	w12-140	1200	

New	Jersey	Avenue,	SEWashington	DC	20590	

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform 

ACT and Part 11 of the Federal Aviation Regulations. 

Petitioner: 

Eric Hall, Innovations 10.01 LLC (INNOVATIONS) 1001 Locust Suite 200 

Kansas City, Missouri

Telephone: 816-292-8777 

Email: eric.hall@innovations1001.com 

INNOVATIONS intends to incorporate the use of SUAS for a variety of 

projects which may include but not be limited to project and construction 

management, inspections and monitoring; environmental review projects; 

aerial surveying; agricultural projects; educational and research projects; 

aerial filmmaking, photography and real estate purposes; search and rescue, 

etc. 

Specific Section(s) seeking exemption: 

14 C.F.R Part 2114 C.F.R. 45.23(b)14 C.F.R. 61.113(a) and (b) 14 

C.F.R. 91.7(a)14 C.F.R. 91.9(b)(2)14 C.F.R. 91.10914 C.F.R. 91.119 

(b)14 C.F.R. 91.21514 C.F.R. 91.104 through 91.417 

Extend of relief requested: 

To permit commercial operation of Small Unmanned Aircraft Systems 

(SUASs) for operations conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

Said exemption would permit the operation of SUASs under controlled 
conditions in limited, predetermined and controlled airspace. Upon granting 

of this proposed exemption request, INNOVATIONS would conduct 

commercial operations of SUASs meeting or exceeding all operational and 

safety requirements per Section 333. 

Public Benefit: 

1.Project and construction management, inspections and monitoring. The 

use of SUASs on construction sites can improve the safety of workers, 

local residents and general public by assessing potential dangerous 

situations. Falls and injuries may be reduced or eliminated through a 

more thorough review of the construction sites. Visual inspections of 

fall protection systems on buildings and bridges can be surveyed 

without placing workers at risk. In some cases, SUASs may reduce 

the reliance of fixed wing aircraft to monitor and document site 

conditions. This may improve safety as well as reduce environmental 

impact by reducing energy usage; 

2.Environmental Review projects. The use of SUASs during the process of 

reviewing projects as required by 14 C.F.R. 50.4, 58.5 and 58.6 would 

provide a more in-depth Environmental Review of the project site as 

well as surrounding areas. Reliance of helicopters or small aircraft 

may be eliminated; 

3.Aerial surveying. The use of SUASs in connection with aerial surveying of 

smaller areas may eliminate the use of helicopters or aircraft. This 

could provide a more cost effective, safer and more energy efficient 

product; 

4.Remote Sensing projects. The use of SUASs could provide views and 

information for remote and inaccessible areas. This could promote 

worker safety as well as reduce the reliance on helicopters and 

aircraft; 

5.Educational and Research projects. The use of SUASs could provide 

information for said projects in a more cost effective and efficient 

manner than other available options; 

7.Aerial filmmaking, photography and real estate purposes. The use of 
SUASs may provide a point of view previously unavailable through 

other means. They would be more cost effective, efficient and more 

safe than helicopters and aircraft; and 

8.Search and rescue. The use of SUASs may provide assistance to local law 

organizations during search and rescue missions. SUASs may reach 

areas unattainable or viewable with helicopters and aircraft. SUASs 

may be implemented quicker as time is of the essence during search 

and rescue operations. 

Reasons why the exemption would not adversely affect safety or how the 

exemption would provide a level of safety at least equal to the existing 

rule. 

Proposed operations using SUASs provide increased safety enhancement 

especially when compared with helicopters and aircraft for the following 

reasons: 

1. The SUASs will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the pilot; 

3. Maximum total flight time for each operational flight will be thirty 

(30) minutes. Flight times may be less than thirty (30) minutes as 

the UAS will continuously monitor battery reserve and return to 

the ground station with at least 15% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will 

never exceed 400 feet AGL; 

5. Minimum crew for each operation will consist of the SUAS pilot and 

a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said 

SUAS; 

7. Written and/or oral permission from relative property owners will be 

obtained prior to operating the SUAS; 
8. All permits, permissions, etc. will be obtained from local government 

offices as required; 

9. The SUAS operated will weigh less than 55 pounds including payload 

(camera, lens, gimbal, etc.); and 

10. The SUAS will operate at speeds less than 50 knots, hover and 

simultaneously move vertically and horizontally; 

11. The SUAS will have the capability to return and land at the predetermined location with the Security Perimeter should the SUAS 

lose communication or GPS signal during any operations; 

12. The SUAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies; 

14. Operations will not be conducted over densely populated areas or 

heavily traffic highways; and

15. Operations will not be conducted within five (5) NM of an airport or 

heliport. 

INNOVATIONS will abide by all regulations including the following: 

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. 

Airworthiness Certificates; 

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in 

Command and 61.133 Commercial pilot privileges and 

limitations; 

4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard 

requirements; 

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and 

certain flight tests; 
7. 14 C.F.R. 91.119 Minimum safe altitudes: general; 

8. 14 C.F.R. 91.121 Altimeter settings; 

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions; 

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. 

airworthiness certificates: Instrument and equipment requirements; 

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment 

and use; 

13. 14 C.F.R. 91.401 Applicability; 

14. 14 C.F.R. 91.403 General; 

15. 14 C.F.R. 91.405 Maintenance required; 

16. 14 C.F.R. 91.407 Operation after maintenance, preventive 

maintenance, rebuilding or alteration; 

17. 14 C.F.R. 91.409 Inspections; 

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment 

tests and inspections;

19. 14 C.F.R. 91.413 ATC transponder tests and inspections;

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and 

21. 14 C.F.R. 91.417 Maintenance records. 

Privileges of exemption outside the United States. 

INNOVATIONS does NOT wish to exercise the privileges of this 

exemption outside the United States.
Aircraft Specifications:

DJI Phantom 3 Professional

Aircraft

Weight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

Camera

Sensor

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range

100-3200 (video) 100-1600 (photo)

Shutter Speed

8s -1/8000s

Image Max Size

4000 x 3000

Still Photography Modes

Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time-lapse

Video Recording Modes

Phantom 3 Professional

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30
FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

2.7K: 2704 x1520p 24/25/30 (29.97)

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate Of Video Storage

Phantom 3 Professional

60 Mbps

Phantom 3 Advanced

40 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature

0°C to 40°C

Gimbal

Controllable Range

Pitch -90° to +30°

Stabilization

3-axis (pitch, roll, yaw)

Vision Positioning

Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

30 cm-300 cm

Operating Range

30 cm-300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote Controller

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

Video Output Port

USB

Operating Temperature

0°C- 40°C

Battery
6000 mAh LiPo 2S

Mobile Device Holder

For tablet or phone

Receiver Sensitivity (1%PER)

-101 dBm ±2 dBm

Transmitter Power (EIRP)

FCC: 20 dBm

CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Battery Charger

Voltage

17.4 V

Rated Power

Phantom 3 Professional

100 W

Phantom 3 Advanced

57 W

Intelligent Flight Battery

Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g

Max Flight Time

Approximately 23 minutes

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W

App / Live View

Mobile App

DJI GO

EIRP

100mW

Power Spectral Density

6.9mW/MHz

Live View Working Frequency

2.4GHz ISM

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

Latency
220ms (depending on conditions and mobile device)

DJI	Inspire	1

Aircraft

Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Power Spectral Density

9.06mW/MHz

Gimbal

Model

ZENMUSE X3
Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60
HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Battery (Standard)

Name

Intelligent Flight Battery

Model

TB47
Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Positioning

Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

Please contact our office if you have any questions or need 

additional information.