1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

REGULATORY DOCKET NO. ______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DRONESTHATWORK,LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

CONCERNING OPERATION OF UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request 

Dear Sir or Madam,

DRONESTHATWORK, LLC respectfully submits that the proposed operations detailed within this petition 

for exemption qualify for expedited approval under Section 333 of the Reform Act of 2012. The 

operations outlined herein, and in the Petitioner's manuals, clearly define UAS operations in the NAS 

that are under appropriately controlled conditions and within secure and sterile zones of operation. 

Further, the proposed operations pose no significant safety risk to persons or property on the ground, 

no risk to National Security, and would not constitute as an invasion of any persons reasonable 

expectation of privacy.

Submitted on January 26, 2015

Leisa Adkins, President

DRONESTHATWORK, LLC

240 Trumpet Drive

West Carrollton, Ohio 45449

Tel: (937)474-2790
2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS..................................................................................................................................3

SUMMARY..................................................................................................................................................................4

INTRODUCTION..........................................................................................................................................................4

BACKGROUND............................................................................................................................................................4

BASIS FOR PETITION...................................................................................................................................................5

A) CONTACT INFORMATION OF PETITIONER...............................................................................................5

B) THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DRONESTHATWORK, LLC

SEEKS EXEMPTION. .....................................................................................................................................5

C) THE EXTENT OF RELIEF DRONESTHATWORK, LLC SEEKS AND THE REASON 

DRONESTHATWORK INC. SEEKS THE RELIEF AND EQUIVALENT LEVEL OF SAFETY......................................9

D) THE REASONS WHY GRANTING DRONESTHATWORK, LLC'S REQUEST WOULD 

BE IN THE PUBLIC INTEREST.........................................................................................................................14

E) PRIVACY....................................................................................................................................................15

F) SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER............................................................15

G) ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT DRONESTHATWORK, LLC'S REQUEST.....................................................................................15

CONCLUSION..............................................................................................................................................................16
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FOMM Flight Operations & Maintenance Manual

FSDO Flight Standards District Office

JSA Job Safety Analysis

NAS National Airspace System

NERC National American Electric Reliability Corporation

NTSB National Transportation Safety Board

MOC Management of Change

PIC Pilot In Command

RF Radio Frequency

Section 333 FAA Modernization and Reform Act of 2012, Section 333

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line-of-Sight

VMC Visual Meteorological Conditions

VO Visual Observer
4

SUMMARY

DRONESTHATWORK, LLC seeks exemption from the requirements of part 21, subpart H: part 27 and 

Sections 45.23(b), 61.113(a) and (B), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) 

and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of 14 C.F.R.. This exemption would permit 

DRONESTHATWORK, LLC to operate the LB700 Unmanned Aircraft System ("UAS") for the special purpose of aerial 

inspection of elevated structures for the electric utility industry (or similar clients/uses) while always operating 

under the core premise that ALL aviation related accidents are preventable.

INTRODUCTION

DRONESTHATWORK, LLC's UAS Program is directed by one of the World's most skilled, safe and 

experienced small UAS pilots. Wendell J. Adkins has served as a Leader Member and Contest Director for the 

Academy of Model Aeronautics and, in addition, has represented the United States in the FAI-F3C Helicopter 

World Aeromodeling Championships, helping win a World Title for Team USA in 1993 in Velden Austria. Wendell 

has flown in 22 U.S. FAI-F3C Helicopter National Championships and has made approximately 15,000 unmanned 

sport aviation flights over the last 35 years, all without ever inflicting injury to any person or damaging the 

property of another. Wendell has also worked as a small UAS consultant to both Veridian Engineering/General 

Dynamics assisting with UAS sensor R&D projects and Northrop Grumman in support of Northrop's Beyond Lineof-Sight Tactical UAV Communications Relay Project.

