10 King Fisher Drive

Birdsboro, Pennsylvania, 19508

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Onuku Industries, LLC Petition for Exemption from Section 333 of the FAA 

Modernization and Reform Act and Part 11 of the Federal Aviation Regulations.

To Whom It May Concern:

RE: Pursuant to Section 333 of the FAA Modernization & Reform Act of 2012 and 14 C.F.R. part 

11. Onuku Industries, LLC, a R&D UAS manufacturer that is developing baseline models to sell 

commercial, hereby applies for exemptions to the listed Federal Aviation Regulations to allow 

testing of new equipment, manufacturing, and sale. Above operations may only be conducted 

under the conditions outlined below or required by section 333.

I. Name and Address of Applicant

Onuku Industries, LLC

ATTN: Jason King, VP of Operations

PH: 610.334.4224

Email: Jason.king@onukuindustries.com

Address: 10 King Fisher Drive, Birdsboro, PA 19508
II. Reasons for Proposed Flights

1. Testing new fail safes to ensure safety and better production

2. Fabrication of new frame designs for further strength and stability 

3. Developing modifications to current frame designs

4. Introduce new electrical layouts for more concise wiring and safer electrical 

management

5. Research and development of new motors and propeller designs for function and 

safety

6. Testing new cameras and sensors to make flying in different conditions safer

7. Development of new flight modes and flight programs

8. Payload verification to improve stability and safety while flying

9. Operator training and maintenance for customers

10. Contract flying for commercial operations

III. Pilots in Command

Name: Kyle Moyer

Name: Jason King

Name: Jerod Heck

Name: Mathew Moyer

IV. Flight Crew Requirements

Only the Pilot in command (PIC) currently conducting operations shall be required to 

hold a valid pilots license issued by FAA as Required by 14 CFR part 61 and a Medical 

Certificate prescribed by 14 CFR part 67. All PIC’s will be required to maintain pilot’s 

licenses, a medical certificate, and all other paperwork as long as they wish to fly any UAS 

that is property of Onuku Industries. Only one of Onuku Industries pilots may have control 

of a copter at any given time, all others will take on the role of visual observer (VO).

The PIC must be trained in all aspects of the UAS including, but not limited to, manual 

controlled flight, computer guided flight, autonomous flight, and crash Avoidance, before 
any UAS flights. Training will be accomplished by either UAS flight simulator or flying in a 

designated training area.

The operating PIC must have 10 hours of documented flight time with any Onuku 

Industries flight system and compatible UAS, as well as an additional 15 hours of 

documented flight time on a particular UAS system before the UAS may be flown for a 

commercial operation. The PIC must have at least one VO with them until the operations,

whether it be training, proficiency, or commercial operations, are finished.

The PIC and VO must go through the entire pre-flight checklist and a proficiency flight 

before commencing any flight operation. The pre-flight check includes, but is not limited to,

visual checks for missing or lose bolts, complete check of all electrical components 

connections and wires, and checking radio connections to limit the possibility of signal loss.

No PIC or VO will participate in any flight operation, (ie. training flights, proficiency 

flights, or commercial operations) if BAC is 0.04% percent or higher or within 8 hours of 

consuming alcohol. The PIC or VO will not participate if under influence of over the 

counter, prescribed or illegal drugs that would negatively influence their ability to fly the 

UAS safely. The PIC and VO are responsible for policing themselves and each other.

No flight crewmembers are allowed to hold two way radio, phone, or text messaging 

conversations while any flight operations are being conducted. All commercial operation 

will be discussed and certified before the UAS takes off, so unnecessary distractions are 

avoided. All efforts will be made to make sure non-essential personnel and pedestrians do 

not interfere with PIC or flight crew while operations are in progress.

All applicable information regarding certificates, permits, authorizations, licenses, 

exemption letters, waivers, flight and maintenance logbooks, and operation manuals are 

going to be made available for any proper authority that asks to see them. All information 

pertaining to the current UAS in operation will be in the possession of the PIC and VO until 

the UAS is returned to Onuku Industries property.

Each PIC is responsible for keeping track of all their records, as both PIC and VO, as 

pertaining to: recertification, flight time logs, VO time logs, when and what maintenance 

they have or had other authorized personnel do to the particular UAS they have in their 

possession. 

All flight records will be recorded with: reasons for flight in specific detail, date of flight, 

take off time, landing time, and duration of flight. All maintenance records will be recorded
with: the maintenance performed, date the maintenance was performed, the time the 

maintenance was started, and the time maintenance was completed. All records will be 

kept for at least 7 years, at that time it is up to the PIC to determine if they want to keep 

them any longer.

