1

December 30, 2015

U.S. Department of Transportation (DOT)

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition for Exemption, requesting relief as per the FAA Modernization and Reform Act of 2012, 

Public Law 112-95, Section 333

AeroWoods, LLC hereby submits to the Federal Aviation Administration, pursuant to the FAA 

Modernization and Reform Act of 2012, an exemption for petition, in accordance with Section 333 of the 

Act.

This letter provides requested information as listed in the FAA’s “Public Guidance for Petitions for 

Exemptions Filed under Section 333” and “Section 333 Petition Guidance & Checklist”.

AeroWoods, LLC Background

AeroWoods, LLC is a North Dakota based company that provides consultation and services with Small 

Unmanned Aircraft Systems (sUAS). sUAS will be operated to support public and private sector partners, 

including but not limited to filming, imagery collection, inspections, photography, surveying, 

videography, marketing, and training. Examples of what these types of operations can support include, 

but are not limited to:

1. Agriculture

2. Air quality monitoring

3. Athletic performances

4. Bridges

5. Building and construction zone

6. Construction sites

7. Crop surveying

8. Education

9. Electric grids

10. Electric utility industry, oil and pipelines

11. Emergency management assistance

a. Search and rescue, hazmat/ chemical, biological, radiological and nuclear management, 

and emergency and disaster response

12. Establish a UAS Flight Instruction Program

13. Flare stacks

14. Geographic Information Systems (GIS)

15. Geologic hazard assessment

16. Image mapping

17. Mapping and survey applications

18. Market research

19. Media and advertising

20. Mines

21. Petroleum and mining industry

22. Power lines

23. Pipeline patrol

24. Precision aerial surveys

25. Professional marketing

26. Railroad infrastructure and operations
2

27. Remote sensing

28. Research and development

29. Security services

30. Student instruction

31. Telecommunication/cell tower sites

32. Wildlife and natural resource

33. Disasters and catastrophe events

Contact Information

Trevor Woods

AeroWoods, LLC.

1106 Sunset Drive

Grand Forks, ND 58201

Telephone: 763-218-4694

Email: trevorjwoods@gmail.com

Specific Sections of 14 CFR for which the exemption is sought:

• 14 CFR 21, Subpart H, Airworthiness Certificates

• 14 CFR 61.23(a) and (c), Medical certificates: Requirement and duration

• 14 CFR 61.101(e)(4) and (5), Recreational pilot privileges and limitations

• 14 CFR 61.113(a), Certification: Pilots, Flight Instructors, and Ground Instructors

• 14 CFR 61.315(a), What are the privileges and limits of my sport pilot certificate?

• 14 CFR 91.7(a), Airworthiness required for operation

• 14 CFR 91.119(c), Minimum safe altitudes

• 14 CFR 91.121, Altimeter settings

• 14 CFR 91.151(a)(1), Fuel requirements for flights in VFR conditions

• 14 CFR 91.405(a), Maintenance required

• 14 CFR 91.407(a)(1), Operations after maintenance

• 14 CFR 91.409(a)(1) and (2), Inspections

• 14 CFR 91.417(a) and (b), Maintenance records

Equivalent level of safety

In an effort to minimize risk to the National Airspace System, and to minimize risk to persons and 

property on the ground, operations will be conducted in accordance to the following limitations and 

conditions:

1. Operations authorized are limited to the UAS requested in this petition when weighing less than 

55 pounds including payload. Proposed operations of any other aircraft will require a new petition 

or a petition to amend.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). Either 

groundspeed or calibrated airspeed may be used to determine compliance with the 87 knot speed 

restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL.
3

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. All documents needed to operate the UAS and conduct its operations in accordance with the 

conditions and limitations stated in this petition, are hereinafter referred to as the operating 

documents. The operating documents must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, the 

conditions and limitations herein take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may update or 

revise its operating documents. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator or any law enforcement official upon 

request. The operator must also present updated and revised documents if it petitions for 

extension or amendment to this petition. If the operator determines that any update or revision 

would affect the basis upon which the FAA would grant an exemption, then the operator must 

petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS−80) may be contacted if questions arise regarding updates or revisions to the operating 

documents.

8. 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 prior to conducting further operations. Functional test flights may only be conducted by a 

PIC with a VO and must remain at least 500 feet from other people. The functional test flight 

must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this petition must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, 
4

a territory, a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this petition, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a 

manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s 

PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated under this 

petition are permitted under the terms of this petition. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 

14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in 

the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport’s management is obtained or otherwise permitted by a COA 

issued to the petition requester. The letter of agreement with the airport management must be 

made available to the Administrator or any law enforcement official upon request.