BACKGROUND

Unmanned Aircraft System: LB700 Rotorcraft

DRONESTHATWORK, LLC seeks an exemption to operate the LB700 UAS, Serial #001, #002, etc., for 

compensation or hire within the national airspace ("NAS"). The LB700 UAS is comprised of a custom built, single 

rotor, lithium-polymer battery-powered unmanned aircraft system and portable ground control station. The LB700 

UAS has a maximum gross weight of approximately twenty (20) pounds, while having a main rotor diameter of 

sixty-three (63) inches. The LB700 UAS derives its flight power from a single lithium-polymer battery-powered

brushless electric motor and has a maximum airspeed of 50 knots. 

NOTE: This request for exemption is in accordance with the proprietary procedures detailed in the 

Petitioner's FOMM document enclosed. The FOMM is submitted as confidential under 14 C.F.R. § 11.35(b), as 

the entire Manual contains confidential commercial information that the Petitioner has not and will not share 

with others. The FOMM contains operating conditions and procedures that are not available to the public and 

are protected from release under the Freedom of Information Act 5 U.S.C. § 552 et.seq.

BASIS FOR PETITION

Petitioner, DRONESTHATWORK, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby formally petitions the Administrator for an exemption from the requirements 

of part 21, subpart H: part 27 and Sections 45.23(b), 61.113(a) and (B), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 

91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of 14 

C.F.R..

The proposed operations detailed within this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. The operations outlined herein, and in the Petitioner's manuals, clearly define UAS 
5

operations in the NAS that are under appropriately controlled conditions and within secure and sterile zones of 

operation and pose no significant safety risk to persons or property on the ground, no risk to National Security, and 

would not constitute as an invasion of any persons reasonable expectation of privacy.

In accordance with 14 C.F.R. § 11.81, DRONESTHATWORK, LLC provides the following information in 

support of its petition for exemption:

A. Name and Address of The Petitioner.

The name and address of the Petitioner is:

DRONESTHATWORK, LLC

Leisa Adkins, President

240 Trumpet Drive

West Carrollton, Ohio 45449

Tel: (937) 474-2790

Email: boomstrike@aol.com

B. The Specific Sections of 14 C.F.R. Parts 21, 27, 45 and 91 From Which DRONESTHATWORK, LLC Seeks 

Exemption.

1. DRONESTHATWORK, LLC Seeks Exemption From The Requirement of Section 14 C.F.R. §

45.23(b) entitled Display of marks; general, states the following:

Section § 45.23 subsection (b), 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 no less than 2 inches nor more than 6 inched high, the words 

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

2. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. § 61.113(a) & 

(b): Private Pilot Privileges and Limitations: Pilot in Command, states the following:

(a) no person who holds a private pilot certificate may act as pilot in command of any aircraft that is 

carrying passengers of property for compensation or hire; nor may that person, for compensation or 

hire, act as pilot in command of 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 if:

(1) The flight is only incidental to that business or employment: and

(2) The aircraft does not carry passengers or property for compensation or hire.

3. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. § 91.7(a): Civil 

Aircraft Airworthiness which states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.
6

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in 

condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, 

electrical, or structural conditions occur.

4. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. § Section 91.9 entitled Civil 

aircraft flight manual, marking, and placard requirements, subsection (b) states the following:

(b) No person may operate a U.S. -registered civil aircraft--

(1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.15 of this chapter unless 

there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the 

manual provided for in § 121l141(b); and

(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.

5. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.103 entitled

Preflight Action, subsection (b)(1) states the following:

in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning the flight, to include, "For any flight, runway lengths at airports of 

intended use, and the following takeoff and landing distance information:...For civil aircraft for which 

an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is 

required, the takeoff and landing distance data contained therein."

6. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.109 entitled

Flight Instruction; Simulated Instrument Flight and Certain Flight Tests, subsection (a) states 

the following:

No person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functional dual controls. However, instrument flight instruction 

may be given in an airplane that is equipped with a single , functioning throwover control wheel that 

controls the elevator and ailerons, in place of fixed, dual controls, when -...

7. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.119 entitled

Minimum Safe Altitudes: General, states the following:

in pertinent part, that except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes:

(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.

8. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.121 entitled

Altimeter Settings, subsection (a) states the following:

in pertinent part, that 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 -...
7

9. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.151(a) entitled

Fuel Requirements For Flights in VFR Conditions, subsection (a) states the following:

(a) in pertinent part, that 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.

10. DRONESTHATWORK, LLC Seeks Exemption From Section 91.203(a) and 91.203(b) entitled 

Civil Aircraft: Certifications Required, subsections (a) and (b) state the following:

(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. Each U.S. airworthiness certificate used 

to comply with this subparagraph (except a special flight permit, a copy of the applicable 

operations specifications issued under § 21.197(c) of this chapter, appropriate sections of 

the air carrier manual required by parts 121 and 135 of this chapter containing that portion 

of the operations specifications issued under § 21.197(c), or an authorization under 

§ 91.611 must have on it the registration number assigned to the aircraft under part 

47 of this chapter. However, the airworthiness certificate need not have on it an assigned 

special identification number before 10 days after the number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special identification 

number, that has been affixed to an aircraft, may only be obtained upon application 

to an FAA Flight Standards District Office ("FSDO").

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft registration Application as provided for in § 47.31(c), or a 

registration certification issued under the laws of a foreign country.

(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 in the cabin or cockpit 

entrance so it is legible to passengers and crew.

11. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.405(a)

entitled Maintenance, Preventive Maintenance, Alterations, subsection (a) states the 

following:

in pertinent part, that an aircraft operator or owner shall have the aircraft inspected as prescribed in 

subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of 

the same section, have discrepancies repaired as prescribed in Part 43 of the chapter.

12. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.407(a)(1) entitled 

Operation after Maintenance, preventive maintenance, rebuilding, or alteration, subsection (a) 

(1) states the following:
8

in pertinent part, any person from operating an aircraft that has undergone maintenance unless it has 

been approved for return to service by a person authorized under § 43.7 of the same chapter.

13. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.409(a)(2) entitled

Inspections, subsection (a)(2) states the following:

in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

14. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.417(a) and (b) 

entitled Maintenance Records, subsections (a) and (b) state the following:

(a) Each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include - (i) A description (or reference data acceptable to the Administrator) of the work performed: and 

(ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the 

person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revisions date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by § 43.9(d) of the chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or 

operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold.
9

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service.

15. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 27 entitled

Airworthiness Standards for Normal Category Rotorcraft, states the following:

(a) This part prescribes airworthiness standards for the issue of type certificates, and changes to those 

certificates, for normal category rotorcraft with maximum weights of 7,000 pounds or less and nine or 

less passenger seats.

C. The Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks The Relief.

1. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From 14 C.F.R. § 45.23(b).

Relief is requested because the LB700 UAV has no entrance to the cabin, cockpit, or pilot station on 

which the word "Experimental" can be placed. Further, two inch lettering would adversely affect the flight 

performance and safe operation of the UAV.

Equivalent Level of Safety

An equivalent level of safety will be assured by having the LB700 UAS marked "Experimental" along each 

side of the camera gimbal upper tube support structure in lettering as large as practicable which will 

prominently inform all parties of the unmanned aircraft's overall operating status.

2. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section 14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations: 

Pilot in Command.

Relief is requested because it is recognized that a certificated commercial pilot is required to meet 

statutory requirements to operate any aircraft in the NAS for commercial purposes or a private pilot 

certificate if "the flight is only incidental to the business or employment." Since the UAS is essential to 

performing the function of inspection of elevated structures, this exception does not apply. Accordingly, 

this petition seeks exemptions from the limitations of both § 61.113(a) & (b) in order that the LB700 UAS 

may be utilized for compensation and for hire when operated by a certificated private pilot.

Equivalent Level of Safety

An equivalent level of safety will be assured by having the UAS operator hold a current private pilot's 

certificate when acting as PIC. Because the UAS carries no pilot or passengers, the proposed operations 

can achieve the equivalent level of safety intended by § 61.113(a) & (b) when operating as specified in the 

petitioner's FOMM. The FOMM sets forth procedures to secure the area of flight operations such that no 

nonessential personnel may enter the exclusion zone while flights are being conducted.

3. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.7(a).

Relief is requested because the LB700 UAS will not be issued a valid airworthiness certificate under this 

exemption request.
10

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in accordance 

with the procedures detailed in the petitioner's FOMM. The DRONESTHATWORK, LLC lead pilot has 35 

years of experience building and maintaining fundamentally similar unmanned aircraft as well as 4 years 

of maintenance records specifically for the LB700 UAS.

4. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.9(b).

Relief is requested because the LB700 UAS weighs approximately twenty (20) pounds at is maximum 

gross weight and cannot carry the approved Rotorcraft Flight Manual onboard. Furthermore, since the 

LB700 UAS is unmanned, the flight crew members are located at the ground control station.

Equivalent Level of Safety

An equivalent level of safety will be assured by making the petitioner's approved FOMM available at the

ground control station, where it is immediately available for reference by the flight crew any time the 

LB700 UAS is being operated.

The approved FOMM will be made available within 7 days to any FAA, U.S. Department of Defense, 

Department of Homeland Security, or law enforcement official upon request.

5. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.103 entitled Preflight Action.

Relief is requested because the information that the PIC is required to review prior to flight operations, 

such as runway lengths and takeoff and landing distance data, do not apply to the operation of the LB700 

UAS unmanned rotorcraft. Further, the FOMM will not be kept on board the aircraft as noted in the 

petitioners request for relief from Section § 91.9(b) above.

Equivalent Level of Safety

An equivalent level of safety will be assured through strict adherence to the extensive preflight checklist 

detailed in the petitioner's FOMM. The PIC is responsible for performing all inspections and taking all 

actions required to assure that both the UAS and the operating environment are suitable for safe 

operations prior to launch.

6. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.109 entitled Flight Instruction.

Relief is requested because the LB700 is a remotely piloted unmanned rotorcraft and, as such, is 

not equipped with fully functional dual controls on board and carries no pilot or passengers. The 

UAS is instead operated by the PIC via a single RF command and control transmitter.

Equivalent Level of Safety

An equivalent level of safety will be assured through providing flight instruction using ground based 

master/slave RF command and control transmitters and performing training flights in a secure and sterile 

environment at least 500 feet away from any nonessential, non-participating personnel.
11

7. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.119 entitled Minimum Safe Altitudes:

Relief is requested because the primary purpose and advantage of the LB700 UAS is to perform 

close proximity inspections of elevated structures that cannot otherwise be safely accomplished 

using manned aircraft without risking damage to either the structure and/or the manned aircraft. 

The UAS will typically be positioned at a horizontal distance of approximately 25 feet from the 

structure being inspected, and so, will be typically operating closer than 500 feet from the

structure being inspected and, as such, will require an exemption to this requirement.

Equivalent Level of Safety

An equivalent level of safety will be assured due to the absence of flammable fuel, along with the 

inherent small size, weight and limited potential kinetic energy of the LB700 UAS. Utilization of a UAS 

for the purpose of close proximity structural inspections poses minimal risk of damage to the 

structures being inspected and other equipment on the ground surrounding the area of operations. In 

addition, strict adherence to the secure and sterile exclusion zone of operations, along with the collision 

avoidance procedures detailed in the petitioner's FOMM, assure that risk to persons and property on the 

ground are minimized.

As detailed in the petitioner's FOMM, flight operations will only be conducted on properties with 

written approval of the owner and/or authorized governing body. Considering the LB700 UAS will 

only be operated below 400 feet AGL, and within 25 feet from the structures being inspected, risks to 

manned aircraft is minimized. While a UAS is always required to yield to manned aircraft, conversely 

manned aircraft are advised to avoid the facilities to be inspected by the UAS under contract. Specifically, 

the FAA strongly advises that - "in the interest of national security and to the extent practicable, pilots 

are strongly advised to avoid the airspace above, or in proximity to, such sites as power plants (nuclear, 

hydro-electric, or coal), dams, refineries, industrial complexes, military facilities and other similar 

facilities."

