Date: Aug, 9

th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE 

Washington, DC 20590

Re: Petition of LifeWrx Media, LLC. 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 ("Reform Act") and 

14 C.F.R. Part 11, LifeWrx ("LifeWrx") hereby applies for an 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 the purpose of conducting controlled flights for production 

of videos for local broadcast, construction, and mapping, as well as environmental impact analysis.

This petition for exemption is created based on information outlined in this Petition for 

Exemption, as well as but not limited to these accompanying LifeWrx documents; 

1. Flight Operations Manual;

2. Operations Manuals

(collectively referred to as “Operations Manuals")

3. User Guide and;

4. User Manual

(collectively referred to as "Manufacturer's Manual").

1

LifeWrx submits these as well as other LifeWrx’s supporting materials as confidential 

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

proprietary information that the LifeWrx has not and will not share with others. Additionally, these

documents contain operating conditions and procedures that are not generally available to the public 

and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but

not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
U.S. Department of Transportation

Aug 9th, 2015

Page 2

This Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operation

A. Videography for Local Broadcast, Construction, Mapping and Environmental Studies.

III. Relevant Statutory Authority

IV. LifeWrx’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

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

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

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

Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

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

Limitations

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

G. 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

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

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

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

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

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
U.S. Department of Transportation

Aug 9th, 2015

Page 3

I. DESCRIPTION OF PETITIONER

LifeWrx Media LLC is a professional video production company based in Pierre South Dakota serving 

the broadcast television community, state and local government agencies, NGO’s and not-for-profit 

organizations since 1998. Client work often includes producing nature and habitat broadcast quality video 

productions airing on local, state, and regional broadcast stations and cable providers. LifeWrx takes on 

assignments for aerial video and still photography of commercial and residential construction video 

development, zoning, and mapping. The company also works to service non-government organizations, 

capturing aerial video and still photography of local environmental studies of habitats, river flows and 

functions, wildlife health studies and impact analysis.

The contact information for Petitioner is as follows: 

Patrick Callahan

Lifewrx Media LLC

455 S Pierre St, Suite 1

Pierre, SD 57501

Phone: 605.494.0109

Email: patrick@lifewrx.com

II.DESCRIPTION OF PROPOSED OPERATION

LifeWrx seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI 

PHANTOM 2 Vision +, DJI PHANTOM 3, DJI INSPIRE 1, known as (LW-UAS) for the proposed 

operations discussed below. All UAS operations will occur under tightly controlled conditions on 

private property where LifeWrx has received permission to operate from the landowner, controller or 

authorized representatives. The proposed UAS operations will be conducted in accordance with the 

conditions and limitations of this Petition for Exemption and LifeWrx’s Operations Manuals. As 

detailed in LifeWrx’s Operations Manuals, all UAS operations will be limited to daytime VFR 

conditions, within visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will

occur at least five miles away from an airport. Moreover, LifeWrx’s Operations Manuals incorporate

redundant safeguards to assure that the aircraft does not travel outside the controlled area of UAS 

operations, including GPS "geo-fencing" technologies.

A. Videography for Local Broadcast, Construction, Mapping and Environmental Studies.

LifeWrx seeks to use small UASs for the purpose of conducting videography for local broadcast, 

construction development video, mapping and environmental studies. 
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Aug 9th, 2015

Page 4

LifeWrx has tailored its operations to meet the requirements established by the FAA in prior grants of

exemptions authorizing commercial use of UAS for video production for the television industry, 

including:

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Flying-Cam, LLC (Exemption No. 11080)

 Aerocine, LLC (Exemption No. 11150)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

 Dronair Solutions (Exemption No. 11671)

All LifeWrx UAS video production operations will be conducted on private property or approved 

city and county property in a controlled area, away from spectators and persons not involved in the

video production. All UAS videography will be conducted during daylight hours, VFR conditions, at 

altitudes below 400' AGL. As set forth below, LifeWrx’s operations provide a superior level of safety

and quality compared to performing the same video work using conventional fixed-wing aircraft or

helicopters. 

LifeWrx seeks to use small UASs for the purpose of conducting videography for local broadcast, 

construction development video, mapping and environmental studies. Traditional methods of trying to 

capture such important video for safe construction project development places videographers at 

construction development sites in uncalled for risk, physical harm, serious injury or death. 

Videographers at construction sites need to climb tower or otherwise perform elevated work, which

exposes them to the risk of dangerous falls, electrocution or other work related extremes. In addition,

depending on the nature of the work, proximity to equipment often involves a risk of exposure to 

hazardous chemicals or oxygen-deficient atmospheres, extreme dangers from operating equipment, 

and other mechanical hazards associated with industrial sites and construction facilities. The use of 

small UASs mitigates these hazards and is ultimately a much safer method of performing these and 

most other types of video photography for construction development video, precision mapping and 

environmental studies.