V. National Security and the Public Interest

Onuku Industries plans to serve as a research and development company that 

manufactures UAS for commercial sale, as well as contract flight operations for companies 

for which purchasing a UAS is not practical. We currently have a small set of materials and 

frames, but plan to expand our inventory of available models to fit all applications that a 

customer might need. UAS have many benefits to their fixed wing cousins. First, they are 

small in comparison and need less space to be stored and maintained. Second, they are 

operated by electric and do not need to carry the dangerous and flammable fuels. Third,

they have an almost minimal impact on surroundings when flight operations are in 

progress. Finally, when companies reach the point that they are comfortable, they will be 

able to minimize people in harm’s way by sending a drone to take care of the situation. An

example would be an electric company using a drone to survey power lines instead of a 

helicopter.

VI. The UAS & Flight

Since Onuku Industries, LLC is a drone manufacturer we cannot say that all drones will 

look the same, as they are modified based on what the customer needs. There are 

several things listed below that will be maintained across all models we build:

 A strong light weight Tarot carbon fiber frame

 Flight controller

 All radio communication equipment

 Commercially tested motors

All our drones have either bright red or orange motor mounts so that orientation of the 

copter can be identified by line of sight. 

MAX. Accent Speed: 5m/s

MAX. Decent Speed: 2m/s

MAX. Flight Altitude: 350m

MAX. Flight Time: approximately 52 minutes 

All Onuku Industries drones will only be operated by one PIC per flight and they must 

comply with the following restrictions:
 All flight operations will take place under 400’ and outside 5 nautical miles from 

any airport unless prior approval is obtained.

 All flight operations will be halted and the drone will land if a full scale aircraft 

enters the airspace to right of way to the full scale aircraft.

 All takeoff and landing locations will be clearly marked and will be clear of all 

non-essential people for at least 10’.

 The UAS will never be used as an invasion of privacy it will only be used for the 

purposes listed above.

 The general public safety and aviation safety will always be the top concern for 

the PIC and VO’s. Pre-developed flight plans will be used whenever possible to 

limit the amount of human error that can interfere with the successfulness of 

the flight operations.

 The Pic will always complete the preflight checklist before each takeoff.

VII. Sections of 14 C.F.R. and Reasons that Applicant is Seeking Exemption from

Parts 21, 45.23, 45.29:

The UAS does not have an area large enough to display 2 inch letters on a flat surface. We will 

place, as large as possible, Onuku Industries on the top of the aircraft body.

Parts 61.23, 61.101(e) (1) (iv), (4), (5), and (6), 61.113(a):

Since the UAS will not be carrying any pilots or passengers, the same level of safety can be 

achieved through proper training and documentation of training. Additional safety measures 

are put in place through the fail safes of proper flight programing, to make sure the up most 

safety for flight crew, pedestrians, and general people is protected with every flight.

Part 91.7:

UAS currently do not fall into any airworthiness categories, before each flight the PIC and VO 

will go through the complete pre-flight check list provided to make sure the UAS is in good 

flying condition.

Part 91.9:

Since there is no cockpit, the PIC and VO will have in their possession (while flying any type of 

operation) both the operation manual for the flight and the flight manual for the aircraft in use.
Part 91.103:

We will follow our pre-flight check completely, since a FAA approved manual for UAS does not 

currently exist.

Part 91.109:

Since a UAS is controlled with a transmitter and receiver, dual controls are not possible. We will 

have a computer communicating with the UAS that can force the UAS to land if deemed 

necessary.

Part 91.119:

If exemption is not granted from this rule it would cause us to fly higher than 400 feet above 

ground level. Since we do not plan to conduct flights above this altitude, this part of 14 C.F.R 

would hinder our flights. If flying near large groups of people we will implement a decent 

control device in case of a power failure to ensure one is hurt by the UAS falling out of the sky. 

Part 91.121:

Without a traditional altimeter onboard, the UAS uses a GPS system to track its movements in 

real time in order the operator to know all the aspects of the UAS operation at any given time.

Part 91.151:

Since the UAS uses a battery and not traditional fuel, the battery will be monitored at all times. 

Fail safes will be put in place to make sure that the UAS does not crash due to insufficient 

battery voltage.

Part 91.203:

All exemption letters and certificates will be held on the ground by the PIC or VO, since the UAS 

does not have a place to store that information.

Parts 91.405, 91.407, 91.409, 91.417:

Since there are no available airworthiness inspections currently available for UAS, we will 

complete our pre-flight checklist. If anything is found to be wrong the operation will be 

canceled until proper maintenance can be performed on the UAS. Any maintenance that is 

performed, whether it be preventive or after a failed pre-flight checklist, will be documented 

and kept for at least 7 years.
We are prepared to amend or modify any part of this petition for exemption to exceed any 

safety concerns. We look forward to a future of working with the FAA to provide safe UAS

vehicles to advance this technology for commercial Applications.

Sincerely,

Jason M. King, VP of Operations

Onuku Industries, LLC.