Via Electronic Submission and Certified U.S. Mail 

Docket Operations 

U.S. Department of Transportation 

West Building, Ground Floor 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590

September 21, 2015 

 Re: Application for Exemption from Specified Aviation Regulations Under 

 Section 333 of the FAA Modernization and Reform Act of 2012. 

 

 Applicant: Worldwide Aviation Solutions LLC

 Attn: James Krieger 

 2744 Moraine Valley Road 

 Wauconda, Illinois 60084 

 Phone: 847-565-0215 

 Email: jkrieger@worldwideaviation.solutions

Dear Sir or Madam: 

Please accept this letter as the application of Worldwide Aviation Solutions , LLC, for 

exemption from specified provisions of the Code of Federal Regulations. This 

exemption request is submitted under Section 333 of the FAA Modernization and 

Reform Act of 2012 (“FMRA”). 

Worldwide Aviation Solutions LLC , (the “Applicant”), specializes in Air Traffic Control 

(ATC) and Airport Construction Safety consulting services. Worldwide Aviation 

Solutions LLC will soon expand into aerial imaging and other commercial applications 

using small unmanned aircraft system (sUAS) technology. The mission of Worldwide 

Aviation Solutions LLC is to be the world leader in air traffic safety consulting and aerial 

imaging services by providing our customers with uncompromised safety and 

exceptional quality in everything that we do. We soon intend to accomplish some of 

these services with the use of cutting-edge unmanned technology in a variety of 

industries. 

JAMES KRIEGER, president of Worldwide Aviation Solutions LLC, is an instrument -

rated, fixed-wing pilot with nearly 500 hours of flying experience. He has over 33 years 

of FAA ATC experience at O’Hare Air Traffic Control Tower (ORD ATCT), Chicago 

TRACON (C90), and in the FAA Runway Safety Group (AJI-14).
The Applicant proposes to use small unmanned aircraft systems (“sUAS”) in the 

following industries. These industries are:

1. Aerial photography and videography; 

2. Precision Agriculture;

3. Wildlife population surveys;

4. Aerial Mapping;

5. Geosurvey 

6. Utility (Pipeline and Powerline) inspection; 

7. Aerial inspections of public and private structures, and

8. Real Estate photography, videography and inspection

The Applicant requests exemption from the following regulations for this purpose: 14 

C.F.R. Part 21, Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 61.113(a), (b)14 C.F.R. § 

91.7(a), (b); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.103;14 C.F.R. § 91.119(b), (c); 14 

C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14 C.F.R. § 91.203(a), (b); 14 C.F.R. § 

91.405(a), (b); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(1)-(2); and 14 C.F.R. § 

91.417(a), (b).

Summary of Applicant’s Scope of Operations

The Applicant proposes to conduct commercial sUAS operations in the areas specified 

above. The Applicant has developed a set of “Standard Operating Procedures for Flight 

Operations” (SOP) that sets forth the standards for performing the Proposed Operations 

(Appendix 1.) The SOP provides a baseline to ensure that all operations are conducted 

safely within the National Airspace System (“NAS”).

Each operation will be initiated following a discrete COA application. The Applicant 

proposes to conduct its commercial operations in Operations Areas that are clearly 

defined in each COA application (the “Operations Areas”).

The Pilot in Command (“PIC”) for each operation will hold, at a minimum, a private pilot 

certificate.

Aircraft and Equivalent Level of Safety

The Applicant’s commercial operations activities will take place in Operations Areas 

defined by the Applicant’s COA applications prior to each commercial flight. The sUAS 

operations in these Operations Areas will pose little risk of injury or property damage. 

The Applicant proposes to use the following sUAS platforms for its operations under this 

application:

1. DJI Phantom 2 Vision 

2. DJI Phantom 3 Professional
These platforms weigh less than 55 pounds, including energy sources and equipment. 

The manufacturer-provided manuals are enclosed with this application (The User 

Manual for the DJI Phantom 2 Vision is enclosed as Appendix 2, and the User Manual 

for the DJI Phantom 3 Professional is enclosed as Appendix 3.) The Manufacturer 

Instructions will be used in conjunction with the Applicant’s SOP to ensure that the 

sUAS platforms are operated safely.

