February 2, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

I represent Tredegar DroneWorks and submitting this Petition for Section 333

Exemption on their behalf under Section 333 of the FAA Modernization and Reform Act of 2012

(“FMRA”).

Applicant Information:

The name of the applicant: Tredegar Droneworks Inc.

The primary contact for this application is:

Tredegar Droneworks c/o

Lewis Industries Inc.

PO Box 74141

Richmond Virginia 23236

Tredegar DroneWorks. is currently a proprietorship formed under the state laws of Virginia on or about

November 11, 2014 and Norwood B Lewis is the owner of Tredegar DroneWorks Inc.

Pursuant to Section 333 of the FMRA, Tredegar DroneWorks hereby requests a

determination by the Secretary of Transportation authorizing commercial operations of UAS for

the purposes of aerial photography & videography, mapping, power line surveillance,

agricultural crop surveillance, aerial inspections, data collection, augmented real estate listings,

commercial videos and other work related to aerial photography in the NAS. Tredegar Dronworks 

does not intend to use for closed set filming. Flight operations will utilize the off the

shelf DJI family of unmanned aircraft. Conduct of UA operations will be with respect to FMRA

Section 333(c) and the UAS “Blanket COA”.
February 2, 2015

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Exemption is necessary to effect the determination requested pursuant to FMRA Section 333.

The attached documentation includes detailed exemption requests that demonstrate how these

exemptions are in the public interest and will maintain at least an equal level of safety to existing

regulations. Authorizing Tredegar DroneWorks Inc. to conduct commercial UAS operations will

result in less disruptive, safer, and more cost effective solutions than manned aviation

equivalents due to the low altitude environment, given the size, speed and inherent risk of

traditional commercial helicopter operations. These commercial operations often occur in the

unsafe areas of the height-velocity diagram requiring special precision and skill. Tredegar 

Droneworks will conduct the commercial UAS operation in a manner that will meet, and in many

cases exceed, the current level of safety of commercial helicopter operations. UA that are under

10 lbs., have a low noise signature, and carry no volatile fuel, will limit collateral damage in the

event of catastrophic failure. The low expense of operation compared to cost prohibitive manned

aviation alternatives allow a greater economic benefit to businesses. For these reasons, granting

an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for

these commercial purposes benefit the public interest in the following ways:

 Reduces the collateral damage risks to life and property associated with low altitude

 helicopter operations in undesirable portions of the height-velocity envelope.

 Increased economic wellbeing to local businesses via cost reductions.

 Enabling aerial business solutions to be available to a larger market.
February 2, 2015

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Table of Contents

I. Exemptions Requested

II. Commercial Operation/Operator

III. Unmanned Aircraft System (UAS)

IV. UAS Pilot-in-Command (PIC)

V. Public Interest

VI. Summary

VII. List of Attachments

I. Exemptions Requested

Pursuant to 14 C.F.R. § 11.81(e),Tredegar DroneWorks Inc. requests exemption from the

following regulations:

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

o Establishes: The procedural requirements for the issuance of airworthiness

certificates as required by 14 C.F.R. § 91.203(a)(1)

Given the small size of the UA and the safeguards that will be taken as outline below, an

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety

under Part 11 and Section 333 of the FMRA with consideration “of the size, weight,

speed, operational capability, and proximity to airports and populated areas of the

particular UAS.”

 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

o When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light-sport, "experimental," or "provisional," as applicable.

Tredegar Droneworks. will ensure compliance with § 45.29(f) to meet the intent of

the regulation by displaying the registration number in the largest practicable lettering.

