Aug 14

th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Innova Contractors, 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, Innova Contractors, LLC (Innova) 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: aerial photography, videography, aerial

Surveys and Geomatics; mapping, geospatial imaging, data collection and management for agriculture,

mining, inspections and real state.

This petition for exemption addresses pertinent FAA FAR’s and CFR’s as well as, but not 

limited to, these accompanying Innova’s documents.

1. Flight Operations Manual and;

2. Operations Manuals

(collectively referred to as Operations Manuals")

3. User Guide and;

4. User Manual

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

1

Innova submits these as well as other Innova 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 Innova 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 etseq.

1

The 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).

INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

This Petition is organized as follows:

I. Petitioner

II. Description of Proposed Operations

A. Aerial Photography and Videography; Aerial Survey and Geomatics; Mapping, Geospatial 

Imaging and Data Management; Precision Agriculture; Real State; Search and Rescue, among 

others

III. Relevant Statutory Authority

IV. Innova Proposed I-UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the I-UAS 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
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

I. DESCRIPTION OF PETITIONER

Innova Contractors, LLC based in Doral, Florida is a Geomatics technology consulting company providing 

business and technical consulting services in areas of aerial mapping and geospatial data collection 

including; remote sensing, measurement by Geomatics instrumentation and technological analysis of aerial 

geospatial data. Innova has more than twenty years of combined experience in the fields of geomatics, 

surveying and analysis of residential, commercial and industrial construction projects. The company provides 

a unique perspective for all of clients through aerial video analytics, digital 3D imagery, predictive 

analytics, information and data management, workflow and processes by utilizing state of the art 

technologies. Innova seeks an exemption to allow for the commercial flight operations of small 55lbs or less 

UAS to provide professional Geomatic innovative services through the deployment of low altitude aerial 

geospatial data collection systems for its clients. Use of the small 55lbs or less UAS will provide Innova 

Contractors, LLC a safe and efficient platform to perform its business flight operations, data management 

operations.

The contact information for Petitioner is as follows: 

Jose Rivera Cacho

President

Innova Contractors, LLC

6445 NW 113 CT 

Doral, FL 33178

Phone: 787.464.4397

Email: jrc@innovacontractors.com

II. DESCRIPTION OF PROPOSED OPERATION

Innova seeks an exemption pursuant to Section 333 of the 2012 Reform Act to operate DJI S1000+, DJI 

Phantoms (II, II+, III pro), DJI Inspire 1, Sense Fly Ebee RTK, Trimble UX5, Sense Fly eXom and a Precision 

Hawk Lancaster, also known as, (I-UAS) for the proposed operations discussed below. UAS operations will 

occur under tightly controlled conditions on private property where Innova 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 Innova’s Operations 

Manuals. As detailed in Innova’s Operations Manuals, 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

5 nm away from an airport. Moreover, Innova’s Operations Manuals incorporate redundant safeguards to 

assure that the aircraft does not travel outside the controlled area of I-UAS operations, including GPS "geofencing" technologies.

A. Aerial Geomatics; Mapping, Geospatial Imaging and Data Management

Innova seeks to use its small I-UAS for the purpose of conducting aerial Geomatics; mapping, geospatial 

imaging, data acquisition and data management. The Company has tailored its operations to meet the 

requirements established by the FAA in prior grants of exemptions authorizing the commercial use of UAS in 

aerial Geomatics; mapping, geospatial imaging, data acquisition and data management including:
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

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

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

 Innova Solutions (Exemption No. 11671)

UAS aerial Geomatics; mapping, geospatial imaging, data acquisition and data management 

operations will be conducted on private property in a controlled area, away from spectators and persons 

not involved in the flight operations. UAS flight operations will be conducted during daylight hours, VFR 

conditions, at altitudes below 400' AGL. As set forth below, Company’s operations provide a superior level 

of safety and quality compared to performing the same Geomatics work using conventional fixed- wing 

aircraft or helicopters.

