August 19, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room w12-140 1200 New Jersey Ave. SE

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 

91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 (a); 91.203 (a) & (b); 

91.405 (a); 91.407 

INTRODUCTION 

Pursuant to Section 333 of the FAA Modernizations and Reform Act of 2012 and 

14 CFR Part 11, Larry Welk, operator of Small Unmanned Aircraft Systems (“sUASs”) 

equipped to conduct aerial photography for KNBC, KTLA, and various other news 

outlets for the purpose of electronic news gathering in Los Angeles, CA. Additional

operations to include closed set filming for the movie and television industry, and data 

acquisition. Larry Welk hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of sUASs under the conditions 

outlined here or modified by the FAA. Larry Welk submits supporting material in this 

application as confidential documents pursuant to 14 C.F.R. § 11.35(b), as the materials 

contain confidential commercial and proprietary information that Larry Welk has not and 

will not share with others.

In the detailed explanation to follow, the series of exemptions being requested 

would allow operation of the commercially procured, DJI S1000, an eight engine and 

blade, light weight, relatively slow (<50 knots) unmanned rotary aircraft (or like 

platform), and an Intuitive Aerial Aerigon IAH3 an twelve engine and blade, light weight 

relatively slow (<50 knots) unmanned rotary aircraft (or like platform), in and around the 

city of Los Angeles during active news, traffic and weather events using very controlled 

conditions and operational procedures to provide robust safety buffers both vertically and 

horizontally to ensure personnel and property safety. These flights would only fly within 

200 feet of the control vehicle with a dismounted pilot and safety team using an autopilot system that would control speed, vectoring and hovering. At no time would the 

vehicle fly directly over locally assembled crowds or over any ongoing fires. The launch 

and recovery point would be cordoned off by the safety team in coordination with law 

enforcement and/or first response units. Approval of this exemption would help to prove 

the safe concept of UAS activity while conducting electronic news gather (ENG) during 

active news, weather or traffic events in a major metropolitan environment with safety 

controls to provide proactive risk management that is technically within the National 
Airspace System, but realistically segregated well below any other air traffic and well 

clear of the Los Angeles International Class B airspace (beneath the lateral confines). 

To date, the FAA has granted an exemption for ENG operations to Arrow Data, LLC, 

Aerigon IAH3 airframe approval to Vision Pictures LLC, and closed set filming approval 

to Team 5 LLC.

The following is contact information for the applicant: 

Larry Welk III

12653 Osborne St. #6

Los Angeles, CA 91331

1 (818)625-1320

EXMEPTIONS (Regulations from which exemption is requested)

• 14 CFR Part 21, Subpart H-Airworthiness Certificates

• 14 CFR 45.23 (b),,

o Aircraft Marking

o Certification and Registration

• 14 CFR 61.113 (a) & (b)

o Pilot in Command

• 14 CFR 91.7 (a)

o Civil aircraft airworthiness

• 14 CFR 91.9 (b) (2)

o Document/Flight Manual

• 14 CFR 91.103 (b)

o Preflight Action

• 14 CFR 109

o Flight Instruction

• 14 CFR 91.113
o Right-of-way rules

• 14 CFR 91.119

o Minimum safe altitude

• 14 CFR 91.121

o Altimeter setting

• 14 CFR 91.131 (a) (1) (c) (2) (d) (1)

o Operations in class B airspace

• 14 CFR 91.151

o Fuel requirements for VFR flight

• 14 CFR 91.203 (a) & (b)

o Civil Aircraft: Certifications required

• 14 CFR 91.405 (a) (1); 409 (a); 417 (a) &(b)

o Maintenance and maintenance inspections

• 14 CFR 407

o Operation after Maintenance, preventative maintenance, rebuilding, 

and inspections 

• 14 CFR 409

o Inspections

• 14 CFR 417

o Maintenance records

• NOTAM 9/5151, NOTAM 4/3621

o Flying around sporting events

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFETY 

Section 333 refers to exemptions for sUASs for commercial operations. Those operations 

could include a vast array of events such as electronic news gathering (ENG). Much like 

the movie industry, aerial news and traffic/weather information gathering is both useful 

and entertaining to the general public. The quick deployment and less restrictive weather 

constraints will create a safer environment, while delivering a superior and timelier 
product to the general public, providing near real time information for traffic, severe 

weather and crime scene avoidance considerations. 

