U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”), UAS Works, LLC (the “Applicant”), planned operator of an Unmanned 

Aircraft Systems (“UAS”) seeks an exemption from Federal Aviation Regulations 

(“FARs”) listed below and discussed in Appendix A. Attached, as Appendix B, is a 

summary of this request, and as Appendix C, a link to the manufacturer’s operational 

manual describing the UAS. 

The requested exemption would allow the Applicant to safely, efficiently, and 

economically use commercial UAS in the National Airspace System (NAS), so long as 

such operations are conducted within and under the conditions outlined herein or as may

be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would authorize the Applicant 

to perform commercial operations with UAS that will provide the following benefits: 

1. Commercial use of UAS to perform aerial acquisition and research in support of 

government entities, agriculture industry, utility companies, local infrastructure, scientific 

studies, wildlife monitoring, mining, surveying, forestry, and much more. All of which 

are critical to the well-being of the general public. 

2. The use of UAS will decrease congestion in the NAS along with reducing the noise and 

air pollution generated during traditional manned aircraft flight operations. 

3. When using UAS to complement field personnel, they reduce safety concerns when 

gathering data from inaccessible or unstable/unsafe areas and in extreme weather or 

terrain. 

4. Operation of UAS will substantially reduce the risk to life and property in the air, and 

on the ground, which is commonly associated with traditional manned aircraft flight 

operations. 

5. Similar to the current manned aircraft flight operations that have been conducted for 

many decades, UAS used for similar tasks will not generate any new privacy issues. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator's) responsibilities under Section 333(c) of the 

Reform Act to "establish requirements for the safe operation of such aircraft systems in 
the national airspace system." 

The name and address of the applicant are: 

UAS Works, LLC

Attn: William Glasscock

Ph: 410.302.4391

Email: w.a.glasscock@gmail.com 

Address: 1507 Devere Dr

Pasadena, MD, 21122

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c); 

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b); 

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a) 

Appendix A discusses each rule listed above and explains why exemptions pursuant to 

the proposal set forth in this letter are appropriate, provide an equivalent level of safety, 

and are in the public interest. 

QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM 

ACT 

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other potentially

relevant factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive UAS 

under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) 

controlled as to access, and; (4) would provide an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose. 

The UAS planned to be operated is a rotorcraft weighing less than 15 lbs., and always 

less than 55 lbs., including payload. It operates, under normal conditions, at a speed of no 
more than 50 knots. The principal construction material of the UAS is typically foam 

and/or plastic. Operations will be performed by a qualified UAS Pilot in Command 

(PIC), as outlined below, to ensure that the UAS will "not create a hazard to users of the 

national airspace system or the public." Given the small size of the UAS involved and the 

pre-planned environment within which they will operate, the applicant believes that these 

operations fall 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 

UAS to commence immediately. Also, due to the size of the UAS and the pre-defined, 

restricted area in which the UAS will operate, approval of the application presents no 

national security issue. The operation of UAS by knowledgeable professionals will serve 

to enhance safety, add to the public benefit, and reduce environmental impacts related to 

current methods of manned aircraft flight operations. 

These limitations and conditions to which the operator, or its employees, acting as UAS 

PIC agrees to be bound when conducting commercial operations under an FAA issued 

exemption: 

1. Safety will be the first and foremost consideration in any UAS operation. 

2. The UAS pilot will be considered Pilot in Command (PIC), whether flying or 

supervising, and will be responsible for safe operation of the flight. 

3. Flights will be operated within line of sight of the PIC and/or an observer, which 

will be at a distance of less than one (1) mile. 

4. The UAS will weigh typically less than 15 lbs., and always less than 55 lbs. 

5. The UAS will operate at a maximum speed of no greater than 50 knots. 

6. Flights will be operated in Class G airspace whenever possible. If operation in 

other airspace is required, the relevant controlling agency will be notified at least 24 

hours prior to the operation and, if required, any necessary permission obtained. 

7. Aircraft shall not be operated within 3 miles of an airport without prior approval 

of, and establishing a line of communication for the duration of the flight operation 

with, the controlling authority of that airport. 

