VOLO WORKS, Inc.

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VOLO WORKS, INC.

December 2, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Volo Works, Inc. for an Exemption Pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 

11, Volo Works, Inc. (“VWI”) hereby petitions the Federal Aviation Administration (“FAA”) for exemption 

from the Federal Aviation Regulations (“FARS”) identified below, to allow commercial operation of small 

unmanned aerial vehicles (i.e. “small unmanned aircraft” or “UAS”) for conducting aerial photography 

for purposes of documentation, inspection and surveys of construction projects, commercial and private 

real estate documentation for purposes of advertising promotion, recreational facility documentation for 

purposes of advertising promotion. Because this petition is similar in all material respects to previously 

granted Section 333 petitions, VWI requests expedited approval pursuant to the FAA’s summary grant 

process.

This petition is made based on information outlined in the Petition for Exemption, as well as the VWI 

UAS Flight Description of Operations, DJI S1000 User Manual v1.1, DJI S900 User Manual v1.2 and 

the DJI Inspire Pro 1.0 User Manual.
VOLO WORKS, Inc.

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TABLE OF CONTENTS

1. Glossary of Abbreviations

2. Description of Petitioner

3. Request for Summary Grant

4. Description of Operations

A. Aerial documentation of Commercial Worksite Construction

B. Aerial documentation of Commercial Building Material Conditions

C. Aerial documentation of Residential Home sites

D. Aerial documentation of Recreational sites and facilities for the purposes of advertising and 

promotion 

5. The UAS

6. Relevant Statutory Authority

7. VWI’s Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS’s Size, Weight, Speed and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations 

Manual

8. Regulations From Which Exemption is Requested

a. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.20

b. 14 C.F R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

c. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

d. 14 C.F.R. §91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 

§91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

e. 14 C.F.R. §§91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

f. 14 C.F.R. §91.103: Preflight Action

g. 14 C.F.R. §91.119: Minimum Safe Altitudes

h. 14 C.F.R. §91.121: Altimeter Settings

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

j. 14 C.F.R. §91.405(a), 91.407(a)(1) and (2), 91.417(a) and (b): Maintenance Inspections

k. 14 C.F.R. Part 61, 14 C.F.R. §61.3, 14 C.F.R. §61.113: Private Pilot Privileges and 

Limitations

9. Privacy

10. Public Interest

11. Conclusion 
VOLO WORKS, Inc.

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SECTION 1: GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

POV Point of view

RTH Return to Home

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing

VWI Volo Works, Inc.
VOLO WORKS, Inc.

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SECTION 2: DESCRIPTION OF PETITIONER

Established in 2014, Volo Works (VWI) is a leading provider of photography services throughout the 

Southeast region of the United States. Primarily headquartered in Atlanta, GA, VWI works 

extensively with the heavy construction industry providing phase documentation of large-scale 

construction projects operating under the supervision of both large commercial operators as well as 

state authorities. VWI presents a cost effective, comprehensive, utilitarian solution to construction 

site management through an integrated presentation of ground-based and aerial-based 

photography. Additionally, VWI works closely with clients in the commercial and residential real 

estate services as well as with the owners/providers of recreational facilities in providing unique 

promotional opportunities for their respective markets. VWI seeks to utilize and leverage the latest 

UAS technology to enhance and expand our client’s ability to affect the marketplace to their 

advantage through previously unavailable, low-cost alternatives to aerial photography and to make 

this service available at affordable costs to them; all while increasing the level of safety to the 

general public

As described herein, the VWI PIC is a certified and current, ATP Commercial Instrument Fixed and 

Rotorcraft rated Pilot with a Class 1 medical. The PIC has over 25 years of aviation experience with 

over 13,000 flight hours. The VWI PIC has extensive experience within the Continental U.S. 

airspace as well as internationally. The VWI PIC is experienced and familiar with the standard 

operating procedures and practices, as well as safety attitudes and safety requirements within the 

aviation industry. Additionally, the VWI PIC is familiar with the C.F.R. and FAR, all classes of 

Airspace, Agreements and Standard Operating Practices within the state of Georgia and throughout 

the continental U.S.