17. 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.

18. For tethered UAS operations, the tether line must have colored pennants or streamers attached at 

not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible 

from at least one mile. This requirement for pennants or streamers is not applicable when 

operating exclusively below the top of and within 250 feet of any structure, so long as the UA 

operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance with an ATO-issued COA. The petitioner may apply for a new 

or amended COA if it intends to conduct operations that cannot be conducted under the terms of 

an existing COA.
5

23. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request.

25. The UA must remain clear and give way to all manned aviation operations and activities at all 

times.

26. The UAS may not be operated by the PIC from any moving device or vehicle.

27. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the 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 in a manner ensuring the safety of nonparticipating 

persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects 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. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

28. All operations shall be conducted over private or controlled-access property with permission from 

the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

For operations of closed-set motion picture and television filming and production, the following 

additional conditions and limitations apply.

30. The operator must have a motion picture and television operations manual (MPTOM) and 

submitted as an amendment to the petition.

31. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must 

submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;
6

b. Name and phone number of the operator for the UAS aerial filming conducted under this 

grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of the 

UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission 

must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation.

32. Flight operations may be conducted closer than 500 feet from participating persons consenting to 

be involved and necessary for the filming production, as specified in the MPTOM.

Unless otherwise specified, the UAS, the UAS PIC, and the UAS operations must comply with all 

applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

Public Interest

Granting the petition will further public interest by allowing AeroWoods, LLC to safely, efficiently, and 

economically perform aerial services at low altitudes in the National Airspace System. The use of 

traditional manned aircraft to perform the services requested are economically less feasible and come at 

an increase in risk to crewmembers on board the aircraft, aircraft in the NAS, and persons and property on 

the ground. The use of a sUAS in place of a manned aircraft reduces this risk considerably.

Proposed Operations

The UAS will be flown in airspace under 400 feet above ground level and under controlled conditions. If 

Petitioner intends to operate within five (5) miles of any active landing strip or airport, Petitioner will 

follow proper FAA procedures for obtaining a Certificate of Authorization, notifying the FAA in advance 

of operation and when operation is complete. Petitioner’s pilot in command (“PIC”) holds at a minimum a 

private pilot’s license, and an FAA medical certification. For training purposes, the PIC will also hold an 

FAA Flight Instructor Certificate. The PIC will always make a safety assessment of the risk of every 

operation and will only operate UAS when the PIC determines no undue hazards exist. No UAS flight 

will exceed line-of-sight distance of the PIC and visual observer at any time.

All UAS will be flown on property with the consent of the landowner. Petitioner will protect the privacy 

of all involved and non-involved parties present during the use of the UAS. Petitioner will obtain consent 

and permission from any party filmed or photographed and will not film or photograph any party that has 

not provided consent. Petitioner will follow the procedures for startup set forth in the manual for each 

UAS. Additionally, Petitioner will perform a site inspection before each flight to determine additional 

measures that may be necessary to safely operate the UAS.

Unmanned Aircraft Systems to be used for Proposed Operations

• DJI Phantom 3 Professional

• DJI Phantom 3 Advanced

• DJI Phantom 3 Standard

• DJI Phantom 2 Vision+

• DJI Phantom 2 Vision
7

• DJI Phantom 2

• DJI Phantom 1

• DJI Inspire 1 Pro

• DJI Inspire 1

• DJI Spreading Wings S1000+

• DJI Spreading Wings S900

• DJI Matric 100

• 3D Robotics Solo

• 3D Robotics X8-M

• 3D Robotics Aero-M

• Airborne A1 HD X8

• Airborne A2 HD X4

• Airborne A2 HD X8

• AEE AP10

• AEE AP11

• Yuneec Q500+

• Yuneec Q500

• Yuneec Typhoon G

• GHOST Drone Aerial 2.0

Summary for Publication in Federal Register

Petition for Exemption

Docket No.: FAA-2015-XXXX

Petitioner: AeroWoods, LLC

Sections of 14 CFR

Description of Relief Sought: The petitioner is seeking an exemption to utilize small Unmanned Aircraft 

Systems (sUAS) to accomplish various sUAS services in support of public and civil industries.

Sincerely,

Trevor Woods

Managing Member

AeroWoods, LLC