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private 

and Commercial Pilot Privilege and Limitations

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this

section, no person who holds a private pilot certificate may act as pilot in

command of an aircraft that is carrying passengers or property for compensation

or hire; nor may that person, for compensation or hire, act as pilot in command of
February 2, 2015

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

command of an aircraft in connection with any business or employment

o 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a

commercial pilot certificate may act as pilot in command of an aircraft – (ii) For

compensation or hire, provided the person is qualified in accordance with this part

and with the applicable parts of this chapter that apply to the operation.

o 14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may

not act as pilot in command of an aircraft:

 For compensation or hire;

 In furtherance of a business;

UA operations will employ a PIC who holds, at a minimum, a recreational or sport pilot

certificate of any category or class and a valid driver’s license.

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

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

The PIC will conduct daily pre and post flight inspections in accordance with

manufactures maintenance manual(s) and guidance. During flight, the PIC will adhere to

§ 91.7(b) and abort air operations immediately upon identification of an in-flight

emergency or other unsafe condition. By complying with procedures outlined by the

manufacturer, an equivalent level of safety will be achieved.

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard 

requirements

o (b)(2) prohibits operation of U.S.-registered civil aircraft 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.

By keeping all operating documents, manuals, authorizations and exemptions in a binder

co-located with the GCS,Tredegar DroneWorks Inc. meet the intent of the regulations

and therefore achieve an equivalent level of safety.

 14 C.F.R. 91.109(a) – Flight Instruction

o 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 majority of sUAS by design are developed with single operational control through

the use of pre-determined GPS enabled waypoints programmed before or during flight in

addition to the use of a single hand held transmitter or control station controlled by the

PIC. The design does not allow for dual controls during flight training and therefore the

exemption is requested to train operators, build experience, and maintain proficiency. An

equal level of safety will be achieved by conducting all training in sterile environments.

Training sessions will be accomplished separately from flights conducted for 

compensation or hire.
February 2, 2015

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 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

o Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes: (b) Over any congested area of a city, town, or

settlement, or over any open air assembly of persons, an altitude of 1,000 feet

above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. 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. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If

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

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

paragraph (b) or (c) of this section, provided each person operating the helicopter

complies with any routes or altitudes specifically prescribed for helicopters by the

FAA.

Commercial UAS operations will be conducted at or below the maximum altitude

authorized by COA. Given the size, weight and lack of fuel; combined with operation

limitations listed below, the operation will be conducted with a greater level of safety

than exists with current manned aviation operations.

 14 C.F.R. 91.121 – Altimeter Settings

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

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

SUAS are equipped with Global Positioning System (GPS), which provide altitude and geolocation

data to the operator without utilizing an altimeter. Due to this fact, an exemption is

required. GPS are precise within a few feet and combined with fail-safes and a visual observer the

operation will meet an equivalent level of safety.

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

o 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;

This regulation is written based on the capabilities of a traditional aircraft, which have

flight times of several hours or greater; therefore, with the majority of sUAS which have

flight times of only an hour or less, this regulation would effectively deny the ability of

the air vehicle to operate.

The PIC will achieve an equivalent level of safety by complying with all manufacturer

guidelines and the DJI low battery failsafe system.
February 2, 2015

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 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Equipment 

and Use.

o All airspace. Unless otherwise authorized or directed by ATC, no person may

operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of

this section, unless that aircraft is equipped with an operable coded radar beacon

transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A

interrogations with the code specified by ATC, or a Mode S capability, replying

to Mode 3/A interrogations with the code specified by ATC and intermode and

Mode S interrogations in accordance with the applicable provisions specified in

TSO C-112, and that aircraft is equipped with automatic pressure altitude

reporting equipment having a Mode C capability that automatically replies to

Mode C interrogations by transmitting pressure altitude information in 100-foot

increments. This requirement applies—

(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in

appendix D, section 1 of this part from the surface upward to 10,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not

originally certificated with an engine-driven electrical system or which has not

subsequently been certified with such a system installed, balloon or glider may

conduct operations in the airspace within 30 nautical miles of an airport listed in

appendix D, section 1 of this part provided such operations are conducted—

 (i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area

designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries

of a Class B or Class C airspace area designated for an airport upward to 10,000

feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an

engine-driven electrical system or which has not subsequently been certified with

such a system installed, balloon, or glider—

(i) In all airspace of the 48 contiguous states and the District of Columbia at and

above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the

surface; and
February 2, 2015

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(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile

radius of any airport listed in appendix D, section 2 of this part, excluding the

airspace below 1,200 feet outside of the lateral boundaries of the surface area of

the airspace designated for that airport.