8. Aircraft shall avoid areas where manned aircraft can be expected to be descending 

through 400ft. 

9. Aircraft shall maintain a minimum horizontal separation of no less than one (1) 

mile from all other manned or unmanned airborne aircraft unless that other aircraft is 

maintaining level flight or climbing at an altitude above 8000ft AGL. 

10. If at any time the operator see or hears another aircraft and it appears that aircraft 

may come within one (1) mile of the operator’s system, or it is questionable whether or 

not it will do so, the operator shall immediately descend the system to 100 ft. AGL or less 
and direct the system on a heading toward it’s designated landing area, or alternate 

landing area if necessary, until the system has landed or it is determined the other aircraft 

has maintained a separation of one (1) mile. 

11. Flights will be operated under visibility and cloud clearance requirements 

equivalent to Visual Flight Rules (VFR). 

12. The UAS will at all times give way to any aircraft carrying persons. 

13. Minimum crew for each operation will consist of the UAS PIC. An observer will 

be utilized if the Risk Assessment, as detailed in Section 5.5 of the General Operations 

Manual, determines the need. The observer and PIC will at all times be able to 

communicate by voice. 

14. Prior to a UAS flight, an area of operation will be established. This area of 

operation will include a defined lateral and vertical area, where the UAS will operate. 

Safety procedures will be established for persons, property and applicable airspace within 

the area of operation. 

15. The UAS shall operate from on-site takoff/landing locations directly next to the 

PIC and/or Observer. 

16. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the UAS or appropriate timing. 

17. The UAS will utilize GPS navigation, failsafe’s, return-to-home (RTH), and flight 

abort safety features, among other built-in safety features. 

18. A Ground Station will be connected, by radio communication, to the UAS during 

the entire flight, which will give the PIC flight information such as GPS Position, 

Altitude, Battery Remaining, and other telemetry information. 

19. A briefing will be conducted in regard to the planned UAS operations prior to 

operation at each new location. All personnel who will be performing duties within the 

boundaries of the area of operation will be present for this briefing. 

20. All required permissions and permits will be obtained from appropriate state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

21. Written, to include electronic, and/or oral permission from the relevant property

owners will be obtained prior to an operation. 

22. The UAS pilot will be trained in advance for the safe operation of the UAS to be 

operated. This will include operation of the UAS both in normal and emergency modes of 

operation, and will include familiarization with the operation manual (or similar) if 

published by the UAS manufacturer. Training will also include types of maneuvers to be 
performed and the safe operation in relation to persons, property and applicable airspace. 



It is the applicant's belief that the size, weight, speed, operating environment, and 

operating capabilities provide an "equivalent level of safety" or better when operating a 

UAS for the public interest as outlined in Section 333 of the Reform Act. It is requested 

that the FAA issue an exemption to permit safe, legal, commercial UAS operation by the 

applicant as soon as possible. 

Respectfully submitted, 

UAS Works, LLC

1507 Devere Dr

Pasadena MD, 21122
Appendix AEXEMPTION REQUESTS AND EQUIVALENT LEVEL OF 

SAFETY 

The applicant requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of UAS’s: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

14 CFR § 91.203(a)(1)Section 91.203(a)(1) requires all civil aircraft to have a 

certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, 

establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR § 91.203(a)(1). Given the size of the aircraft (typically less than 15 lbs., 

and always less than 55 lbs.) and the limited operating area associated with its utilization, 

it is unnecessary to go through the certificate of airworthiness process under Part 21 

Subpart H to achieve or exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the 

Reform Act 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 UAS involved. 

In this case, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness 

certificate. The UAS weighs typically less than 15 lbs., and always less than 55 lbs. fully

loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will 

operate exclusively within an area pre-disclosed and in compliance with conditions set 

forth herein. Operations under this exemption will be tightly controlled and monitored by

both the operator, pursuant to the conditions set forth above, and by local public safety 

requirements. The FAA will have advance notice of all operations through the filing of 

NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the 

lack of flammable fuel, and the fact that the aircraft is carried to the location and not 

flown there all establish the equivalent level of safety. The UAS provides at least an 

equivalent, and most likely exceeds, level of safety to that of such operations being 

conducted with conventional aircraft that would be orders-of- magnitude larger and 

would be carrying passengers, cargo, and flammable fuel. 