The Applicant will apply to register the sUAS platforms with the FAA prior to conducting 

operations. These registrations will be in accordance with the FAA’s guidance to COA 

holders from the FAA UAS Integration Office dated November 5, 2014, as the same 

may be updated from time to time.

The Applicant agrees to be bound by the following limitations and conditions when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 pounds including energy sources and equipment.

2. The sUAS will be flown at a speed less than a ground speed of 50 knots.

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

4. Flights will be operated within line of sight of the Pilot in Command (PIC) at all 

 times.

5. All operations will utilize a visual observer. The visual observer and PIC will be in 

 communications at all times.

6. The Applicant’s SOP and the relevant Manufacturer Instructions will be 

 maintained and made available to the FAA upon request.

7. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for 

 safe flight.

8. The Applicant will follow the manufacturer’s sUAS aircraft and component 

 maintenance, overhaul, replacement, inspection, and life limit requirements. 

9. The PIC will possess at least a private pilot certificate and a third-class medical 

certificate or driver’s license.

10. The sUAS will not be operated directly over any person below an altitude that is 

hazardous to persons or property on the surface in the event of an sUAS failure or 

 emergency.

11. The Applicant will utilize the documented emergency procedures appropriate to 

 each sUAS platform in the event of system malfunctions. These procedures shall be 

those set forth in the Applicant’s SOP and the Manufacturer Instructions.

12. The Applicant will obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. The COA will require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.

13. If required, the word “Experimental” will be placed on the fuselage in compliance 

with § 45.29 (f). The equivalent level of safety will be provided by having the sUAS 

marked on its fuselage as required by § 45.29(f) where the pilot, observer and 

others working with the sUAS will see the identification of the sUAS as 

“Experimental.” The FAA has issued the following exemptions to this regulation to 
Exemptions Nos. 10700, 8738, 10167 and 10167A. The FAA has also waived the 

marking requirement entirely in other Section 333 Exemption applications, such as 

Exemptions Nos. 11109 and 11110.

14. The Applicant will document and maintain a record of the sUAS maintenance in the 

UAS airframe logbook as set forth in the Applicant’s SOP.

15. Each sUAS operated under this exemption will comply with all manufacturer Safety 

Bulletins.

16. At least 3 days before flight operations, we will submit a written Plan of Activities to 

the local FSDO with jurisdiction over the area to be flown. The Plan of Activities will 

include the following: 

a. Dates and times for all flights.

b. Name and phone number of the PIC for the sUAS flight conducted under the 

grant of this exemption.

c. Make, model, and serial or N-number of sUAS to be used.

d. Name and certificate number of sUAS PIC.

e. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the flight.

f. Signature of exemption holder or representative.

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

 where the flight will be conducted.

17. The documents required under 14 C.F.R. sections 91.9 and 91.203 will be 

available to the PIC at the ground control station of the sUAS any time the aircraft 

is operating.

18. The sUAS will 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.).

19. sUAS operation will be conducted during daylight hours. 

20. The sUAS will be operated by the PIC from a stationary position, i.e., not from 

any moving device or vehicle. 

21. The sUAS will 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. 

22. The sUAS will not operate in Class B, C, or D airspace without written approval 

from the FAA. The sUAS will not operate within 5 nautical miles of the geographic 

center of a non-towered airport 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 operator’s 

COA. 

23. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site. Further flight operations will not be conducted until the incident, 

accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided.
Regulations From Which the Applicant Requests Exemption 

The Applicant requests exemption from the following regulations:

14 C.F.R. Part 21, Subpart H 14 C.F.R. § 45.23(b) 

14 C.F.R. § 61.113(a), (b) 14 C.F.R. 14 C.F.R. § 91.7(a) (b) 

14 C.F.R. § 91.9(b)(2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.119(b), (c) 14 C.F.R. § 91.121 

14 C.F.R. § 91.151(a)(1) 

14 C.F.R. § 91.203(a), (b) 14 C.F.R. § 91.405(a), (b) 14 C.F.R. § 91.407(a)(1) 

14 C.F.R. § 91.409(a)(1)-(2) 14 C.F.R. § 91.417(a), (b)

The sUAS platforms the Applicant seeks approval to use through this exemption request 

all weigh 55 pounds or less, including payload. They operate, under normal conditions 

at a speed of no more than 50 knots. The rotorcraft platforms have the capability to 

hover and move in the vertical and horizontal plane simultaneously. Each sUAS 

platform will operate only in visual line of sight and will operate only within the 

Operations Areas defined by the discrete COA applications filed prior to each flight. 