Furthermore, the petitioner warrants to conduct operations over private or public lands in the herein 

listed uses with the safety for the general public as the greatest priority. In addition, the safe 

integration of the UAS into the national airspace without interference or hazard to manned aircraft is 

of utmost importance. The proposed services are offered with the intent of enhancing the 

development and safe operation of unmanned aircraft systems, realizing that current manned 

aircraft operations pose a much greater risk of personal injury and/or death and extensive property 

damage.

The contact information for Petitioner is as follows:

Al Eckford

CEO

Volo Works, Inc.

1880 W Oak Parkway

Marietta, GA 30062

Phone: (770) 337-2266

Email: aleckford@me.com
VOLO WORKS, Inc.

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SECTION 3: REQUEST FOR SUMMARY GRANT

Because this petition is similar in material respects to previous petitions the FAA has granted, VWI 

requests that the FAA issue a summary grant of exemption pursuant to the agency’s expedited 

summary grant process. Specifically, the public interest and safety benefits VWI’s operations will 

achieve are materially similar to those recognized in Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 

11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382) and 11213 to Aeryon Labs, Inc. (see

Docket No. FAA-2014-0642). VWI will adhere to a series of operating parameters that will offer the 

same level of safety as the conditions the FAA currently requires in its summary grants.

SECTION 4: DESCRIPTION OF OPERATIONS

VWI is seeking exemption pursuant to Section 333 of the Reform Act to use small UASs weighing 

50 lbs. or less for conducting aerial photography for the purposes of construction documentation 

and providing promotional material for the exclusive use of our clients. VWI will adhere to the 

following operating parameters when operating UAS pursuant to a grant of the requested 

exemption:

1. All UAS operations will occur under controlled conditions. The UAS operations will be 

conducted in accordance with the conditions and limitations of this Petition for Exemption 

and VWI’s Flight Operation Manual. 

2. UAS operations will be limited to daytime VFR conditions in uncontrolled airspace.

3. UAS operations will occur at least 5 miles away from an airport as detailed in the 

Manufacturer’s Manuals unless granted specific authorization through letter of agreement 

from local FAA authorities through local petition to conduct operations in their airspace at 

times designated by them.

4. VWI’s Flight Operation Manual incorporates safe guards to assure that the aircraft does not 

travel outside the AOI, including, but not limited to, GPS “geo-fencing” technologies and 

RTH functions in case of signal loss.

5. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour), at an 

altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute 

miles, less than 500 feet below or 2,000 feet horizontally from a cloud.

6. All operations will be conducted in accordance with a Certificate of Waiver or Authorization 

(“COA”).

7. All operations will use a pilot-in-command (“PIC”) and a visual observer (“VO”), and the UAS 

will remain within the visual line of sight of the PIC or the VO at all times. The PIC will 

maintain VLOS capability and the ability to communicate verbally with the VO at all times.

8. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot 

certificate, as well as an FAA airman medical certificate or a valid U.S. driver’s license. The 

PIC will meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate.
VOLO WORKS, Inc.

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9. VWI will ensure prior to operation that the PIC has demonstrated the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be 

logged in a manner consistent with 14 C.F.R. § 61.51(b).

10. VWI’s operating documents will be accessible during UAS operations and made available to 

the Administrator upon request.

11. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the UAS will not be operated until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight.

12. VWI will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements, as well as safety bulletins, for the aircraft and aircraft 

components.

13. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and will 

yield to all manned aviation activities.