DRONESTHATWORK, LLC's lead pilot, being a retired Electric Utility Manager, is intimately 

knowledgeable of NERC best practices and clearly understands how to operate the LB700 UAS in a 

manner that will not unduly risk the reliable operation of any bulk electric generating facility. 

It must be emphasized that large industrial complexes, and in particular, large bulk electric generating 

stations are inherently secure environments due to NERC requirements regarding national security. 

Considering this, the ability to control a secure flight operations perimeter is greatly enhanced when 

compared to any other public environment.

8. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.121(a) entitled Altimeter Settings: 

Relief is requested because the LB700 UAS is not equipped with a barometric altimeter than can 

be corrected to the elevation of the departure airport or barometric pressure. Rather, the LB700 

UAS will utilize either the GPS altitude indicator and/or the physical height of the structure being 

inspected as a reference not-to-exceed elevation.
12

Equivalent Level of Safety

An equivalent level of safety will be assured by following the process detailed in the petitioner's 

FOMM for altitude monitoring. The most accurate and reliable method is to verify the as-built 

elevation of the structure from final, approved construction drawings. Upon reaching the vertical limit of 

the structure of known height, the camera operator will alert the PIC to stop climbing and descend upon 

obtaining visual confirmation from the live video downlink that the top of the structure has been reached.

9. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.151(a) entitled Fuel Requirements for Flight in VFR Conditions:

Relief is requested because the LB700 UAS is battery powered with a flight duration of 

approximately 10 minutes and, as such, requires an exemption to the 30 minute reserve fuel 

requirement.

Equivalent Level of Safety

An equivalent level of safety will be assured by limiting all flights to 10 minutes or 25% remaining battery 

capacity, whichever occurs first. In addition, the petitioner's FOMM sets forth procedures to secure the 

area of flight operations such that no nonessential personnel may enter the exclusion zone while flights 

are being conducted.

10. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.203(a) and (b) entitled Civil Aircraft:

Relief is requested because the LB700 UAS is unmanned and, as such, has no cabin, cockpit, pilot station, 

or entrances thereto. Therefore, the flight crew member is located at the ground control station and no 

passengers are carried at any time. The petitioner has previously requested relief from the requirements 

of 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness in this submittal.

Equivalent Level of Safety

An equivalent level of safety will be assured by locating the required documentation at the ground control 

station, where it is immediately available to the flight crew member PIC of the LB700 UAS any time the 

unmanned aircraft is operating.

The documents specified must be made available within 7 days to any FAA, U.S. Department of Defense, 

Department of Homeland Security, or law enforcement official upon request.

11. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.405(a) entitled Maintenance, Preventive Maintenance, 

Alterations.

Relief is requested because the LB700 UAS will not be issued an FAA airworthiness type 

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in 

accordance with the procedures detailed in the petitioner's FOMM. The DRONESTHATWORK, LLC
13

lead pilot has 35 years of experience building and maintaining fundamentally similar 

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

12. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.407(a)(1) entitled Operation after Maintenance, preventive 

maintenance, rebuilding, or alteration.

Relief is requested because the LB700 UAS will not be issued an FAA airworthiness type 

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in 

accordance with the procedures detailed in the petitioner's FOMM. The DRONESTHATWORK, LLC

lead pilot has 35 years of experience building and maintaining fundamentally similar 

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

13. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91. 409(a)(2) entitled Inspections.

Relief is requested because the LB700 UAS will not be issued an FAA airworthiness type 

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in 

accordance with the procedures detailed in the petitioner's FOMM. The DRONESTHATWORK, LLC

lead pilot has 35 years of experience building and maintaining fundamentally similar 

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

14. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91. 417(a) and (b) entitled Maintenance Records.

Relief is requested because the LB700 UAS will not be issued an FAA airworthiness type 

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in 

accordance with the procedures detailed in the petitioner's FOMM. The DRONESTHATWORK, LLC

lead pilot has 35 years of experience building and maintaining fundamentally similar 

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

15. Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From 14 C.F.R. § 21.185.