These operations will ensure that the sUAS will “not create a hazard to users of the 

national airspace system or the public,” as contemplated by Section 333(b) of FMRA. 

Given the small size of the sUAS platforms involved and the limited environments within 

which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of sUAS to commence immediately. Also, due 

to the size of the sUAS platforms and the defined areas in which the relevant sUAS will 

operate, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the FMRA, the authority contained in the Federal Aviation 

Act, as amended; the strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit associated with sUAS operations, it is in 

the public interest to grant the requested exemption. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay. 

Narrative Regarding Requested Exemptions
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. § 91.203(a)(1)

The FAA has previously determined that no airworthiness certification is necessary for 

sUAS platforms. See, e.g., Exemption No. 11110. The Applicant therefore believes that 

no exemption is necessary from Part 21, Subpart H.

To the extent that the FAA finds that Part 21 is applicable to the Applicant’s proposed 

operations, the Applicant requests an exemption from it. Subpart H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by 14 C.F.R. § 91.203(a)(1). Given the size and 

limited operating area associated with the sUAS platforms to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the FMRA. The Federal 

Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the FMRA both authorize the FAA 

to exempt aircraft from the requirement for an airworthiness certificate upon 

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular sUAS. In all cases, an analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft operating with an airworthiness certificate without the 

restrictions and conditions proposed.

The sUAS platforms to be operated under this exemption all weigh less than 55 pounds, 

fully loaded. The platforms carry no pilots or passengers, no explosive materials or 

flammable liquid fuels, and will operate exclusively within the Operations Areas defined 

in this application. Operations under this exemption will be tightly controlled and 

monitored by the operator. The FAA will have advance notice of all operations. These 

safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Application of these same criteria demonstrates 

that there is no credible threat to national security posed by the sUAS platforms due to 

their size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23(b). Marking of the Aircraft

The FAA has previously determined that an exemption from § 45.23(b) is not required 

for sUAS platforms that do not need to be certified under Part 21. See, e.g., Exemption 

No. 11110. The Applicant therefore believes that no exemption is necessary from 14 

C.F.R. § 45.23(b). To the extent that the FAA finds that § 45.23(b) is applicable to the 

Applicant’s intended operations, the Applicant requests an exemption therefrom as 

follows.

The regulation requires: 
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.

Even though the sUAS platforms will have no airworthiness certificate, an exemption 

may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station 

on which the word “Experimental” can be placed. Given the size of the sUAS platforms, 

two-inch lettering may be impossible. The word “Experimental” will be placed on the 

fuselage in compliance with 14 C.F.R. § 45.29(f).

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by 14 C.F.R. § 45.29(f) where the pilot, visual observer and others 

working with the sUAS will see the identification of the sUAS as “Experimental.” The 

FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 

8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot’s certificate rather than a commercial pilot’s certificate to operate 

this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS 

is remotely controlled with no living thing on board. The Operations Areas will be 

controlled and all flights will be planned and coordinated in advance. The level of safety 

provided by the requirements included in the Applicant’s SOP and the Manufacturer 

Instructions exceeds that provided by a single individual holding a commercial pilot’s 

certificate operating a conventional aircraft. The risks associated with the operation of 

sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of sUAS as requested 

with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. 

§ 61.113 (a) & (b). The FAA has approved sUAS operations with a private pilot’s 

certificate in other exemptions. See, e.g., Exemption No. 11110.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. An equivalent level of safety will be provided by the small size of the 
aircraft and the requirements contained in the SOP and Manufacturer Instructions for 

maintenance and use of safety check lists prior to each flight. The Applicant will ensure 

that the sUAS is in an airworthy condition prior to each flight based on compliance with 

the specifications in the SOP and Manufacturer Instructions.

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

Section 91.9(b)(2) provides: 

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

 (2) 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.