Traditional methods of aerial Geomatics; mapping and geospatial imaging, expose Geomatics 

technicians to higher risks of serious injuries, or death. Geomatics technicians need to climb towers, roof tops 

or otherwise perform elevated work, which exposes them to the risk of dangerous falls or other work related 

extremes. In addition, depending on the nature of the data needed, proximity to equipment, and other 

mechanical hazards associated with industrial and construction sites often involves a risk of exposure to 

many hazards. The use of UAS mitigates such hazards and is ultimately a much safer method of performing 

these and most other types of Geomatics work.

UAS aerial Geomatics; mapping and geospatial imaging is much safer than traditional manned aircraft 

performing the same function. Conventional Geomatics flight operations using rotorcraft and fixed-wing 

aircraft in low level operations present very high risks with vehicles weighing thousands of pounds, carrying 

passengers and large amounts of fuel. It is important to note that the use of small I-UAS in this area will not 

only be safer and more cost effective, but the quality of collected data and information is far superior. 

Additionally, aerial Geomatics; mapping and geospatial imaging is more reliable, and allows for the 

collection, dissemination, and storage of visual content and other sensory data with greater precision and 

duration. UAS are also capable of mapping and geospatial imaging in areas that would otherwise be 

inaccessible to humans and would be impossible to be completed with conventional aircraft or other methods.
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

III. RELEVANT STATUTORYAUTHORITY

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 Airspace System ("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. INNOVA’S PROPOSED I-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333

OF THE REFORMACT

The small I-UAS operations proposed by Innova 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 I-UAS's Size, Weight, Speed, and Operational

Capability

A Grant of Exemption is appropriate for operations conducted using the I-UAS due to its size weight, speed, 

and operational capability.
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

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

2

 I-UAS weigh less than 55 pounds, including payload.

 I-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.

 I-UAS 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 I-UAS to return to a predetermined location and safely land without 

injury or damage.

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

Federal Communications Commission ("FCC") and other appropriate government 

oversight agency requirements. The operating frequency for I-UAS are 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 I-UAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating 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 LowCountryRC, 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).
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

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

Operations Manuals

Innova’s Operations Manuals and the Manufacturer's Manual for the selected I-UAS will contain all the 

procedures and limitations necessary to safely and successfully perform the operations specified in this Petition 

for Exemption. To assist the FAA in making a safety assessment of Innova’s proposed operations, below is a 

summary of operational limitations and conditions that Innova will adhere to, and which will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. I-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. I-UAS 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) markingsin 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 I-UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct 

the mission.

5. PICs shall possess at least a Sport Pilot's Certificate and current Class II 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 Innova’s 

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

upon request.
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

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

Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and must be followed. 

Otherwise, Innova shall follow the procedures outlined in their Operations Manuals.

10. Innova 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. Innova 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, Innova will seek 

an amendment to its Grant of Exemption. Innova will contact the FAA’s I-UAS Integration Office (AFS80) if questions arise regarding updates or revisions to the operating documents.

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

ground control station anytime the I-UAS is operating.

12. The PIC is prohibited from beginning a I-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 I-UAS will be limited to 50 minutes 

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

than 20%, 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 fromthe 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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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 Innova 

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 I-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 I-UAS records as required by Innova's Operations Manuals.

19. Innova 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 Innova's Operations Manuals. The PIC who conducts the functional test flight 

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

functional test flight and I- UAS record entry shall be included in the Innova's Operations Manuals.
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

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 Innova’s Operations Manuals.

23. Innova 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 a current Class II Medical Certificate or a valid state 

driver’s license.

29. Prior to conducting operations for Geomatics, 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. This 

requirement can be, and often is completed through non-commercial hobbyist flight activities.

30. Prior to conducting operations for Geomatics, 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 hours as UAS 

pilot operating the make and model of UAS to be utilized for operations under the exemption and three 

take-offs and three 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. The UAs will not be operated from an elevated platform or moving device/ vehicle.

35. 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 ISREQUESTED

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 I-UAS, from its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the publicinterest.3

Innova 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 I-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 that provided by the rule from which you seek exemption.
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INNOVA CONTRACTORS LLC / TEL. 787-464-4397 / NW 113CT, DORAL, FL 33178

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 I-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 I-UAS that fail to meet the requirements of the 

Reform Act, an exemption is requested.