Relief is requested from the airworthiness certificate requirements of the Federal Aviation 

Regulations. The petitioner proposes to commercially operate the LB700 UAS without an 

airworthiness certificate, for the special purpose of conducting inspections of elevated 

structures for the electric utility industry (or similar clients and uses). Flight operations will 
14

only be conducted on clients private property with approval, pursuant to specific operating 

limitations and a Flight Operations & Maintenance Manual ("FOMM"). DRONESTHATWORK, LLC

seeks relief from the airworthiness certificate requirements of 14 C.F.R. § 21.185 to the extent 

that the LB700 UAS, which has not been type certificated by the FAA, may be operated as if it 

were a restricted category aircraft for a single, defined, special purpose operation, specifically, 

(aerial inspection of elevated structures).

Equivalent Level of Safety

An equivalent level of safety will be assured because operation of the LB700 UAS will not create 

a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

Further, Section 333 provided the authority for such UAS to operate without airworthiness 

certification. Specifically, Section 333 states the following, in part:

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection 

(a), the Secretary, shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2)whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

The proven safe operational history of DRONESTHATWORK, LLC's. Lead Pilot over the past 35 years flying 

fundamentally similar unmanned rotorcraft, as well as the specific parameters of the 

DRONESTHATWORK, LLC's intended operation pursuant to this exemption, demonstrate that the LB700 

UAS can be operated in the NAS without creating a hazard to other aircraft or persons or property on the 

ground. All operations shall be performed in strict adherence to the provisions set forth in the 

DRONESTHATWORK, LLC's. Flight Operations & Maintenance Manual ("FOMM"). Accordingly, the FAA 

may approve the LB700 UAS , without an airworthiness certificate, by setting forth specific operating 

limitations to ensure a level of safety equivalent to what would be provided otherwise by airworthiness 

certification.

D. The Reasons Why Granting DRONESTHATWORK, LLC's Request Would Be In The Public 

Interest:

Granting the present Petition for Exemption will further the public interest by providing a much more 

thorough and comprehensive conditional assessment of aging electric utility infrastructure (or similar 

clients/uses). Utilities and other similar industries rely on accurate inspection data in order to make 

intelligent and timely run/repair/retire decisions of critical structures. The U.S. still relies heavily on fossil 

fuel powered electric generation to supply the country's energy needs. These plants were designed for a 

useful service life of 25 years on average. The vast majority have now significantly exceeded this milepost 

through the use of life extension programs and EPA mandated environmental upgrades. 
15

It is important that the large critical structures these plants rely on receive regular condition assessments 

in order to prevent catastrophic failures and potential lost generation. This is vital in order for utilities to 

continue to safely provide reliable energy to the nation's power grid and, consequently, enhance national 

security. Additionally, use of the LB700 UAS replaces the need to put the lives of ironworkers at high risk 

using rope access to provide an inspection that is far less thorough, yet more costly and hazardous to 

human life to perform. The LB700 can typically inspect 100% of the exterior of a large structure in one 

fourth the time required for a human to physically inspect 10% of the same area. 

E. PRIVACY

Flight operations will only be performed on private property with written consent of the owner or 

governing body. Since the sole purpose of each flight is to inspect a structure - gathering images of any 

other object, for any other purpose, is both unwarranted and unwanted.

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

DRONESTHATWORK, LLC seeks exemption from the requirements of part 21, subpart H: part 27 and 

Sections 45.23(b), 61.113(a) and (B), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of 14 C.F.R.. This exemption 

would permit DRONESTHATWORK, LLC to operate the LB700 Unmanned Aircraft System ("UAS") for the 

special purpose of performing aerial inspections of elevated structures for the electric utility industry (or 

similar clients/uses) while always operating under the core premise that ALL aviation related accidents are 

preventable. 