The sUAS aircraft to be employed by Larry Welk, has a number of safety features that 

make it ideal for use in this environment. The state of the art DJI S1000 with single 

22,000 mAh, 22.2 volt battery technology and the ability to fly with two engines 

inoperable. The Intuitive Aerial Aerigon with a triple 10,000 mAh or 16,000 mAh, 22.2

volt battery technology and the ability to fly with 4 engines inoperable. Both UAS are 

well under 55 pounds with a top speed of approximately 40 knots. Additionally, there is 

redundancy in the power system to the data link, motherboard, and wireless 

communications within the sUAS team operating the system. The mobile vehicle to be 

used with the UAS is already fitted with redundant power sources for satellite and camera 

operations and would be available to the UAS safety team as well. The aircraft would be 

employed utilizing Visual Line-of Sight (VLOS) operations not to exceed 200 feet 

vertically and launched from a sterile area created upon arrival at the news event by the 

safety team in coordination with local law enforcement and first responders. Any vertical 

obstructions would be noted upon arrival and the pilot and safety team would ensure 

operations remained well clear of those obstructions. The pilot would launch the aircraft 

and navigate to an acceptably safe hover point at which time a waypoint would be 

designated and the auto-pilot would be engaged in an auto-hover mode while filming 

commences. A loss of communication “return to base” fail-safe system is integrated as 

well. The battery life is approximately 30 minutes with a planned flight time of not more 

than 15 minutes. Larry Welk, will file a FAA Form 7711-1 or any such form deemed 

appropriate with the local Flight Standards District Office. Additionally, an Operations 

Plan would be submitted on a mutually agreed periodical basis to the FSDO.

All sUAS pilots being employed by Larry Welk, for this mission will have a FAA Private

Pilot Certificate and a second class FAA medical certificate with additional experience in 

unmanned aircraft operations. The team composition will consist of a minimum of one 

pilot, one camera operator and one safety observer during all mobile news events, giving 

redundancy to the human element as well. Pilots will be well trained in areas of both 

normal and abnormal operations equipped with checklists and operations and 

maintenance manuals to be able to contend with any scenario. After extensive range 

testing and pilot training, the sUAS team will perform “dry-runs” to simulate and practice 

actual news events and situations. To help prepare for actual flight and news gathering 

with a UAS, the team would deploy with the mobile news team and observe conditions 

and scenarios where future operations might take place. This would give the team a feel 

for the “cadence” of an active news event to allow them to be able to plan timing and 

coordination issues. Unlike other uses for sUASs, these flights would be mostly shorter in 

length, obviating the need for a backup pilot. The designated safety observer would help 

to provide greater situational awareness for the team in order maintain alertness and vigil 

at all times. An environmental assessment will be performed to measure such parameters 

as noise and hazardous material concerns. 

Additionally, Larry Welk proposes that the exemption requested apply to civil 

aircraft that have the characteristics and that operate with the limitations listed. These 

limitations provide for at least an equivalent or even higher level of safety to operations 
under the current regulatory structure because the proposed operations represent a safety

enhancement to the already safe aerial photography and closed set aerial filming for 

movie and television filming operations conducted with conventional aircraft.

These limitations and conditions to which Larry Welk agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

Flights will be terminated at 25% battery power reserve should that occur prior to 

the 30 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical. 

7. sUAS Pilot assume all duties and responsibilities as Pilot in Command (PIC). 

8. The sUAS will only operate within a confined “Sterile Area”. Security will be 

performed by the operator and designated security personnel.

9. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day’s production activities. It will be mandatory that all personnel who will 

be performing duties within the boundaries of the safety perimeter be present for 

this briefing. 

10. The operator will obtain the consent of all persons involved in the mission and 

ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and this radius may be reduced to 30 feet based upon an equivalent 

level of safety determination. With the advanced permission of the relevant 

FSDO, operations at closer range can be approved. 

11. When required, the operator will submit a written Plan of Activities to the 

FSDO three days before the proposed shoot.

12. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated.

13. ALL crew members will at all times be able to communicate by ONLY voice 

communications as to ensure all crew members maintain a visual contact with the 

UAS at ALL TIME.

14. Written and/or oral permission from the relevant property holders will be 

obtained. 

15. 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. 

16. If the sUAS loses communications or loses its GPS signal, the UAS will have 

capability to return to a pre-determined location within the Security Perimeter and 

land. 

17. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.
UAS Crew Requirements:

 UAS Pilot in Command must:

1. Hold at least a FAA Private Pilot with current 3rd class medical

2. Have a minimum of 200 flight cycles and 25 hours of total time as 

a sUAS rotorcraft pilot and at least 10 hours as a sUAS pilot with 

a similar sUAS type (single blade or multirotor); 

a minimum of 5 hours as sUAS pilot with the make and model of 

sUAS to be utilized for operations under the exemption and 3 take 

offs and landings in the preceding 90 days; 

3. Received training in the safe operation of the UAS to be operated. 

Training will include:

a. Normal and emergency modes of operation

b. Familiarization with the operation manual published by 

the UAS manufacturer.

c. Types of maneuvers to be performed during operations 

including safe operation in relation to persons, property 

and applicable airspace using the actual UAS or 

manufacturers simulation software

Camera Operator must:

1. Become familiar with the operation manual published by the UAS 

manufacturer. 

2. Receive training in the safe operation of the systems operated 

onboard the UAS. Training will include:

a. Proper method of loading, rigging, or attaching the camera 

mount, lighting, and any external equipment

b. Types of maneuvers to be performed during operations

c. Safe operation in relation to persons, property and 

applicable airspace. 

d. Receive training on basic VFR weather minimums 

outlined in 14 CFR 91.155

In a dual control configuration, the Camera Operator will not operate the master 

controller. 

Visual Observer must:

1. Be familiar with the use of VHF / FM radio communication.

2. Have received training on the National Airspace System 14 CFR 71 and 

the basic VFR weather minimums outlined in 14 C.F.R. 91.155. 

The Plan of Activities
The Plan of Activities must include the following:

1. Dates and times for all flights;

2. Name and phone number of the person responsible for the photography / 

filming event;

3. Name and phone number of the person responsible for the aircraft;

4. Make, model and serial number and/or registration number of all UAS t to 

be used;

5. Name and certificate number, if applicable, of all crewmembers to be 

utilized in the event including copies of FAA Medical Certificates and 

endorsements;

6. A statement that the Waiver Holder has obtained permission from property 

owners and/or local governmental officials to conduct the event;

7. Signature of Waiver Holder or representative;

8. A description of the flight activity including maps or diagrams of any area, 

city, town, county, and/or State over which filming will be conducted and 

the minimum altitudes essential to accomplish the operation.

Briefing 

Larry Welk or his appointed event representative will conduct a verbal and written 

briefing for the members involved, including emergency, if applicable, and security 

personnel. This briefing will be conducted prior to each day’s UAS activities and will 

include the following items.

 

1. Authorization UAS flight operations, Plan of Activities, special provisions and 

any additional provisions issued by the Flight Standards District Office having 

jurisdiction over the photo / filming area.

2. Radio communications. 

3. Takeoff procedures.

4. Aviation activities to be conducted during the event.

5. Approach and landing procedures.

6. Alternate landing zone in the event of emergency or security breach.

7. Recall procedures.

8. Emergency procedures.

9. Possible risk to personnel that are involved.

10. Control of non-participating persons.

11. Location of boundaries or deadlines, man-made or natural, readily visible to the 

participants.

13. Local governmental limitations, restrictions, or any special circumstances, such as 

noise sensitive areas, time of day restrictions or changes in operating procedures.

Security
The exclusion from the flight operations area of unauthorized persons, vehicles or 

aircraft will be enforced by designated event personnel, private security officers or sworn 

law enforcement officers at the direction of Larry Welk.

Larry Welk or his designated representative will halt flight operations in the event 

unauthorized persons, vehicles or aircraft enter the flight operations area. 

A predetermined abort signal will be used to halt flight operations should a breach 

of perimeter security occur, or for any other reason in the interest of safety.

Alternate UAS landing sites will be made available prior to the start of the event.

14 CFR Part 21, Subpart H– Airworthiness Certificates 14 CFR 91.203 (a) (1) 

Subpart H (Airworthiness Certificates) defines the requirements for airworthiness 

certificate issuance IAW FAR 91.203 (a) (1). Existing law (49 USC 44701 (f)), Part 11 

and Section 333 allow the FAA to exempt aircraft from the requirements of an 

airworthiness certificate upon consideration of the size, weight, speed, operational 

capability and proximity to airports and populated areas of the identified sUAS. Unlike a 

manned helicopter, the sUAS being employed is lightweight, has no flammable fuel or 

other lubricants, operates at very slow speeds and stays well below any conflicting air 

traffic thereby providing, an equivalent level of safety when compared to currently 

employed manned aircraft. 