Small UAS inspection is also safer than traditional manned aircraft performing the same

function. Conventional operations using rotorcraft and fixed-wing aircraft in low level operations 

present risks associated with vehicles weighing thousands of pounds and carrying large amounts of 

fuel. It is important to note that the use of small UAS in this area will not only be safer and more cost 

effective, but the quality of collected data and information is far superior. 

Small UAS inspection is more reliable, and allows for the collection, dissemination, and 

storage of visual and other sensory data with greater precision and duration. Small UASs are also 

capable of accessing and inspecting areas that would otherwise be inaccessible to humans or cannot be

completed with conventional aircraft.
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Aug 9th, 2015

Page 5

III. RELEVANT STATUTORY AUTHORITY

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

Modernization and Reform Act of 2012 ("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's size, weight, speed and operational capability;

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

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

Additionally, 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. § 106(f) (defining the authority of the 

Administrator); 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).

IV. LifeWrx’s PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION

333 OF THE REFORM ACT

The small UAS operations proposed by LifeWrx 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.

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

A Grant of Exemption is appropriate for operations conducted using the LW-UASUASs due to its size

weight, speed, and operational capability.

 The LW-UAS have been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

 The LW-UAS weighing less than 55 pounds, including payload.
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 The LW-UAS will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall safety and 

predictability of the system. If connection to the remote control or ground control station is lost, 

failsafe systems will permit the UAS to return to a predetermined location and safely land without

injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the LW-UAS is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely

exceed 6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The

difference in weight between the LW-UAS and a helicopter significantly reduces the potential harm to 

the participating and non- participating individuals or property in the event of an accident or incident. 

In addition, the risk to the onboard pilot and camera operator is eliminated.

________________________

2See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, 

Corp. (Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); Grant of 

Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total Safety

U.S., Inc. (Exemption No. 11156).
U.S. Department of Transportation

Aug 9th, 2015

Page 7

B. Approval is Warranted Based on the Operational Restrictions Set Forth in LifeWrx’s 

Operations Manuals

LifeWrx’s Operations Manuals and the Manufacturer's Manual for the selected UASs 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 LifeWrx’s 

proposed operations, below is a summary of operational limitations and conditions that LifeWrx will

adhere to, and which will ensure an equivalent or higher level of safety to operations conducted under

current regulatory guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission 

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

owner/controller or authorized representative will be obtained for each flight operation.

3. All UASs operated under the Grant of Exemption will be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance

with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely

conduct the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. 

The PIC will also 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.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued Medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic Messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the LifeWrx’s 

Operations Manuals. The Operations Manuals will be maintained and made available to the

Administrator upon request. 
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Aug 9th, 2015

Page 8

If a discrepancy exists between the conditions and limitations in the Grant of Exemption and LifeWrx’s 

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and 

must be followed. Otherwise, LifeWrx shall follow the procedures outlined in their Operations Manuals.

10. LifeWrx may update or revise its Operations Manuals. Revisions will be tracked and a revised

copy of the Manual will be provided to the Administrator upon request. LifeWrx will also present an

updated and revised Operations Manuals if it petitions for extension or amendment to its Grant of

Exemption. If an update or revision would affect the basis upon which the FAA grants the exemption, 

LifeWrx will seek an amendment to its Grant of Exemption. LifeWrx will contact the FAA’s UAS

Integration Office (AFS-80) if questions arise regarding updates or revisions to the operating

documents.

11. LifeWrx’s Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first intended point of landing, and assuming

normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the LW-UAS will be limited to 40 

minutes or the amount of time the UAS can be flown and still maintain a reserve battery power of no 

less than 25%, whichever occurs first.

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

navigable controlled airspace without prior written authorization and approval from the FAA. In the

event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 

feet above the highest point on the structure, and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. 

(persons other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and

structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons 

leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or;
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Aug 9th, 2015

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b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the LifeWrx

COA. The letter of agreement with the airport management will be made available to the Administrator 

upon request.

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

flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or

equipment, not already covered in the relevant sections of the operating documents. 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 in a condition for safe flight. 

The ground control station shall be included in the preflight inspection. All maintenance and 

alternations must be properly documented in the UAS records as required by LifeWrx’s Operations 

Manuals.

19. LifeWrx will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in the

UAS records, including total time in service, description of work accomplished, and the signature of the

authorized person returning the UAS to service.