Utilities and other similar industries rely on accurate conditional assessments in order to make intelligent 

and timely run-repair-retire decisions of critical structures. This is vital and critical in order for utilities to 

continue to safely provide reliable energy to the nation's power grid and, consequently, enhance national 

security. Use of the LB700 UAS replaces the need to put the lives of ironworkers at risk by using rope 

access to provide an inspection that is far less thorough, yet more costly and hazardous to human 

life to perform. The LB700 can typically inspect 100% of the exterior of a large structure in one fourth

the time required for a human to physically inspect 10% of the same area. Additionally, the close 

proximity inspections proposed in this request cannot be safely performed using full size aircraft.

DRONESTHATWORK, LLC is uniquely qualified to perform this work as its lead pilot has 35 years 

experience as a professional in both designing, building, maintaining and piloting unmanned aircraft,

combined with 35 years experience inspecting and/or managing large-scale critical infrastructure 

inspections for one of the world's largest global electric utilities.

G. ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT DRONESTHATWORK, 

LLC'S REQUEST.

1. DRONESTHATWORK, LLC's Lead Pilot Has Been Safely Operating UAS's for 35 Years.
16

The skills required to become an FAI World Championship caliber unmanned aircraft pilot are 

considerable. They include spending thousands of hours designing, building, maintaining and 

remotely piloting aircraft at the highest possible level over many years. All of these skills are 

identical to those required to safely operate a UAS in an industrial environment. The LB700 UAS 

is fundamentally similar in design and performance to the remotely piloted aircraft flown by 

DRONESTHATWORK, LLC's Lead Pilot in aeromodeling competition for 22 years between 1980 to 

2002.

2. The Specifications Of The LB700 UAS Demonstrate Its Safe Characteristics.

The LB700 UAS does not create a hazard to users of the NAS or the public considering its size, 

weight, speed, and intended operation. Further, these same operational characteristics assures 

that its operation poses no threat to national security. The specifications of the LB700 are 

detailed within the FOMM submitted as part of this petition. 

Petitioner submits the FOMM manual as a confidential document under 14 C.F.R. 11.35(b) as 

the entire manual contains proprietary information that the petitioner has not and will not 

share with others. The manual contains non-public information and is protected from release 

under the Freedom of Information Act 5 USA 552 et.seq.

3. The secure and sterile flight operations zone maintained clear of all non-essential personnel.

Electric Generating Stations, for example, are typically very space-limited. Establishing large 500 

foot exclusion zones is not always practicable as it would shut down critical plant operations. A 

200 foot exclusion zone exceeds that used by 250 foot tall construction cranes making OSHA 

defined "critical lifts" of hundreds of tons. This distance is more than double the minimum 

distance spectators must be spaced away from an aerobatic flightline at an RC aerobatic event as 

sanctioned by the Academy of Model Aeronautics. This distance has been used for decades at 

thousands of AMA sanctioned events and has been proven reasonable for remotely piloted

aircraft of larger size performing aerobatic maneuvers. The petitioner's FOMM details 

administrative procedures for assuring the safety of persons and property on the ground while

employing a continuously monitored 200 foot exclusion zone for nonessential personnel.

CONCLUSION

DRONESTHATWORK, LLC lead pilot has literally accumulated a lifetime of practical experience in all

aspects of small unmanned aerial vehicles. While procedures and processes are critical components to 

safely operating a UAS in an industrial environment, experience and good judgment play equally 

important roles. In a rapidly growing industry, where the trends all point towards reliance upon "plug and 

play" technology, rather than demonstrated piloting skills and technical experience, DRONESTHATWORK, 

LLC believes that the airman's knowledge it has accumulated could prove beneficial to the FAA's efforts

going forward. 

DRONESTHATWORK, LLC has applied the principles of Stop Work Authority, Management of Change, 

Continuous Improvement and Near-Miss Tracking to great advantage with tangible results on safe UAS 

operations. DRONESTHATWORK, LLC would welcome the opportunity to share these processes,

procedures, operating data, or any other information, that is non-proprietary in nature, in an effort to 

advance the goal of safe integration of small commercial unmanned aerial systems into the NAS.