The sUAS to be used in the proposed operation does not come equipped with a

transponder. No transponder exists for the sUAS, which can be installed. The petitioner

requests relief from the exemption to the extent required to operate in areas in which a

transponder is required according the applicable regulations in this part.

The PIC will achieve an equivalent level of safety by complying with all provisions of

the COA under which operations are to be conducted. By issuing appropriate NOTAMS

and prior ATO coordination, an equivalent level of safety can be achieved as other

manned aircraft, which receive authorization to fly in airspace where a transponder is

required but not operable. In order to give proper notice to the ATO, the PIC will comply

with the provisions of 91.215(d)(3). The sUAS flown under this exemption will comply

with all altitude limits and airport standoff distances required by COA, which mitigate

hazards to aircraft controlled by the ATO in congested airspace.

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – 

Maintenance Inspections

o 91.405(a) States: Each owner or operator of an aircraft—(a) Shall have that

aircraft inspected as prescribed in subpart E of this part and shall between

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

discrepancies repaired as prescribed in part 43 of this chapter

o 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has

been approved for return to service by a person authorized under § 43.7 of this

chapter

o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no

person may operate an aircraft unless, within the preceding 12 calendar months, it

has had—(2) An inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter. No inspection performed under paragraph

(b) of this section may be substituted for any inspection required by this

paragraph unless it is performed by a person authorized to perform annual

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance

records.

o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§

91.411 and 91.413, each registered owner or operator shall keep the following

records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i

– iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for

the periods prescribed: (paragraphs 1 – 3)
February 2, 2015

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The PIC will conduct Pre/Post flight inspections and maintenance in accordance with the

manufacturer’s guidance as stated in the operations manual. If maintenance is required,

the PIC will conduct a dedicated test flight will be conducted to ensure safety before

resuming commercial operations. All inspection, maintenance and alterations will be

documented and maintained in a record. These actions will meet the intent of the

regulations from which exemption is being requested and lead to an equivalent level of

safety.

II. Commercial Operator/Operation

Any UA flown under this exemption will be controlled by a certificated PIC. The PIC will hold,

at a minimum, a recreational or sport pilot certificate.

For each flight,Tredegar DroneWorks Inc.:

 Will contact the controlling air traffic organization to issue a NOTAM.

 Will conduct a comprehensive worksite inspection and analysis, identifying limits of

customer property or authorized access areas.

 Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

 Will operate in those areas only with the consent of the landowner or designated

representative.

 Will identify potential obstructions or other hazards to safe operation.

 Will clear the area of personnel or bystanders that are non-essential to the operation,

maintaining at a minimum, 500 feet away from non-participating persons.

 Will conduct a preflight safety briefing to Visual Observer (VO) and participating

persons.

 Will at all times yield to manned air traffic.

 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communications with VO and participating persons.

 Will operate under visual flight rules, in visual meteorological conditions, for the airspace

in which the flight is conducted.

 Will not exceed the maximum altitude as defined in the COA under which flight

authorized, as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder colocated

with the GCS.

 Will immediately terminate flight, in the safest manner possible, when safety to persons

or property become compromised.

 Will terminate flight, in the safest manner possible, when unable to comply with these

limitations or any other limitations granted as part of this exemption.