14. VWI will register and mark its UAS in accordance with 14 C.F.R. parts 45 and 47.

Sub-Section A: Aerial Documentation of Worksite Construction

VWI provides hundreds of sorties a year in support of multi-site located heavy construction projects 

across the state of Georgia and the Southeast. The majority of these require standardized, repetitive 

photographs to satisfy contractual obligations for the purposes of documenting construction progress 

and adherence to bid specifications. Traditionally, aerial photography services would need to be 

employed to provide these services, at a significant cost in both manpower and material. VWI 

provides a cost-effective means of fulfilling these required contractual obligations while significantly 

improving upon previous industry standards for safety, practicality and environmental practices. To 

wit:

● VWI vastly improves the quality, detail and resolution of the worksite photographs by 

employing a 30 mega-pixel hi-res, fully articulated, gimbal-controlled commercial-grade camera 

at altitudes typically between 100 and 250 ft. AGL (uncontrolled airspace), at multiple points and 

angles to the construction site and at resolutions that allow clients to better manage and control 

job progress. This stands as a stark contrast to photos taken through typical aerial services 

which are taken from a minimum altitude of 1500 ft. AGL, in controlled airspace (which requires 

the coordination of ATC facilities), with lower resolution, wide-angle lenses, and which is 

typically a single POV with no client input to modify.

● While operating a UAS, there is a significant decrease in risk to the general public when 

compared to standard aerial services. VWI has adopted all industry best-practices standards 

and incorporated them into our operations manual and company procedures. These include but 

are not limited to; utilizing multi-rotor UAS that have “fly-home” capabilities; utilizing to the fullest 

extent possible, inherent UAS technologies (GEO-fencing, RTH, etc.) to protect and honor 

airspace requirements in the event of signal loss; employing UAS “team” or “cockpit” concepts 

(plan, brief, fly, debrief, etc.) that make full use of every crew’s experience and practical 

knowledge while bringing multiple sets of “eyes” on every sortie. This, compared to the 
VOLO WORKS, Inc.

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employment of an actual aircraft (helicopter, light civilian, etc.) and aircrew, significantly lessons 

the impact on the general public should abnormal operations occur.

● There is a quantitative improvement that UAS operations hold over standard aerial services 

that significantly lessons the carbon footprint of these type operations and the environmental 

impact that can have. VWI utilizes a “zero-emission” UAS in all aerial operations which stands in 

stark contrast to the much larger carbon footprint of any helicopter or light civilian aircraft. Even 

taking into account the carbon emissions of ground vehicles used to pre-position the UAS, VWI 

provides a significant upgrade to the environment and an “eco-friendly” operation.

Subsection B: Aerial documentation of Commercial Building Material Conditions

VWI provides supporting documentation for commercial realtors and investors by providing an 

enhanced ability to inspect and photograph the external material condition of commercial properties. 

By employing a UAS to conduct inspections the client is now able to reach, observe and ascertain 

portions or sections of large commercial structures previously hidden from view or inaccessible by 

ground-based means. (I.e. through the use of ladders, lifts, stairways, vents, etc.) Through the use 

of multiple angle shots and POV’s, directly controllable by the client, potential trouble spots can be 

identified and pinpointed and the appropriate preventive or precautionary measures taken to mitigate 

the effects a deficient section of structure could pose. Where available, this is now proving to be the 

desired method that most realtors/contractors/investors are employing to satisfy the due diligence 

required for the sale of a commercial property.

Additionally, VWI provides video documentation for our clients that help our clients to develop a 

dynamic, moving presentation that displays their properties in a most favorable light. This 

promotional footage has shown to significantly upgrade the value our clients place on their rental 

space by setting apart their properties in a crowded marketplace.

Subsection C: Aerial documentation of Residential Home Sites

VWI provides video and still photography documentation for our clients that help them to develop to 

the fullest potential, their promotional opportunities for listed properties. This dynamic footage has 

shown to significantly upgrade the value of listed properties when compared to traditional listings.

Subsection D: Aerial documentation of Recreational sites and facilities for the purposes of 

advertising and promotion

VWI provides video and still photography promotional footage for our clients that help them to 

develop to the fullest potential, their promotional and marketing opportunities for recreational 

facilities (I.e. golf courses, water parks, theme parks, etc.) This dynamic footage has shown to 

significantly upgrade the marketing opportunities of these type properties, especially when 

compared to traditional advertisements.