The proposed sUAS to be employed is under 55 lbs. when outfitted with all 

equipment and batteries. There are no flammable liquids or other hazardous materials that 

would propose a danger to the public or event participants. Accordingly, no threat to 

national security exists due to the inability of carriage of any external stores or ordnance 

and the exhaustive vetting of team personnel. All activities will be closely monitored by a 

team of aviation professionals and using a system with redundancies in all areas. 

14 CFR 45.23 (b) Display of Marks; general 

CFR 45.23 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. 

An exemption to this section is needed due to the lack of a cabin, cockpit or pilot 

station where any reference to the term “Experimental” could be affixed. Accordingly, 

the wording will be placed on the fuselage. This equivalent level of safety will allow the 

team to clearly see “Experimental.” Previous precedence exists within Exemptions 

10700, 10167, and 10167A. 
CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command 

CFR 61.113 (a) & (b) states: 

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 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. 

To reach an equivalent level of safety, the self-imposed experience and training 

requirements would more than offset any risk introduced by using private pilots to fly an 

unmanned aircraft in very restricted and controlled areas. 

CFR 91.7 (a) Civil aircraft worthiness 

CFR 91.7 (a) states: 

No person may operate a civil aircraft unless it is in an airworthy condition. 

Assuming no airworthiness certificate will be required due to relief from Subpart 

H, no regulatory standard exists for determining airworthiness. The equivalent level of 

safety will be achieved through the employment of the manufacturers flight manual and 

maintenance manual procedures, pilot training and analytical risk management for each 

event. 

CFR 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft 

CFR 91.9 (b) (2) states: 

No person may operate a U.S.-registered civil aircraft—

For which an Airplane or Rotorcraft Flight Manual is not 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. 

Given the size of the sUAS being utilized in this endeavor, there is no room 

onboard for an aircraft flight manual. 
The equivalent level of safety will be achieved by keeping the flight manual with 

the pilot/team on the ground with easy access. Previous precedence is resident in 

Exemptions 8607, 8737, f8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

f32827, and 10700. 

CFR 91.103 (b) Preflight action 

CFR 91.103 (b) states: 

Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include—

(b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing distance 

data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft performance 

under expected values of airport elevation and runway slope, aircraft gross weight, and 

wind and temperature. 

This regulation dictates that a pilot conduct preflight activities. Without an FAA 

approved flight manual, relief is required from this regulation. Extensive pre-flight 

planning will provide an equivalent level of safety by using the operations plan, aircraft 

flight manual, maintenance manual and available weather and NOTAM information. 

CFR 91.109 Flight instruction 

CFR 91.109 states: 

No 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. 

sUASs clearly have no onboard flight controls. An equivalent level of safety will 

be accomplished by conducting pilot training via the control system that communicates 

with the aircraft from the ground. 

CFR 91.113 Right-of-way rules: Except water operations. 

CFR 91.113 deals with the many scenarios whereby different types of aircraft in different 

states must give way to other aircraft. 
Because the sUAS PIC does not have “see and avoid” capability, the petitioner 

requests relief from this regulation. All operations will be within VLOS of the pilot and 

well below any airspace where other flight activity is taking place. 

CFR 91.119 (d) (1) Minimum safe altitudes; general 

CFR 91.119 states: 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) 

or (c) of this section, provided each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA. 

Recognizing that this relief is unprecedented, the petitioner asks that the FAA 

recognize the inherent capability of the Larry Welk, we feel that an acceptable level of 

safety can be achieved. Extensive range testing and additional on-site testing in a benign 

environment would be conducted in real or near-real time conditions. The current altitude 

and/or horizontal restrictions on rotorcraft assumes a much heavier manned aircraft 

loaded with fuel and possible external stores. The light-weight sUAS being proposed for 

use in this activity along with its precise guidance and redundant systems create an 

entirely different paradigm that should be considered by regulatory bodies. 

The activities being proposed by this petitioner are in a very controlled and open 

area. The flights would be confined to the immediate area of the mobile control center 

(MCC). Given these considerations, Larry Welk, proposes allowing flights to operate no 

more than 300 feet from the MCC and well clear of the Class B airspace and attendant 

manned air traffic. 

CFR 91.121 Altimeter settings 

CFR 91.121 states: 

Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating—

Below 18,000 feet MSL, to—

The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

The sUAS aircraft intended for this activity will not be equipped with a 

barometric altimeter. Instead it will incorporate radio altimetry via the onboard GPS. An 
equivalent level of safety will be achieved through use of the operations and maintenance 

manuals governing altitude control. A preflight calibration of launch site altitude will be 

accomplished. 

CFR 91.131 (a) (1) (c) (2) & (d) (1) Operations in Class B airspace 

CFR 91.131 states:

(a) Operating rules. No person may operate an aircraft within a Class B airspace 

area except in 

compliance with § 91.129 and the following rules:

(1) The operator must receive an ATC clearance from the ATC facility 

having jurisdiction for that area before operating an aircraft in that area.

(c) Communications and navigation equipment requirements. Unless otherwise 

authorized by ATC, no person may operate an aircraft within a Class B airspace area 

unless that aircraft is equipped with—

(2) For all operations. An operable two-way radio capable of 

communications with ATC on appropriate frequencies for that Class B airspace area. 

(d) Other equipment requirements. No person may operate an aircraft in a Class B 

airspace area unless the aircraft is equipped with—

(1) The applicable operating transponder and automatic altitude reporting equipment 

specified in § 91.215 (a), except as provided in § 91.215 (e), and 

Much of the city of Los Angeles lies within the limits of the Class B airspace, or 

various other controlled airspace. Because the planned sUAS to be employed lacks an 

onboard transponder or two way communication capability, relief from this regulation is 

required. An equivalent level of safety will be achieved by limiting the operating ceiling 

of the sUAS to altitudes well below any conflicting manned aircraft traffic (no higher 

than 200 feet). This assures de-confliction with all other traffic and specifically traffic 

within the Class B airspace. Additionally, the sUAS will remain clear of the Los Angeles 

International Class B airspace at all times. Larry Welk, will periodically report to the 

FSDO on operations and risk management issues. 

CFR 91.145 (b) Management of aircraft operations in the vicinity of aerial 

demonstrations and major sporting events. 

CFR 91.145 states: 
In deciding whether a temporary flight restriction is necessary for an aerial 

demonstration or major sporting event not listed in paragraph (a) of this section, the FAA 

considers the following factors: 

(1) Area where the event will be held.

(2) Effect flight restrictions will have on known aircraft operations. 

(3) Any existing ATC airspace traffic management restrictions.

(4) Estimated duration of the event.

(5) Degree of public interest.

(6) Number of spectators.

(7) Provisions for spectator safety.

(8) Number and types of participating aircraft.

(9) Use of mixed high and low performance aircraft.

(10) Impact on non-participating aircraft.

(11) Weather minimums.

(12) Emergency procedures that will be in effect. 

If KNBC, or KTLA, or various other news outlets intends to use the sUAS to 

cover sporting events from the outside of the activity, coordination will be completed by 

contacting the FSDO prior to the event to ascertain the presence of any other unmanned 

activities. Flight activity will be conducted using the same operations plan as with any 

other ENG activity with particular attention to the avoidance of over flight of large 

concentrations of people. All of the concerns in the above twelve subparagraphs have 

been or will be addressed in other portions of this exemption application. However, 

specific relief from this regulation is still necessary to ensure compliance with FARs. 

CFR 91.151 (b) Fuel requirements for flight in VFR conditions. 

CFR 91.151(b) states: 

No person may begin a flight in a rotorcraft 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, to fly after that for at 

least 20 minutes. 

The batteries that power the DJI S100 and Intuitive Aerial Aerigon have a mission 

life of approximately 30 minutes. To meet the 20 minute reserve requirement, the 

airborne mission would be limited to approximately 10 minutes. Given the limitation of 

the proposed flight area during any ENG, a more liberal flight time is a reasonable 

request. The aircraft would never be further than 150 feet from the recovery area, literally 

representing seconds to land. In no case would the aircraft be operated with less than 20% 

battery life remaining. 
No night time operations are currently planned. 

CFR 91.203 (a) & (b) Civil Aircraft: Certifications required 

CFR 91.203 (a) & (b) states: 

(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. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a copy 

of the applicable operations specifications issued under § 21.197(c) of this chapter, 

appropriate sections of the air carrier manual required by parts 121 and 135 of this 

chapter containing that portion of the operations specifications issued under §21.197(c), 

or an authorization under § 91.611) must have on it the registration number assigned to 

the aircraft under part 47 of this chapter. However, the airworthiness certificate need not 

have on it an assigned special identification number before 10 days after that number is 

first affixed to the aircraft. A revised airworthiness certificate having on it an assigned 

special identification number, that has been affixed to an aircraft, may only be obtained 

upon application to an FAA Flight Standards district office. 

