UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. FAA-2014-0506

WOOLPERT, INC.’S PETITION FOR AMENDMENT TO CONDITION AND 

LIMITATION NUMBER 27 OF GRANT OF EXEMPTION NO. 11111 

Submitted on February 13, 2015

GREGORY S. WINTON, ESQ.

JARED M. ALLEN, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorneys for Petitioner
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Petitioner, Woolpert, Inc. (“Woolpert”), by and through undersigned counsel, pursuant to 

the provisions of the Federal Aviation Regulations and the Federal Aviation Administration 

(“FAA”) Modernization and Reform Act of 2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator for an amendment to the 

conditions and limitations of Grant Of Exemption No. 11111 (Regulatory Docket No. FAA2014-0506), which granted to Woolpert an exemption from 14 C.F.R § 91.119(c) to the extent 

necessary to allow Woolpert to operate the Altavian Nova Block III unmanned aircraft system 

(“UAS”) for the special purpose of precision aerial surveys. 

Specifically, Woolpert seeks an amendment to Exemption No. 11111 to the extent 

necessary to allow Woolpert to operate the Nova Block III UAS within five (5) nautical miles 

of an airport reference point as denoted on a current FAA-published aeronautical chart if a letter 

of agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a Notice To Airmen (“NOTAM”) as required by the operator’s Certificate of 

Authorization (“COA”). 

Woolpert submits that the conditions and limitations set forth in Exemption No. 11111 

and herein will ensure the safety of the National Airspace System (“NAS”), as well as the safety 

of persons or property on the ground.

In support thereof, Woolpert states as follows:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Woolpert, Inc.

4454 Idea Center Blvd.

Dayton, Ohio 45430
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The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com

B. Woolpert Seeks To Amend Condition and Limitation No. 27 Of Grant Of 

Exemption No. 11111.

Condition and Limitation No. 27 of Exemption No. 11111 states the following:

The Nova Block III UA may not operate within 5 nautical miles of the geographic 

center of an airport as denoted on a current FAA-published aeronautical chart.

Exemption No. 11111 at page 12, ¶27.

C. Extent Of The Amendment That Woolpert Seeks And The Reason Woolpert Seeks 

To Amend Condition And Limitation No. 27.

Woolpert submits that Condition and Limitation No. 27 be amended as follows:

The UA may not operate within 5 nautical miles 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 operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

This relief is requested because Woolpert’s original Petition For Exemption (Regulatory Docket 

No. FAA-2014-0506) did not request operation of the Nova Block III UA within 5 nautical miles 

of an airport reference point as denoted on a current FAA-published aeronautical chart. 

However, Woolpert proposes that it may safely operate the Nova Block III UA within 5

nautical miles of an airport reference point as denoted on a current FAA-published aeronautical 

chart if: (1) a letter of agreement with that airport’s management is obtained; (2) the operation is 

conducted in accordance with a Notice to Airmen (“NOTAM”) as required by Woolpert’s 
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Certificate of Authorization (“COA”); and (3) the letter of agreement with the airport 

management is made available to the Administrator upon request.

D. The Reasons Why Granting Woolpert’s Request For Amendment Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present petition for amendment will further the public interest as set forth by 

the Administrator in Exemption No. 11111. As the Administrator held in Exemption No. 11111

at page 8, the enhanced safety achieved using an unmanned aircraft (“UA”) with the 

specifications described by Woolpert and carrying no passengers or crew, rather than a manned 

aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, is good 

cause to find that Woolpert’s UAS operation is in the public interest. Woolpert’s UAS 

operations will provide benefits to agriculture, science, the environment, wildlife monitoring, 

forestry, and energy. Furthermore, the benefits of Woolpert’s proposed operation of the Nova 

Block III UAS will be realized without implicating any privacy issues. 

Woolpert’s proposed amendment not only furthers the public’s interest as set forth by the 

Administrator in Exemption No. 11111, it also is another step forward in fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, by allowing 

Woolpert to safely, efficiently, and economically operate the Nova Block III UAS commercially 

within the NAS.

E. The Reasons Why Granting An Amendment To Condition And Limitation No. 27 

Would Not Adversely Affect Safety.

Woolpert proposes that it may safely operate the Nova Block III UA within 5 nautical 

miles of an airport reference point as denoted on a current FAA-published aeronautical chart 

because: (1) a letter of agreement with that airport’s management is obtained; (2) the operation is 

conducted in accordance with a NOTAM as required by Woolpert’s Certificate of Authorization 
5

(“COA”); and (3) the letter of agreement with the airport management is made available to the 

Administrator upon request.

Woolpert respectfully submits that an equivalent level of safety as presented in 

Exemption No. 11111 will be maintained because no operations within 5 nautical miles of an 

airport reference point as denoted on a current FAA-published aeronautical chart will be 

conducted without first gaining airport management’s approval. As such, airport management 

will be aware of Woolpert UAS operations in the NAS and will be able to ensure safe operations. 

Furthermore, all users of the NAS will be fully aware of Woolpert’s operation of the Nova Block 

III UAS, as the operation is conducted in accordance with a NOTAM as required by Woolpert’s 

COA. 

Additionally, the FAA has previously issued a condition and limitation identical to 

Woolpert’s proposed amendment in Grants of Exemption specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11161, 11160, 

11159, 11158, 11157, 11153, and 11150).

Woolpert further submits that safety will be ensured as all other conditions and 

limitations within Exemption No. 11111 will remain in effect.

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which Woolpert Seeks Exemption:

Woolpert, Inc. seeks to amend Condition and Limitation number 27 of Grant of

Exemption No. 11111.

A Brief Description Of The Nature Of The Exemption Woolpert Seeks:

This amendment to Grant of Exemption No. 11111 will permit Woolpert, Inc. to safely 

operate the Nova Block III UA within five (5) nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart if: (1) a letter of agreement 

with that airport’s management is obtained; (2) the operation is conducted in accordance 

with a Notice to Airmen (“NOTAM”) as required by Woolpert’s Certificate of 
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Authorization (“COA”); and (3) the letter of agreement with the airport management is 

made available to the Administrator upon request.

G. Any Additional Information, Views, Or Arguments Available To Support 

Woolpert’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Woolpert’s request for amendment may be granted pursuant 

to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

CONCLUSION

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Woolpert respectfully requests that the 

Administrator grant this Petition for an amendment to Exemption No. 11111 to the extent 

necessary to allow Woolpert to operate the Nova Block III UAS within five (5) nautical miles 

of an airport reference point as denoted on a current FAA-published aeronautical chart if a letter 

of agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a Notice To Airmen (“NOTAM”) as required by the operator’s Certificate of 

Authorization (“COA”). 
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Dated: February 13, 2015

Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________

Gregory S. Winton, Esq.

Jared M. Allen, Esq. 

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorneys for Petitioner 

cc: James H. Williams, AFS-80

Robert Pappas

Dean Griffith, Esq.