20. Any UAS that has undergone maintenance or alterations that affect the UAS operation or

flight characteristics (e.g., replacement of a flight critical component) must undergo a functional test

flight in accordance with LifeWrx’s Operations Manuals. The PIC who conductsthe functional test

flight must make an entry in the UAS aircraft records of the flight. The requirements and proceduresfor a

functional test flight and UAS record entry shall be included in the LifeWrx’s Operations Manual.
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Aug 9th, 2015

Page 10

21. The UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements 

on LifeWrx’s Operations Manual.

23. LifeWrx will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude

level and potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

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

communication between the PIC and the Observer.

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

emergencies.

28. PICs and Observers will have at least medical certificate or a valid driver’s license. 

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a 

UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 logged 

hours as UAS pilot operating the make and model of UAS to be utilized for operations under the

exemption and thirty take-offs and thirty landing in the preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted.

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

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing

activities, hang gliders, etc.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

V. 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 UASs, from its safety regulations and minimum standards when the Administrator

decides a requested exemption is in the public interest.

3

LifeWrx 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: (1) the specific sections of 14 C.F.R for which exemption is 

sought, and (2) the operating procedures and safeguards that Petitioner has established which will

ensure a level of safety better than or equal to the rules from which exemption is sought.

4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716). 

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would

provide a level of safety at least equal to that provided by the rule from which you seek exemption.
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Page 12

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

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.

5 

If, however, the FAA determines that there are some characteristics of the chosen UAS that fail to Meet

the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

LifeWrx’s use of the LW-UAS is safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV (A), the LWUAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess 

of 50 knots. UAS is also equipped with safety features that will allow Petitioner to operate the UAS

safely after experience certain in-flight contingencies or failures.

6 7

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3):

"The LW-UAS have the capability to operate safely after experiencing certain in-flight contingencies 

or failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also able to

respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, 

predictable, automated flight maneuver, and manual flight control functionality as a backup. These

safety features provide an equivalent level of safety compared to a manned aircraft performing a

similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5):

The LW-UAS can be operated entirely by a touch-screen, map-based interface. This means the 

operator only needs to command the system where to go, and the system does all the flying for the 

operator. The can be operated in both semi and fully autonomous flight modes, with the operator

simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can 

create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas

{footnote continued}
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Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in Company's 

Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the 

operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. LifeWrx will also provide the FAA with advance notice of all

operations via NOTAMs as required by the applicable COA. In all cases, operation of the LW-UAS

under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft 

operating with an airworthiness certificate.

Lastly, the UASs do not need a Means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In addition, no 

sense-and-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.

9

 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 Company’s small UASs 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.

{continued from previous page}

The petitioner states further that the UAS has built-in intelligent fault handling which allowsthe LW-UAS 

to detect a system fault while in the air and automatically fly back to its takeoff location and land. Faults

that can be detected include: loss of communication; exceeding pre-set wind thresholds; and low battery

levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. The flight control system employs not only GPS positioning but a

variety of sensors including sonar, barometric pressure, temperature, wind speed and othersto ensure

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly

away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id.
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Page 14

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

Requirements

LifeWrx seeks an 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."

10

Equivalent Level of Safety

All UA flown by LifeWrx will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.

11

10

FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

LifeWrx seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 91.409(a)(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.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or 

Service Bulletins. Further, as required by LifeWrx’s Operations Manuals, the PIC will conduct a preflight inspection of the UAS and all associated equipment to account for all discrepancies and/or 

inoperable components. Maintenance will be performed and verified to address any conditions 

potentially affecting safe operation of the UAS and no flights will occur unless, and until, all flight 

critical components of the UAS have been found to be airworthy and in a condition safe for operation. A 

functional test flight will be conducted following the replacement of any flight-critical components. As 

required by LifeWrx’s Operations Manuals, the PIC who conducts the functional test flight will make an

entry in the UAS aircraft records of the flight.

LifeWrx’s Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (power plant), propellers, avionics and control 

surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems 

(including batteries), ground control station, hazard accessories, and spare parts. Further, LifeWrx’s 

Operations Manuals also includes procedures to document and maintain a record of the UAS

maintenance, preventative maintenance, alterations, status of replacement /overhaul component parts,

and the total time in service of the UASs used under this Grant of Exemption. As a whole, the 

maintenance and inspection procedures required in LifeWrx’s Operations Manuals ensure that an 

equivalent or higher level of safety will be achieved.
U.S. Department of Transportation

Aug 9th, 2015

Page 16

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

LifeWrx seeks exemption from 14 CFR § 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 UASs will be operated as part of a commercial

operation, it carries neither passengers nor cargo. 