(2) An effective U.S. registration certificate issued to its owner or, for operation within 

the United States, the second copy of the Aircraft registration Application as provided for 

in § 47.31(c), or a registration certification issued under the laws of a foreign country. 

(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. 

The sUAS to be employed has no cockpit or pilot and therefore has no ability to 

carry onboard any certification or registration documentation. 

The equivalent level of safety will be achieved by keeping these documents with 

the pilot/team on the ground at the event. Previous precedence is resident in Exemptions 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A and 10700. 

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 417 (a) & (b) Maintenance 

These CFRs state:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter; 

Operation after maintenance, preventive maintenance, rebuilding, or alteration. 
(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter; and 

(2) The maintenance record entry required by § 43.9 or § 43.11, as applicable, of this 

chapter has been made. 

Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had—

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter. 

operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance 

of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and 

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its appliances 

are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 
revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a) (1) of this section shall be retained until the 

work is repeated 

or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a) (2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

These FARs only concern aircraft with an airworthiness certificate and therefore would 

not apply in this situation. All maintenance and inspections will be conducted IAW the 

maintenance manual and operations manual. The ability for an almost immediate safe 

recovery and landing if a malfunction occurs and the multi engine configuration with the 

ability to fly with loss of thrust on 2 engines provides a comfortable operating envelope 

and ensures an equivalent level of safety. 

The reasons why granting Larry Welk, request would be in the public interest; that is, 

how it would benefit the public as a whole: 

Granting the exemption to Larry Welk, would allow the public to safely view breaking 

news from a dynamic and unprecedented aerial perspective. Larry Welk has created a 

unique way to view news events that benefits the general public socially and

economically. Larry Welk, sets the industry standard in using purpose built Small 

Unmanned Aircraft Systems (sUAS) with multiple redundant features that enhance 

safety. Larry Welk, operates its DJI S1000 and Intuitive Aerial Aerigon platform with 

dual electronic motherboards and flight control systems, multi high-capacity batteries 

rated between 10,000 mAh and 22,000 mAh each, and the ability to maintain controlled 

flight with the loss of 2 engines. 

In addition, enhanced safety is achieved by using an unmanned aircraft that does not 

carry passengers or crew and does not carry flammable fuel. 

IAW 14 CFR Part 11.81, the following summary is provided for publication in the 

Federal Register, should it be deemed necessary: 
Applicant seeks relief from the following rules: 

14 CFR Part 21, Subpart H– Airworthiness Certificates, 14 CFR 45.23 

(b),14 CFR 61.113, (a) & (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 

CFR 91.103 (b), 14 CFR 109, 14 CFR 91.119, 14 CFR 91.113, 14 CFR 

91.121, 14 CFR 91.131 (a) (1) (c) (2) (d) (1), 14 CFR 91.145 (b), 14 

CFR 91.151, 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a); 407 (a) (1); 

409 (a); 417 (a) & (b), 14 CFR 407, 14 CFR 409, 14 CFR 417, 

NOTAM 9/5151 

The unparalleled operational and testing capabilities created by the partnership 

between Larry Welk, and Intuitive Aerial will enable the Federal Aviation Administration 

to allow for the introduction of sUASs into environments not previously allowed with an 

acceptable level of safety. This is an opportunity to use highly dependable, multiredundant unmanned aircraft in a major metropolitan area, but to do so with stringent 

controls, pervasive risk management and detailed mitigation strategies to ensure that the 

public is not at any time exposed to unsafe conditions. Extensive range testing, “dry-run” 

testing under benign conditions and simulated emergencies will demonstrate that this 

activity can be accomplished without hazard to the general public. The rotorcraft being 

proposed for this operation has redundancy in every conceivable area: thrust, 

communications, and electrical power for both the aircraft itself and the supporting 

system. Eight engines powered by multiple separate batteries power ranging between 

10,000 mAh and 22,000 mAh and a data link system with “fly home” capability ensure 

that at no time will the aircraft not be able to land safely should that need arise. Preplotted waypoints using Geographic Instrument System coordinates and auto-pilot “fly 

to” commands provide extremely precise navigation. A Safety Management System will 

be employed and will address such issues as environmental impact (noise and hazardous 

material) and coordination with local Emergency Services/Incident Management 

personnel to include: 

• Fire fighting

• Medical Response

• Incident investigation

These capabilities, in total, provide a level of safety that should be satisfactory to the 

FAA and general public. 

In view of the beneficial advantages to public safety, we respectfully submit our Section 

333 exemption request.