SECTION 5: THE UAS

VWI requests an exemption to operate the following UAS’s. VWI will utilize the following UAS’s for 

conducting aerial photography/video, inspection or documentation sorties:
VOLO WORKS, Inc.

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● DJI S1000- The DJI S1000 is comprised with a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) and a transportable Ground Control Station (GCS). The S1000 has a max gross 

takeoff weight of 11kg (24 lbs. 4 0z.), an average endurance of 18 minutes, and a spread rotor 

width of 1109 mm (3’ 7.6”). The S1000 is equipped with 8 rotors, each driven by a Lithium 

Polymer battery powered 500W electric motor. The S1000 has a “fly-home” capability in the 

event there are multiple motor failures (depends on motor locations). The S1000 operates by 

using the A2 Operating System. 

● DJI S900- The DJI S900 is comprised of a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) and a transportable Ground Control Station (GCS). The S900 has a max gross 

takeoff weight of 8.2kg (18 lbs.), an average endurance of 18 minutes, and a spread rotor width 

of 988 mm (3’ 2.8”). The S900 is equipped with 6 rotors, each driven by a Lithium Polymer 

battery powered 500W electric motor. The S900 has a “fly-home” capability in the event there’s 

a single motor failure. The S900 operates by using the A2 Operating System.

●DJI Inspire 1- The DJI Inspire 1 is comprised of a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The Inspire 1 has a 

max gross takeoff weight of 2.935kg (6 lbs. 7.5oz.), a max speed of 22 m/s (49.2 mph), an 

average endurance of 18 minutes, and a spread rotor width of 451 mm (1’ 5.8”). The Inspire 1 is 

equipped with 4 rotors, each driven by a Lithium Polymer battery powered DJI 35210 electric 

motor. 

SECTION 6: RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems 

into the national airspace system”. Pursuant to Section 333 of the Reform Act, the FAA Administrator is 

to permit unmanned aircraft systems to operate in the National Air Space (NAS) where it is safe to do 

so based on the following considerations:

● The UAS size, weight, speed and operation capability

● Operation of the UAS in close proximity to airports and populated areas

● Operation of the UAS within the visual line of sight of the operator

In addition, the FAA administrator has general authority to grant exemptions from the agency’s safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. §44701(f) (permitting exemptions from §§44701(a), (b) and §§44702-

44716, et seq.). A party requesting an exemption must explain the reasons why the exemption, (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 exemption).
VOLO WORKS, Inc.

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SECTION 7: PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS 

OF SECTION 333

The small UAS operations proposed by VWI in this petition for Exemption qualify for expedited approval 

pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are 

satisfied.

• Approval is Warranted Based on the UAS’s Size, Weight, Speed, and Operational Capability

VWI will employ the DJI S1000, S900 and Inspire Pro for the operations specified in this Petition for 

Exemption. These are the same UAS models approved for use in the FAA’s Grant of Exemption in 

other cases. This UAS has a maximum take-off weight of 24, 18, and 7 lbs. respectively. Flight speed 

will not exceed 50 mph, and they will not be flown in controlled airspace or at an altitude that exceeds 

400ft. AGL without prior written authorization and approval from the FAA. As new drone technology 

evolves, VWI will adhere to using FAA approved UAS models. All flights/sorties will be flown in such a 

way that they can be safely terminated once the operator receives the first low battery warning 

(approximately 30% of the battery’s maximum charge). All DJI UAS’s do not carry any flammable 

propellant or fuel. All three have an integrated GPS system that calculates the UAS’s position and 

height and relays that information via a secure connection to the operator. Additionally, as 

acknowledged by the FAA in its prior grant of exemption to Douglas Trudeau, the DJI product line “Has 

the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an 

auto-pilot system to maintain the UAS stability and control. The UAS is also able to respond to a loss 

of GPS or a lost-link event with pre-coordinated automated flight maneuvers.”