Equivalent Level of Safety

Innova’s use of the I-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 I-UAS weighs less than

55 pounds, including payload and will not be flown at a ground speed in excess of 50 knots. I-UAS is also

equipped with safety features that will allow Petitioner to operate the I-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

UAS have the capability to operate safely after experiencing certain in-flight contingencies or

failures and uses an auto-pilot system to maintain I-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 UAS’s 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. I-UAS 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 I-UAS carry neither pilots nor passengers, carry no explosive materials or flammable 

liquid fuels, and operate exclusively within the parameters stated in Innova’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. Innova 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 I-UAS under the proposed 

conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness 

certificate.

Lastly, the I-UAS 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 I-UAS.8In addition, 

no sense-and-avoid technology is necessary for the I-UAS 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}

deemed unsafe or unnecessary to fly over. The petitioner states further that the I-UAS has built-in intelligent 

fault handling which allows the Phantom II and S1000+ 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 batterylevels.

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 others to 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.

8See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

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

Requirements

Innova 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 two inches nor more than six 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 Innova will bear N-number markings that are as large as practicable in accordance 

with 14 C.F.R. Part 45, Subpart C.11

10FAA 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

Innova 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 insubpart

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 I-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 Innova’s Operations Manuals, the PIC will conduct a pre-flight inspection of 

the I-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 I-UAS and no flights will occur unless, and until, all flight critical components of the I-UAS have been 

found to be airworthy and in a condition safe for operation. A functional testflight will be conducted following 

the replacement of any flight-critical components. As required by Innova’s Operations Manuals, the PIC who 

conducts the functional test flight will make an entry in the I-UAS aircraft records of the flight.

Innova’s Operations Manual also includes requirements to follow the manufacturer’s I-UAS 

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

following applicable components: powertrain system (powerplant), 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, Innova’s Operations Manuals also 

includes procedures to document and maintain a record of the I-UAS maintenance, preventative maintenance, 

alterations, and status of replacement /overhaul component parts, and the total time in service of the I-UAS 

used under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in 

Innova’s Operations Manuals ensure that an equivalent or higher level of safety will be achieved.
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PILOT-IN-COMMAND OF THEUAS

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

Innova 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 I-UAS 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 

I-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 MedicalCertificate. 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 I-UAS operations are involved.

Equivalent Level of Safety

The restrictions Innova has placed on its I-UAS operations meet or exceed the restrictions similarly 

imposed on Astraeus Aerial. Innova will operate on private property away from persons and property not 

involved in the operation. Innova 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 applicableCOA.

In addition to these flight restrictions, Innova 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 I-UAS flight. As set forth in the Operations Manuals, pilots will have 

experience not only in I-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 Innova. 

The pilot qualification, training, and currency requirements in the Operations Manuals ensure that Innova 

pilots are competent and proficient in the I-UAS they are operating. Innova’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.

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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OPERATING PARAMETERS OF THE I-UAS

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

Although there will be no airworthiness certificate issued for the I-UAS, Innova 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.

13Accordingly, 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. 03(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.

13See id. at 13-14, 22
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Given the small size and configuration of the I-UAS, it would be impossible to keep airworthiness 

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

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

Innova 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 Innova’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 Innova’s Operations Manuals, including checklists covering PreFlight, 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. Innova’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

I-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. FAA- 2014-

0352 at 16-18.
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Innova 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." I-UAS 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 I-UAS that Innova intends to use, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are aboard the RE- UAS, and as 

required by the Innova’s Operations Manuals, all persons will be a safe distance away in the event that the 

I-UAS experiences any difficulties during flight instruction. Moreover, as required by the Innova’s Operations 

Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety 

procedures provided for in Innova’s Operations Manuals ensure that the proposed I- UAS operations provide 

an equivalent or higher level of safety than that providedby the flight instruction regulations.

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

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

91.119(c).15Section 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 noncongested 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 I-UAS operations will normally need to occur below

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

AGL, the I-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 I-UAS.

15

Relief 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 I-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).
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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 I-UAS, 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 I-UAS, 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 I-UAS 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 I-UAS and any possible debris resulting from IUAS failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person 

within 500 feet of the I-UAS leaves a shielded position. Further, I-UAS operations will occur at least 500 feet 

away from vehicles or structures unless the property owner or 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 Innova’s 

Operations Manuals will ensure operationscan be conducted without compromising safety.

16

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

Innova 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 I-UAS donot have 

a barometric altimeter, but rather a GPS altitude read out.

16See 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 or structures 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.
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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 I-UAS 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 I-UAS that Innova intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by Innova’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 I-UAS Innova 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

Innova 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 I-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 I-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).
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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 I-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 I-UAS batteries for the IUAS 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 I-UAS operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, and 

that in the event that the I-UAS should run low on power, the PIC will be alerted and can land the I-UAS as 

soon as possible. Like the VDOS Grant of Exemption, Innova’s use of the I-UAS, 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 I-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. Innova will adhere to this limitation for I-UAS flights.

The I-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 I-UAS to a groundbased-on-screen display.

20 As required by Innova’s Operations Manuals, the PIC will promptly fly the IUAS back to the home launch location or pre-determined abort location where the I-UAS may safely land, 

while still maintaining a minimum of 25% reserve battery power. Innova 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 I-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.

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

20The I-UAS ground control station displays, the I-UAS 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 I-UAS.
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VI. DRUG AND ALCOHOL PROGRAM

Innova will have policies in place to ensure that no person may participate in I-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 Innova’s Petition for Exemption. Congress has 

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

environments such as those 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 I-UAS may operate safely in the NAS before completion of the statutorily required 

rulemaking.

UAS aerial Geomatics; mapping and geospatial imaging is much safer than traditional manned aircraft 

performing the same function. Conventional Geomatics flight operations using rotorcraft and fixed- wing 

aircraft in low level operations present very high risks with vehicles weighing thousands of pounds, carrying 

passengers and 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. 

Additionally, aerial Geomatics; mapping and geospatial imaging is more reliable, and allows for the 

collection, dissemination, and storage of visual content and other sensory data with greater precision and 

duration. UAS are also capable of mapping and geospatial imaging in areas that would otherwise be 

inaccessible to humans and would be impossible to be completed with conventional aircraft or by other 

methods. Public benefit of UAS aerial Geomatics is provided through the many public and private construction 

programs that are made possible with the use of this new method of aerial robotics delivering higher precision 

safer buildings, defining better-best building location and expanding building design opportunities.

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

thousands of pounds, carrying crew in addition to flammable fuel, the I-UAS carry no passengers or crew. 

Further, in the unlikely event of an accident, Innova small battery powered I-UASs presents significantly less 

danger to persons on the ground when compared to operations by conventional manned aircraft.21 As 

Petitioner's I-UAS 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 filmmakers while Geomatics engineers perform the 

same operations for aerial Geomatics as do cameramen for aerial Geomatics, adding a greater degree of 

flexibility, which supplements the current capabilities offered by manned aircraft or by other means.

22

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

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

an onboard pilot, in addition to other onboard crewmembers, as necessary.

{footnote continued}
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VIII. PRIVACY

All Innova’s I-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 aerial Geomatics; mapping, 

geospatial imaging and data acquisition with conventional fixed-wing aircraft, rotorcraft, or other 

methods.

X. CONCLUSION

Innova’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 Innova use small UAS for providing aerial Geomatics; mapping, geospatial 

imaging, data acquisition and data management.

{continued from previous page}

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 Geomatics 

operation."

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
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Page 25

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

Respectfully Submitted,

Jose Rivera Cacho

President

Innova Contractors LLC 6445

NW 113 CT

Doral, FL 33178

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

exemptions, please contact the undersigned at:

Innova Contractors LLC 

Phone: 787.464.4397

Email: jrc@innovacontractors.com

(The following attached items contain 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. Innova 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. Maintenance Manuals