The sUAS platforms, given their size and configuration, have no ability or place to carry 

a flight manual. An equivalent level of safety will be maintained by keeping the flight 

manual at the ground control point where the pilot flying the sUAS will have immediate 

access to it. The FAA has issued the following exemptions to this regulation: Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 

10700. The FAA has previously determined that an exemption from this regulation is not 

necessary, as relevant materials may be kept in a location accessible to the PIC and not 

on the sUAS itself. See Exemption No. 11110.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved flight manuals will not be provided for the 

aircraft an exemption will be needed. An equivalent level of safety will be provided 

through the PIC following the procedures set forth in the SOP and Manufacturer 

Instructions. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight. The PIC will account for all relevant site-specific conditions in the 

preflight procedures. The FAA has granted exemption from this regulation to other sUAS 

operators. See Exemption No. 11109.

14 C.F.R. § 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for sUAS that are similar to helicopters, and 

the exemption requests authority to operate at altitudes up to 400 AGL, an exemption 

may be needed to allow such operations. The sUAS platforms will not be operated at 

higher than 400 AGL.
The equivalent level of safety will be achieved given the size, weight, speed of the 

sUAS platforms as well as the locations where they are operated. The low-altitude 

operations of the sUAS platforms will ensure separation between these sUAS 

operations and the operations of conventional aircraft that must comply with Section 

91.119. 

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

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS platforms may 

not have a barometric altimeter, but instead a GPS altitude read out, an exemption may 

be needed. An equivalent level of safety will be achieved by the operator, pursuant to 

the SOP and Manufacturer Instructions, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight.

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

Section 91.151 (a) prohibits an individual from beginning “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.”

Given the limitations on the proposed Operations Areas, a longer time frame for VFR 

conditions is reasonable. Applicant believes that an exemption from 14 CFR § 91.151(a) 

falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed 

Martin Corporation to operate without compliance with 14 C.F.R. § 91.151 (a)). 

Operating the sUAS platforms in controlled Operations Areas does not engender the 

type of risks that Section 91.151(a) was intended to alleviate given the size and speed 

of the sUAS platforms. Similar exemptions have been granted to other operations, 

including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The FAA has previously determined that no airworthiness certification is necessary for 

sUAS platforms. See, e.g., Exemption No. 11110. The Applicant therefore believes that 

no exemption is necessary from § 91.203. However, to the extent that the FAA finds that 

section 91.203 is applicable to the Applicant’s operations, the Applicant requests an 

exemption therefrom.

The regulation provides in pertinent part:

 (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. 

The sUAS platforms weigh no more than 55 pounds fully loaded, and are operated 

without a pilot onboard. As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to 

this regulation. A representative sample of other exceptions includes Exemption Nos. 

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

14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the Applicant. Maintenance will be 

accomplished by the operator pursuant to the SOP and the Manufacturer Instructions. 

An equivalent level of safety will be achieved because these sUAS are very limited in 

size, will carry a small payload, and will operate only in defined Operations Areas for 

limited periods of time. If mechanical issues arise the sUAS platforms can land 

immediately and will be operating from no higher than 400 feet AGL. As provided in the 

SOP and Manufacturer Instructions, the operator will ensure that the sUAS is in working 

order prior to initiating flight, perform required maintenance, and will keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

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:
Applicant seeks an exemption from the following rules: 

14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 61.113(a), (b); 

14 C.F.R. § 91.7(a), (b); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.103; 14 C.F.R. § 

91.119(b), (c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14 C.F.R. § 

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

91.409(a)(1)-(2); and 14 C.F.R. § 91.417(a), (b), to operate a small unmanned 

aircraft system weighing less than fifty-five pounds. 

Approval of exemptions allowing commercial operations of sUAS platforms for 

commercial purposes will enhance safety by providing services to customers without the 

danger and cost associated with manned aircraft. The operation of sUAS, weighing less 

than 55 pounds, conducted in accord with the conditions outlined above, will provide an 

equivalent level of safety supporting the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment. As a result, sUAS are far safer than conventional 

operations conducted with manned aircraft. 

Privacy Considerations 

All flights will be conducted in the Operations Areas defined in the Applicant’s discrete 

pre-flight COA applications. These areas will present no privacy issues of consequence. 