• Approval is Warranted Based on the Operational Restrictions Set Forth in the Flight Operation’s 

Manual

The VWI Operations Manual and the Manufacturer’s Manuals for the selected UAS will contain all the 

procedures and limitations necessary to safely and successfully perform the operations specified in this 

Petition for Exemption. To assist the FAA in making a safety assessment of VWI’s proposed 

operations, below is a summary of operational limitations and conditions that will ensure an equivalent 

or higher level of safety to operations conducted under current regulatory guidelines:

1. The DJI UAS employed by VWI all weigh less than 50 lbs., fully loaded.

2. The radio frequencies used for operations and control of the UAS (2.4 GHz) will comply with 

the Federal Communications Commission (FCC) or other appropriate government oversight 

agency requirements.

3. Minimum crew for each operations flight/sortie will consist of a pilot, who will be Pilot-inCommand (PIC) of the UAS employed, and one or more Visual Observers (VO) as 

necessary to safely conduct the mission.

4. The UAS shall be operated within Visual Line of Sight (VLOS) of the PIC and VO at all times. 

The PIC will use human vision unaided by any device other than corrective lenses. The VO 

may use additional UAS imagery to augment and further refine safe corridors of flight on an 

as needed basis.

5. The UAS shall be operated during daylight only. Operations shall occur during daytime VFR 

Meteorological conditions; flights under special visual flight rules (SVFR) shall not be 

conducted. UAS operations under Instrument Flight Rules (IFR), at night, or beyond VLOS 

are prohibited.
VOLO WORKS, Inc.

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6. The VO designated for any operation shall be in constant voice contact with the PIC.

7. The additional requirements identified in the exemption grant shall be added to VWI’s Flight 

Operations Manual (FOM). The FOM will be maintained and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations 

in the granted exemptions and the VWI FMO, the conditions and limitations in the granted 

exemptions will be incorporated into the FOM.

8. The UAS will be operated and maintained according to the Manufacturer’s Manuals and any 

required manufacturer Safety/Service Bulletins.

9. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

10. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for 

flight. The PIC shall not operate the UAS if the inspection reveals a condition that affects 

the safe operation of the UAS until the necessary maintenance has been performed and the 

UAS is found to be a condition that is safe for flight. All maintenance and alterations must 

be properly documented in the UAS records.

11. Any UAS that has undergone maintenance or alterations that affected the UAS operation or 

flight characteristics must undergo a functional test flight (FCF) in accordance with VWI’s 

FOM. The PIC who conducts the FCF must make an entry in the UAS aircraft records of the 

flight.

12. Prior to operation, there will be a Flight Plan setting forth the operational limitations and 

conditions for the flight operations, as well as key personnel contact information and a 

description of any potential hazards on or in the vicinity of the survey site.

13. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing 

point and land the UAV once the low battery warning is received (approximately 30% of the 

battery’s maximum charge).

14. The UAV shall remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultra light vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

15. The UAV shall not be operated by the PIC from any moving vehicle or device.

16. Flights will be operated at an altitude of no more than 400 ft. AGL and will never enter 

navigable controlled airspace without prior written permission from the FAA authorities.

17. Flights will be operated at a lateral distance of at least 100 feet from any non-participating 

persons, unless that person is in a position where he/she is shielded from the UAS and any 

possible debris resulting from UAS failure.

18. At no time will the UAS be operated so close to persons or objects to present an undue 

hazard to the PIC or VO, pursuant to §91.119(a).

19. UAS operations will occur at least 200 feet away from non-participating vehicles or 

structures unless the property owner/controller has granted permission, and the PIC has 

made a safety assessment of the risk of operating closer to those objects. At no time will 

the UAS be operated so close to structures or vehicles as to present an undue hazard to the 

PIC or VO, per §91.119(a).

20. Flights will be limited to a speed of 30 knots and vertical ascent/descent rates will be limited 

to 15 fps.
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21. If the UAS loses communication with the PIC, the UAS has the capability to return to a predetermined location within the operational area and land safely.

22. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and VO.

23. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or 

emergencies. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with VWI’s FOM.

SECTION 8: REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including UAS’s, from its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest.

VWI seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations (“14 C.F.R.”) parts 21, 45, 61 and 91 for purposes of conducting the requested operations 

using a UAS. Listed below are the specific sections of 14 C.F.R. for which exemption is sought.

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.20

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the UAS selected provides an equivalent level of safety when compared 

to aircraft normally used for the same application. These criteria are met, and therefore, no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-

0352 at 13-14, 22. If however, the FAA determines that there are characteristics of the 

chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification 

of normal category rotorcraft. To the extent that VWI’s small UAS’s would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27’s airworthiness 

standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 

21, Subpart H, supra.

C. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

VWI seeks an exemption from 14 C.F.R. §91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required for 14 

C.F.R. §91.7(a) to the extent that the requirements of Part 21 are waived or found 

inapplicable. See Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, Petitioner 

requests that the requirements for §91.7(a) be treated in accordance with Section V(A), 

supra.

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

VWI seeks exemption from 14 C.F.R. §91.9(b)(2). Given the small size and configuration of 

the UAS, it would be impossible to keep airworthiness documents and other aircraft manuals 

on because of size restrictions.
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E. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

VWI seeks exemption from the aircraft marking and identification requirements contained in 

14 C.F.R. §§91.9(c), 45.23(b) and 45.27(a).

14 C.F.R. §91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides 

that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter.

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.

14 C.F.R. §45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that 

rotorcraft horizontally on both surfaces of the cabin, fuselage, boom or tail the marks 

required by §45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft “have identification (N-Number) 

markings in accordance with 14 C.F.R. Part 45, Subpart C if the markings are as large as 

practicable.” FAA Docket No. FAA-2014-0352.

F. 14 C.F.R. §91.103: Preflight Action

VWI seeks an exemption from 14 C.F.R. §91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA 

approved Flight Manual onboard the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent 

that an FAA approved Flight Manual is required.

G. 14 C.F.R. §91.119: Minimum Safe Altitudes

VWI seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. §91.119 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure 

in non-congested areas. See 14 C.F.R. §91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated “without 

hazard to persons or property on the surface,” provided that “each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA.”

An exemption is required because the proposed UAS operations will occur below 400 ft. 

AGL. Additionally, due to the nature of the proposed operations, the Pilot and/or 

Observer(s) may need to be less than 500 feet away from the UAS.

H. 14 C.F.R. §91.121: Altimeter Settings

VWI seeks an exemption from 14 C.F.R. §91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to 
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the elevation of the departure airport or barometric pressure. An exemption is required to 

the extent that UASs do not have a barometric altimeter, but rather GPS altitude display.

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

VWI seeks an exemption from 14 C.F.R. §91.151(a)’s fuel requirement for flight in VFR 

conditions. The technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30-minute battery reserve. An 

exemption from the fuel requirements of 14 C.F.R. §91.151(a) is therefore required.

J. 14 C.F.R. §91.405(a), 91.407(a)(1) and (2), 91.417(a) and (b): Maintenance Inspections

VWI seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. §91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b). These regulations 

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 

14 C.F.R. §91.405(a) (stating that each owner or operator of an aircraft “shall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections...have discrepancies repaired as prescribed in part 43 of this chapter”). An 

exemption from these regulations is needed because Part 43 and these sections only apply 

to aircraft with an airworthiness certificate, which the UAS to be operated under this grant of 

exemption will not have.

K. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and 

Limitations

61.113: subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with 

any business or employment if –

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

VWI seeks exemption from 14 C.F.R. §61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second-class medical 

certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if 

the private pilot is carrying passengers or cargo for hire. In this case, while the UAS’s will be 

operated as part of a commercial operation, it carries neither passengers nor cargo, beyond 

an integrated camera. In the Grant of Exemption to Astraeus Aerial17, the FAA determined 

the unique characteristics of UAS operation of controlled airspace did not warrant the 

additional cost and restrictions attendant with requiring a PIC to have a Commercial Pilot 

Certificate and Class II Medical Certificate. The fulfillment of the additional requirements for 

a private pilot to become qualified as a commercial pilot would not lead to any additional 

safety benefits when UAS operations are involved. Furthermore, while helpful, a pilot 

license will not ensure remote piloting skills. The risks associated with the operation of small 

UAS is far less than the risks associated with the commercial activities outlined in 14 C.F.R. 

§61.113(a) and (b).
VOLO WORKS, Inc.

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SECTION 9: PRIVACY

All VWI UAS operations will be conducted in accordance with applicable federal, state or local laws 

regarding privacy. All operations shall be conducted over private or controlled-access property with 

permission from the land/building owner/controller or authorized representative. Permission from 

land/building owner/controller or authorized representative will be obtained for each flight to be 

conducted. Notification of inspection activities (including UAS operations) will be delivered via 

land/building owner/controller or authorized representative a minimum of 24 hours prior to UAS 

operations.

SECTION 10: PUBLIC INTEREST

The public interest will be served by granting VWI’s Petition for Exemption. Congress has established 

a national policy that favors early integration of the UAS into the NAS in controlled, safe working 

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfills 

Congress’ goal in passing 333(a) through (c) of the Reform Act- the FAA Administrator’s assessment of 

whether certain UAS may operate safely in the NAS before completions of the statutorily required 

rulemaking. The proposed UAS may operations in this Petition for Exemption significantly improve 

safety and reduce risk by alleviating the public’s exposure to danger associated with traditional aerial 

survey and inspection methods, namely full size fixed-wing aircraft and rotorcraft as well as the use of 

inherently dangerous equipment use such as scaffolding and aerial work platforms. The UAS’s that 

VWI intends to use are battery powered and create no emissions. Moreover, in the unlikely event that 

one of the Petitioner’s UAS’s crash, there is no fuel to ignite and explode. Any accident involving 

Petitioner’s lightweight UAS’s will present significantly less danger to the pilot and other individuals on 

the ground than one involving a full size aircraft. Furthermore, VWI’s UAS’s will be capable of 

documenting conditions and providing aerial services previously unavailable to the public.

SECTION 11: SUMMARY AND CONCLUSION

VWI seeks exemption from the following rules in Title 14 of the Code of Federal Regulations: 14 C.F.R. 

21, subpart H; 14 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. 

§9(b)(2); 14 C.F.R. §91.109; 14 C.F.R. §91.119; 14 C.F.R. §91.121; 14 C.F.R. §91.151(a); 14 C.F.R. 

§§91.203(a) and (b); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §91.409(a)(1); 14 C.F.R. 

§91.409(a)(2); 14 C.F.R. §§91.417(a) and (b) to commercially operate lightweight unmanned UAS 

during aerial surveys, evaluations and photography.

Granting VWI’s request for exemption will reduce current risk levels and thereby enhance safety. VWI 

will be able to accomplish this all while better servicing the needs of clients and enhancing the 

efficiency of their operations. The use of UAS-assisted photography will provide a practical means of 

documentation for construction site management, assist commercial realtors in assessing and 

promoting their properties and provide unparalleled dynamic promotional footage for advertising 

purposes. As demonstrated above, the UAS operations VWI has proposed in the petition for exemption 
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will garner significant public benefits while presenting minimal safety risks. VWI’s petition satisfies the 

criteria of Section 333 of the FMRA and is substantially similar to previous petitions the FAA has 

granted, meriting a summary grant of exemption. 

VWI respectfully requests that the FAA grant its exemption request without delay. The FAA has the 

authority to issue the exemption sought by VWI pursuant to the Federal Aviation Act, 85 P.L. 726 

(1958), as amended (the “Act”).

Respectfully submitted,

Al Eckford

Volo Works, Inc.