In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the 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.

Equivalent Level of Safety

The restrictions LifeWrx has placed on its UAS operations Meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. LifeWrx will operate on private property away from persons and 

property not involved in the operation. LifeWrx will also obtain an ATO issued COA prior to 

conducting any operations under this Grant of Exemption. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level 

and potential transponder requirements. A NOTAM will also be issued as required by the applicable

COA.

In addition to these flight restrictions, LifeWrx will further ensure safe operation by requiring

that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all

aircraft operators but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, 

pilots will have experience not only in UAS operations generally but have logged flight time in the

specific make and model used for the operations before they are permitted to participate in commercial

flights on behalf of Lifewrx. The pilot qualification, training, and currency requirements in the 

Operations Manuals ensure that LifeWrx’s pilots are competent and proficient in the UAS they are

operating. LifeWrx’s training and qualification requirements are consistent with those contained in prior 

FAA Section 333 Grants of Exemption, and will provide a higher level of competency and proficiency

for its pilots and will ensure at least an equivalent level of safety.

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Aug 9th, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

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

Although there will be no airworthiness certificate issued for the UASs, LifeWrx 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.

13 Accordingly, Petitioner requests that 

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

G. 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

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed

at the cabin or cockpit entrance so that it is legible to passengers or crew.

13

See id. at 13-14, 22 
U.S. Department of Transportation

Aug 9th, 2015

Page 18

Given the small size and configuration of the UASs, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and the UAS 

has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a)

and (b) is Met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration 

certificate, and other required documents from the ground control station from which he or she is 

operating the aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is 

to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of 

safety will be achieved by ensuring that the pilot has access to the documents at the ground control 

station from which he or she is piloting the UAS.

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

LifeWrx 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 on board 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.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the LifeWrx’s Operations Manuals 

and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any

defects or inoperable components in accordance with the LifeWrx’s Operations Manuals, including 

checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be 

required to review weather, flight requirements, battery charge, landing and takeoff distance, UA

performance data, and contingency landing areas—before initiation of flight. LifeWrx’s Operations

Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible 

to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
U.S. Department of Transportation

Aug 9th, 2015

Page 19

LifeWrx seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, 

by their design, do not have functional dual controls. Instead, flight control is accomplished through 

the use of a device that communicates with the aircraft via radio communications. Accordingly, an 

exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that LifeWrx’s intends to use, an equivalent level of safe

training can still be performed without dual controls because no pilot or passengers are aboard the UAS, 

and as required by the LifeWrx’s Operations Manuals, all persons will be a safe distance away in the

event that the UAS experiences any difficulties during flight instruction. Moreover, as required by the

LifeWrx’s Operations Manuals, all flight training will be conducted in controlled and sterile 

environment. As a whole, the safety procedures provided for in LifeWrx’s Operations Manuals ensure

that the proposed UAS operations provide an equivalent or higher level of safety than that provided by

the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

LifeWrx requests an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119(c).

15 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 normally need to occur

below 400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height 

exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the 

structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed 

operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on

a Tree Aerial (FAA-2014-0534 at 15).
U.S. Department of Transportation

Aug 9th, 2015

Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the UASs, any risk associated with these

operations is far less than those that presently exist with conventional aircraft. An equivalent level of 

safety will be achieved given the size, weight, and speed of the UASs, as well the controlled location 

where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be 

restricted to 400 feet AGL or below, or when inspecting a structure whose height exceeds 400 feet AGL, 

within 100 feet above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless 

that person is in a position where he or she is shielded from the UAS and any possible debris resulting 

from UAS failure. As required by the Operations Manuals, flights will be terminated if a

nonparticipating person within 500 feet of the UAS leaves a shielded position. Further, UAS operations 

will occur at least 500 feet away from 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 and, operations near the PIC or Observer will not present an undue hazard per § 91.119(a). 

Adherence to these restrictions in LifeWrx’s Operations Manuals will ensure operations can be

conducted without compromising safety.

16

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

LifeWrx 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 the elevation 

of the departure airport or barometric pressure An exemption is required to the extent that the UASs do

not have a barometric altimeter, but rather a GPS altitude read out.

____________________________________________

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA

or debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded

such protection. The operator must also ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such protection and are within 500

feet of the UA, flight operations must cease immediately. When considering how to immediately cease

operations, the primary concern is the safety of those nonparticipating persons. In addition, the FAA

finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the 

owner/controller of any such vessels, vehicles orstructures grants permission for the operation and the

PIC makes a safety assessment of the risk of operating closer to those objects and determines that it 

does not present an undue hazard.”
U.S. Department of Transportation

Aug 9th, 2015

Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be

achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or below

17

, (2)

within VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a

ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS.