14 CFR. § 45.23 & 91.9(c): Marking of the Aircraft 

Regulation 45.23 provides:(a) Each operator of an aircraft must display on that aircraft 

marks consisting of the Roman capital letter “N” (denoting United States registration) 

followed by the registration number of the aircraft. Each suffix letter used in the marks 

displayed must also be a Roman capital letter.(b) When marks include only the Roman 

capital letter “N” and the registration number is displayed on limited, restricted or lightsport 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. 

Regulation 91.9(c) provides:No person may operate a U.S.-registered civil aircraft 

unless that aircraft is identified in accordance with part 45 of this chapter. 

The UAS has no entrance to the cabin, cockpit, or pilot station on which the markings can 

be placed. Given the size of the UAS, two-inch lettering will be impossible. Official 

marking systems for UAS have not yet been established for operations inside the NAS. 

The applicant is prepared to mark the UAS with the name of the organization and 

location or origin and fulfill any other request by the FAA to this topic in accordance to § 

45.29(f) where the pilot, observer, and others working with the UAS will see the 

identification of the UAS. 

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 

8738, 10167, 10167A and 10700. 

14 CFR § 61.113 (a) and (b): Private Pilot Privileges and Limitations, Medical 

Certificate 

In addition, applicant seeks exemption from 14 C.F.R § 61.113, which restricts private 

pilot certificate holders from flying aircraft for compensation or hire, and which would 

also require a second class medical certificate. The purpose of this section is to ensure the 

skill and competency of any PIC where the aircraft is carrying passengers or cargo for 

hire. In this case, while the UAS will be operated as part of a commercial operation, it 

carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. 

FAA-2014-0352, the FAA determined that the unique characteristics of UAS operation 

outside of controlled airspace did not warrant the additional cost and restrictions 

attendant with requiring the PIC to have a commercial pilot certificate and class II 

medical certificate. Additionally, instead of having a second or third class medical, we 

suggest that the PIC exercise the privileges similar to that of a sport pilot, requiring only 

a valid US driver’s license. 

Safety Mitigation 

Petitioner seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in 

airspace and communication issues pertaining to all aircraft operators but also in the 

unique aspects of UAS flight. 

14 CFR § 91.7(a): Civil aircraft airworthiness. This regulation requires that no 

person may operate a civil aircraft unless it is in airworthy condition. Should the 

exemption be granted allowing commercial operation of UAS without an airworthiness 

certificate, no standard will exist for airworthiness of the UAS. Given the size of the UAS 

and the previous COAs issued for similar UAS, an equivalent level of safety will be 

achieved by ensuring compliance with the given UAS manuals and use of safety 

checklists prior to each flight. 
14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation

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. 

Given the size of UAS, they have no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. 

The equivalent level of safety will be achieved by keeping the flight manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. The FAA 

has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 CFR § 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 rotorcraft flight manuals will not be 

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

be provided by following a comprehensive preflight checklist. The PIC will take all 

actions including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction 

These regulations provide that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls. 

The UAS are remotely piloted aircraft and by design, do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The flight plan is either 

manually controlled through point- and-click navigation or preprogrammed as way points 

into the auto pilot before or during flight and only in unusual circumstances will the pilot 

input control functions to alter the pre-programmed flight. Given the size and speed of 

the UAS, an equivalent level of safe training can still be performed without dual controls 

because no pilot or passengers are aboard the UAS, and all persons will be a safe distance 

away should the UAS experience any difficulties during flight instruction. The FAA has 

approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 

5778K & 9862A. 

14 CFR § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically,
91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 

feet above the surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

Because aerial survey, mapping and inspection work must be accomplished at relatively 

low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 

91.119(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material 

with which UAS are built. Also, no flight will be taken without the permission of the land 

owner or those who control the land. Because of the advance notice to the landowner, all 

affected individuals will be aware of the flights . Compared to aerial survey operations 

conducted with aircraft or rotorcraft weighing far more than 55 lbs. and carrying 

flammable fuel, any risk associated with these operations will be far less than those 

currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, 

the low-altitude operations of the UAS will maintain separation between these UAS 

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

91.119. 

14 CFR § 91.121: Altimeter Settings 

Section 91.121 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. Some UAS have a barometric pressure sensor, while others only 

use GPS for elevation or altitude. When a barometric pressure sensor is on the UAS, it is 

typically “zeroed” at the point of take-off; this is right next to the PIC and not at a 

departure airport. The altitude reading will be relative to that point (on the ground) and 

not a known elevation. 

The equivalent level of safety will be achieved by the PIC confirming the elevation or 

altitude of the launch site. The altitude of the UAS will also be displayed via telemetry on 

the Ground Station and will be constantly monitored by the PIC during the entire flight 

operation. 

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation 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.” 

The different UAS batteries provide a variety of powered flight times. An exemption 

from § 14 CFR 91.151 is therefore required. 

The applicant believes that an exemption from 14 CFR § 91.151(a) is safe and within the 

scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin 
Corporation to operate without compliance with 91.151(a)). Operating the UAS, without 

30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was 

meant to prevent given the size and speed at which the UAS operates. The fact that it 

carries no pilot, passenger, or cargo also enhances its safety. In the unlikely event that the 

UAS should run out of fuel, it would simply land. Given its weight and construction 

material, the risks are less than contemplated by the current regulation. 

The applicant believes that an equivalent level of safety can be achieved by maintaining 

20% of reserve fuel (or battery), which would be more than adequate to return the UAS 

to its planned landing zone from anywhere in its operating area. 

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 

10673 and 10808. 

14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

(a) ... no person may operate a civil aircraft unless it has ... 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 UAS fully loaded weigh typically less than 15 lbs., and always less than 55 lbs. As 

such, there is no ability or place to carry certification and registration documents or to 

display them on the UAS. In addition, there is no pilot on board the aircraft. 

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

control point where the pilot flying the UAS will have immediate access to them. 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 CFR § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections 

Section 91.405(a) requires 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 ...” Section 91.407 similarly makes reference to 

requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the 

issuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator 

to keep records showing certain maintenance work that has been accomplished by

certificated mechanics, under Part 43, or licensed pilots and records of approval of the 

aircraft for return to service. 

The UAS are nearly maintenance free, they perform automatic pre-flight checks and the 

failure of any check will prevent take-off. Checks which cannot be done by the system 
will be performed by a qualified person prior to each flight and at predefined intervals as 

part of a maintenance schedule. 

Pre-flight checklist includes:1. Visual inspection of the airframe2. Visual inspections 

of rotor integrity3. Check charge of all batteries (aerial vehicle, command station, radio 

repeater station) 

An equivalent level of safety will be achieved because the UAS is small in size, will 

carry no external payload, will operate only in restricted predetermined areas and is not a 

complex mechanical devise. The operator of a UAS will ensure that it is in working order 

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

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

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

ensure an equivalent level of safety. 

If mechanical issues arise, the UAS can land immediately due to the pre-determined area 

of operation. Moreover, the UAS's small size, carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time, create less 

risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft 

performing the same operation. 
APPENDIX BSUMMARY OF SECTION 333 EXEMPTION REQUEST 

UAS Works, LLC hereby provides pursuant to Part II a summary of its exemption 

application to allow commercial operation of UAS for aerial acquisition and research in 

support of government entities, agriculture industry, utility companies, local 

infrastructure, scientific studies, wildlife monitoring, mining, surveying, forestry, and 

much more. All of which are critical to the well-being of the general public. An 

exemption is requested from the following regulations: 

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c); 

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b); 

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a). 

Appendix C – Operating Manual

Please click the link below to view the Yuneec Q500 Typhoon 4K operating manual

http://yuneec.com/support/download/manuals/q500_4k_user_manual.pdf