 In order to remain at an altitude at or below the attitude prescribed by the applicable COA, relief

 is needed from Section 91.119 (c). By following these operating standards, the commercial

 operation will meet an equivalent level of safety to the regulation in which relief is sought.
February 2, 2015

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III.Unmanned Aircraft System

Tredegar Droneworks. seeks exemption to operate DJI UAS. Other UAS types may be

requested in future amendments. The DJI Phantom 3 is the primary aircraft in our operation for

which we seek exemption. The UA will be flown via a combination of RC control and tablet

GCS. This UA type is a GPS equipped, multirotor helicopter. A quad-copter type rotorcraft

utilizing four motors. Lithium-polymer batteries power the UA.

The UA also has several fail-safes for loss of RC signal, loss of GPS, and low battery as 

outlined in the respective Operation Manuals. The UA display visual and emit an audible low 

battery alerts at which time the UA will automatically engage the landing sequence. Based upon

those safeguards, I request exemption from Section 91.151(b) Fuel requirements for flight in 

VFR conditions.

Given the size, weight, speed, and controlled operating area associated with the UA to be

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §

91.203 (a) and (b) is requested. Exemption is sought from § 45.23 Marking of the aircraft. The

UA will display the registration number in the largest practicable lettering. DK Consulting

Group, Inc. seeks to be exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and

(b) Maintenance inspections will be conducted according to operations manual and prudent

judgment as previously outlined to determine the integrity and safety of the UA and associated

equipment. Further, relief is required from 91.7(a), which prohibits the operation of an aircraft

without an airworthiness certificate and 91.9(b) (2) requiring an approved flight manual in the

aircraft. The UA will not be operating with an airworthiness certificate therefore, this would be

inappropriate. The UAS are too small to carry the operating documents so an equivalent amount

of safety can be achieved through keeping the operating documents and manuals at the GCS.

IV. UAS Pilot in Command (PIC)

Under part § 61, recreational, sport and private pilots are limited to non-commercial operations,

however Tredegar DroneWorks Inc. can ensure UA operations will achieve an equivalent level

of safety as current regulation because UA do not carry any pilots or passengers. A commercial

pilot certificate will not ensure RC piloting ability, as the psychomotor skills are different. The

inherent risks of operating a UAS are far less than in the commercial activities outlined in 14

CFR part 61, et seq., thus exemption is requested from § 61.101 Recreational Pilot Privileges

and Limitations. PICs will maintain recent flight experience on the UAS. Training and

experience flights will be conducted separate from commercial operations.

V. Public Interest

Given the above stated evidence, procedures, and precautions operating UAS commercially for

the purposes of aerial photography & videography, mapping, power line surveillance,

agricultural crop surveillance, aerial inspections, data collection, augmented real estate listings,

commercial videos and other work related to aerial photography will ultimately be in the public
February 2, 2015

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interest. These operations, when executed with prudence, will exceed the current level of safety

as the regulations from which exemption is sought. UA operations will allow greater access to

commercial aerial services that were not previously economically feasible for many firms. This

will provide a much needed economic uplift to the community and hence the public. UA

operations are associated with less risk of collateral damage to persons and property while

limiting disruptive noise pollution associated with low altitude aviation operations.

VI. Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and 

Reform Act of 2012”,Tredegar DroneWorks Inc., hereby applies for authorization to conduct

commercial unmanned aerial systems (UAS) operations for the purposes of aerial photography 

& videography, mapping, power line surveillance, agricultural crop surveillance, aerial 

inspections, data collection, augmented real estate listings, commercial videos and other work 

related to aerial photography listings Rules for which exemption is sought:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 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. § 91.215(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) & (b)
VII. Attachments:

1. Specific UAV manuals.

a. DJI Phantom 3 Phantom 3 Safety Guidelines and Disclaimer

2. Battery Manuals

a. DJI Phantom 3 Phantom_3_Intelligent_Flight_Battery_Safety_Guidelines__en

Thank you for your prompt attention and consideration. Traverse Legal and its clients are

committed to safe UAS operation and ambassadors. Please do not hesitate to contact me

directly with any questions or concerns at 804-928-9940.

Very truly yours,

Norwood B Lewis

Owner Operator.

tlewis@lewisindustriesinc.com

Enclosures