18

The UASs that LifeWrx intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by LifeWrx’s Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants 

of Exemption, the UASs LifeWrx intends to use, and the safety mitigation procedures contained in the

Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of 

Exemption to the requirements of § 191.121 is therefore appropriate.

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

LifeWrx requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind

and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, 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.

_____________________

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated 

more than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation

Aug 9th, 2015

Page 22

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a LW-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered 

that the UAS batteries for the LW-UAS provided provide approximately 20 minutes of powered flight 

(with payload) and provided battery level and battery time remaining in minutes and seconds to the 

PIC.19 The FAA also considered the fact that the LW-UAS operating manual states: “start every flight 

with a fully charged battery in the aerial vehicle”, and that in the event that the UAS should run low on 

power, the PIC will be alerted and can land the LW-UAS as soon as possible. Like the VDOS Grant of 

Exemption, LifeWrx use of the DJI S1000, combined with the requirements of Petitioner's Operations 

Manuals, ensure that an equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA 

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions 

could be achieved by prohibiting the PIC from beginning a flight with the LW-UAS unless 

(considering wind and forecast weather conditions), there was enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power remaining. LifeWrx will 

adhere to this limitation for LW-UAS flights. 

The LW-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS to a 

ground-based-on-screen display.20 As required by LifeWrx’s Operations Manuals, the PIC will 

promptly fly the UAS back to the home launch location or pre-determined abort location where the 

UAS may safely land, while still maintaining a minimum of 25% reserve battery power. LifeWrx

submits that the procedures requiring flights to be safely terminated once the batteries fall below 25%

capacity, combined with the requirement that flights only be conducted within a secure, isolated area, 

using a UAS weighting less than 55 pounds, and within VLOS of the PIC and Observer(s), ensure that 

the proposed operation will provide an equivalent or higher level of safety to that provided by the 

regulations from which exemption is sought. 

 ________________________

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The LW-UAS ground control station displays, the UASs position, navigation route, tail number, 

altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and 

sensor heading and orientation relative to the UAS. 
U.S. Department of Transportation

Aug 9th, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

LifeWrx will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

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

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

working proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's assessment of 

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

rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improves safety and 

reduces risks of serious injury to engineers and videographers. Traditional methods of capturing such 

important video for construction project development, places videographers in uncalled for risk, 

physical harm, serious injury or death. The use of small UASs can eliminate these hazards and is 

ultimately a much safer method of performing video photography for construction development, 

precision mapping and environmental studies.

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no 

passengers or crew. Further, in the unlikely event of an accident, LifeWrx small battery powered 

UASs presents significantly less danger to persons on the ground when compared to operations by 

conventional manned aircraft.21 As Petitioner's UASs are battery powered, the public will also benefit 

from a reduction in harmful emissions associated with conventional aircraft performing in the same

functions proposed herein. Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption 

to video photographers and filmmakers, 

__________________________

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by 

an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will 

weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located 

from the aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard 

pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming 

operation." 
U.S. Department of Transportation

Aug 9th, 2015

Page 24

UASs provide an additional tool for the aerial filming industry, adding a greater degree of flexibility, 

which supplements the current capabilities offered by manned aircraft.22

VIII. PRIVACY 

All LifeWrx’s 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 owner/controller or authorized representative. Permission from 

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

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

FEDERAL REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 

91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 

91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners 

from the substantial hazards associated with performing equivalent film work and aerial inspection and 

environmental monitoring of industrial sites, transmission and storage facilities, construction facilities 

and precision aerial surveys with conventional fixed-wing aircraft, rotorcraft, or other Methods.

X. CONCLUSION

LifeWrx’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform 

Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed UAS operations will benefit the public as a 

whole by improving safety and reducing risk by alleviating human exposure to danger. In consideration 

of the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for 

granting the requested exemptions allowing LifeWrx to use small UASs for: controlled flights for 

production of videos for local broadcast, construction, planning, zoning and mapping, as well as 

environmental impact analysis.

____________________

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Aug 9th, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted,

Patrick Callahan

Lifewrx Media LLC

455 S Pierre St, Suite 1

Pierre, SD 57501

Should you have any questions, or if you need any additional information to support the requested 

exemptions, please contact the undersigned at:

Lifewrx Media LLC

Phone: 605.494.0109

Email: patrick@lifewrx.com

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file 

pursuant to 14 C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals