VOLO WORKS, Inc.

1 

## VOLO WORKS, INC.

Dec ember 2 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Peti tion 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 Moderni zation and Reform Act of 2012 ( FMRA ) and 14 C.F.R. Part 11, Volo Works, Inc. ( “ VWI ” ) hereby petitio ns the Federal Aviation Administration (“FAA”) for exemption
from the Fede ral Aviation Regulations ( “ FARS ” ) identified below, to allow commercial operation of small unmanned aerial vehicles (i.e. “ small unmanned aircraft ” or “ UAS ” ) for conducting aerial ph otography for purposes of documentation, inspe ction and surveys of construction projects , commercial and private real estate documentation for purposes of advertising promotion, recreational facility documentation for purposes of advertising promotion. Be cause 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 Exempt i on, 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.

2 

## 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 Stand ards: 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 Condit ions 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. ConclusionVOLO WORKS, Inc.

3 

## SECTION 1: GLOSSARY OF ABBREVIATIONS

A GL 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.

4 

## SECTION 2: DESCRIPTION OF PETITIONER

E stablished in 2014, Volo Works (VWI) is a leading provider of photography services throughout the
Southeas t region of the United States. Primarily headquartered in Atlanta, GA, VWI works extensively with the heavy construction industry providi ng phase documentation of large

- scale construction projects operat ing 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

- base d photography. Addi tional ly , 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. V WI 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 availabl e 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 2 5 years of aviation experience with

ov er 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 indust ry. 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 througho ut
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
airc raft 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
Ma rietta, GA 30062 Phone: (770) 337

- 2266 Email: aleckford@me.comVOLO WORKS, Inc.

5 

## 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 s ummary 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 Astraeu s 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.



## SE CTION 4 : DESCRIPTION OF OPERATIONS

VWI is seeking exemption pursuant to Section 333 of the Reform A ct 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 t o the following operating parameters when operating UAS pursuant to a grant of the requested exemption:

1. All UAS operations will occur under con trolled conditions. The UAS operations will be
conducted in accordance with the conditions and limitations of thi s Petition for Exemption
and VWI ’s Flight Operation Manual.
2. UAS operations will be limited to daytime VFR cond itions 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 air craft 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 operation s 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.

6 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 t his 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 inspec tion 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 maintenan ce, 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 avia tion 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. Traditi onally, 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 impro ving 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. Th is 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 inc orporated 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 “ey es” on every sortie. This, compared to theVOLO WORKS, Inc.

7 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 contras t 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” o peration.

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 o f 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 t he 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 take n 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 p roperty.

Additionally, VWI provides video documentation for our cl ients 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 th e 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 document ation for our clients that help them t o 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 R ecreational 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 oppo rtunities fo r recreational facilities (I.e. golf courses, water parks, theme parks, etc.) This dynamic footage has shown to signi ficantly 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.

8 ● DJI S1000

- The DJI S1000 is comprised with a vertical takeoff and landin g (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The S1000 has a max g ross takeoff weight of 11 kg (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 powe red 500W electric motor. The S1000 has a “fly

- home” capability in the
event there are multiple motor failure s (depends on motor location s )

. 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 8.2 kg (18 lbs.), an average endurance of 18 minutes, and a spr ead rotor wid th 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 ST ATUTORY 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 a irports and populated areas

● Operation of the UAS within the visua l line of sight of the operator

In addition, the FAA administrator has general authority to grant exemptions from the agency’s safet y regulations and minimum standards when the Administrator decides a requested exemption is in the

p ublic 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 explai n 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.

9 

## 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 f actors 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 ap proved 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 authorizat ion and approval from the FAA. As new drone technology evolves, VWI will adhere to using FAA approve d UAS models. All flights/ sorties will be flown in such a way that they can be safely terminated once the operat or 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 t hat information via a secure connection to the operator. Additionally, as acknowledged by the FAA in its prior grant of exemption to Do uglas Trudeau, the DJI product line “Has the capability to operate safely after experiencing certain in

- flight contingen cies 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 Operationa l 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

- in

Command (PIC) of the UAS employed, and one or more Visual Observers (VO) as necessary to safely conduct the m ission.
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 saf e 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 unde r Instrument Flight Rules (IFR), at night, or beyond VLOS are prohibited.VOLO WORKS, Inc.

10 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 Oper ations 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 t hat 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 w ell 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 weathe r conditions) there is enough power to f ly 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 an d 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, unles s 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 t ime 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.VOLO WORKS, Inc.

11 21. If the UAS loses com munication with the PIC, the UAS has the capability to return to a pre

determined 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 , f rom 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 Fed eral Regulations (“14 C.F.R.”) p arts 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 ha s 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 the refore, no exemption is needed. See Grant of Exemption to Astraeus Aerial, Do cket 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 exe mption 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 ex tent that VWI’s small UAS ’ s w ould 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 Aircr aft 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): Civi l Aircraft Flight Man ual 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 d ocuments and other aircraft manuals
on because of size restrictions.VOLO WORKS, Inc.

12 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
1 4 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 provisiona lly 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”, “experim ental”, 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 Altitud es 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, veh icle, 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 cruisi ng altitude or flight level by reference to an altimeter that is set toVOLO WORKS, Inc.

13 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 operati ons 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 see ks 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 ch apter”). 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 carryin g 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 certi fications 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 Certifi cate. 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 ens ure 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.

14 

## 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 fr om 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 representa tive 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
rulemakin g. 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 batte ry 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 pilo t 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 opera tions. 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 ad vertising

purposes. As demonstrated above, the UAS operations VWI has proposed in the petition for exemptionVOLO WORKS, Inc.

15 will garner significant public benefits while presenting minimal safety risks. VWI’s petition satisfies the
criteria of Section 333 of the FMRA a nd 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 VW I pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”).

Respectfully submitted

,

Al Eckford Volo Works, Inc.