Conclusion

By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the 

interests of the public, by allowing Worldwide Aviation Solutions LLC to safely, efficiently, 

and economically operate a DJI Phantom 2 Vision and DJI Phantom 3 Professional 

sUASs commercially within the NAS. The Applicant requests that the FAA grant the 

exemption requested herein. 

Respectfully Submitted, 

_____________________ 

James Krieger 

President 

Worldwide Aviation Solutions LLC 

Note: Due to file size limitation on Regulations.gov the following hyperlinks have been 

provided in place of Appendices 2 and 3: 
 
Appendix 1 
Worldwide Aviation Solutions LLC 

Small Unmanned Aviation System (sUAS) 

Standard Operating Procedures (SOP)

Worldwide Aviation Solutions LLC shall conduct small UAS (sUAS) 

operations in accordance with the following procedures:

1. All sUAS maintenance will be documented in a logbook.

2. All flying operations will be conducted with a two-person crew 

consisting of:

a. A drone pilot in command (PIC) who is an FAA certificated pilot 

holding an Air Transport (ATP), commercial, or private pilot 

license, and

b. A visual observer who will assist the pilot and act as a second pair 

of eyes. The visual observer will always maintain sight of the 

aircraft.

c. The visual observer and PIC must be in communication at all 

times.

3. Worldwide Aviation Solutions LLC crews shall:

h. Be equipped with:

1. A First Aid Kit

2. Ground Station Monitor

3. OSD (On Screen Display Information)

4. GPS Tracker

5. Current FAA Sectional Aeronautical Chart for the operations 

area.
6. The appropriate flight manual for the aircraft used in the 

operation.

b. NEVER fly in an area without the necessary permission to do so. 

c. Ensure that the documents required under 14 C.F.R. sections 91.9 

and 91.203 are available to the PIC at the ground control station 

of the sUAS any time the aircraft is operating.

d. Review current and forecasted weather for flight operations 

period.

e. Know what the “course” or survey area will be. Identify all 

potential hazards, obstacles, etc.

f. Perform a compass calibration before every flight.

g. Utilize the checklist in Appendix A. for all flight operations.

h. Conduct themselves in a professional and courteous manner at all 

times.

4. During flight operations:

a. Visual observers and PICs shall maintain constant visual contact 

with the aircraft at all times. 

b. PICs will ensure that the sUAS will 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.

c. PICs will not operate the sUAS in Class B, C, or D airspace 

without written approval from the FAA. The sUAS will not 

operate within 5 nautical miles of the geographic center of a non-
towered airport 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 operator’s COA.

d. PICs will ensure that the sUAS will 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.).

e. PICs will operate the sUAS only from a stationary position, i.e., 

not from any moving device or vehicle. 

f. PICs are RESTRICTED from flying above 400ʹ AGL (Above 

Ground Level).

g. PICs are PROHIBITED from operating aircraft directly over any 

person below an altitude that is hazardous to persons or property 

on the surface in the event of an sUAS failure or emergency.

h. PICs shall never take-off in manual mode. 

i. PICs shall wait for GPS lock on the ground before taking off.

j. PICs must always take off and land at least 50ʹ away from people 

that are unfamiliar with the operation of your aircraft.

k. PICs shall take off from an area free from obstacles whenever 

possible to ensure that a “return to home” landing can be 

accomplished safely.

l. PICs shall fly in GPS mode whenever possible.
m. PICs shall report any 1) incident, 2) accident, or 3) flight 

operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be 

reported to the FAA’s UAS Integration Office (AFS-80) within 24 

hours. Accidents will be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB 

Web site.

5. General: PICs of Worldwide Aviation Solutions must be 18 years or 

older and possess an FAA pilot license, current FAA medical 

certificate or driver’s license, and AMA membership insurance. 

In the event there are questions, call 847-565-0215.
Appendix A. 
Appendix 2 

Go to: http://download.dji-innovations.com/downloads/phantom-2-vision/en/

Phantom_2_Vision_User_Manual_v1.8_en.pdf
Appendix 3 

Go to: http://download.dji-innovations.com/downloads/phantom_3/en/

Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf