May 8, 2015 

 Exemption No. 11514 

 Regulatory Docket No. FAA–2015–0468 

Mr. Luis Cardenas 

DroneWorks, Inc. 

3400 Powerline Road 

Oakland Park, FL 33309 

Dear Mr. Cardenas: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter dated February 17, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of DroneWorks, Inc. (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct precision aerial surveys and photography. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner is a DroneWorks i1. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
2 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, DroneWorks, Inc. is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, DroneWorks, Inc. is hereafter referred to as the operator. 
3 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DroneWorks 

i1when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption. 

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). The 

exemption holder may use either groundspeed or calibrated airspeed 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. 

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. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, 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 
4 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this 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 under this exemption. 

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 exemption 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, 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 exemption, 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 
5 

(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 exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building 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 exemption 

holder. 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. 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. 

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

20. 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. 

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

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. 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. 
6 

23. 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. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. 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. 

27. 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. 

28. 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. 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

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

as documented in this grant of exemption. 
7 

30. 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; 

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. 

31. 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 

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, 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. 

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 
February 17, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and

Part 11 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”) 

and 14 C.F.R. Part 11, Luis Cardenas of (“DroneWorks”), Owner and operator of the i1

Unmanned Aircraft System (“UAS” or “i1”), seeks an exemption from the Federal

Aviation Regulations (“FARs”) listed below and discussed in Appendix A.

1 Attached as

Appendix B is a summary of this request.

The requested exemption would permit commercial operation of DroneWorks’ UAS, which weighs

5.5 lbs. and performs precision aerial surveys that consist of still photographs taken by onboard 

cameras. The i1 takes a series of high quality, still digital images that are used to produce

precision digital point clouds, triangulated models, and contour maps of the surveyed area.

Applications for these UAS devices and associated data processing functions include 

agriculture, mining, and professional surveying. Use of the UAS for aerial surveys reduces the 

need to operate conventional aircraft for the same purpose and provides high quality imagery

at a fraction of the cost of surveys using conventional aircraft. These savings result in 

enhanced efficiency and productivity for the affected activities, as well as environmental 

benefits.

2

1 See Pub. Law 112-95, 126 Stat. 11, § 333 (2012) 2 See, e.g. Jack Nicas, Drones Find Fans Among Farmers, Filmmakers, WALL STREET

JOURNAL (March 10, 2014, 7:45 PM) (describing how an overseas surveyor used to spend

25,000 Euro ($34,345) to survey 15 square kilometers with a team of 12 surveyors, and it would 

take 2 to 3 weeks to collect all the data. With a DroneWorks i1, he accomplished the same task

for 5,000 Euro and got all the data he needed in 3 to 4 days. Because the surveys cost him less

to perform, he passes those savings on to his customers.), available at:

http://online.wsj.com/news/articles/SB10001424052702304732804579425342990070808.
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Operations under the exemption will be subject to strict operating requirements and conditions 

to ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333.

3

As described more fully below, the requested exemption would authorize commercial operations 

of aerial surveys using the i1, which at 5.5 lbs. is small in size.

4 The i1 will be operated under

controlled conditions at low altitude in airspace that is limited in scope, as described more fully

herein; it will have automated control features, as described below. The i1 also will be operated

by an individual who has passed an FAA approved ground training exam and a required

manufacturer’s training program for the UAS. Finally, the airspace in which the UAS

will operate will be disclosed to the FAA in advanced.

DroneWorks respectfully submits that because this small, unmanned aerial vehicle—will

be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary 

conventional aircraft, the FAA can have confidence that the operations will achieve at least an

equivalent level or greater level of safety. 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: 

Attn: Luis Cardenas

Ph: 754-234-7813

Email: Luroyale@gmail.com

Address: 3400 Powerline Road

Oakland Park, Florida 33309

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(b);

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

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

14 C.F.R. 91.119;

3 While DroneWorks is filing this exemption request on its own behalf, it anticipates that its 

customers, in the future, will file exemption applications to allow them to operate the i1 in 

commercial operations at their own facilities, farms, mines, and other sites that require precision 

surveys. Those filings will be substantially similar to this exemption application.

4 DroneWorks expects to receive a Special Airworthiness Certificate (Experimental) for the i1 

as the result of the application it filed on February 17, 2015.
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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.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

DroneWorks submits that grant of this exemption application for use of the i1 in precision aerial 

surveys will advance the Congressional mandate in Section 333 of the Reform Act to accelerate

the introduction of UASs into the national airspace system (“NAS”) if it can be accomplished 

safely. This law directs the Secretary of Transportation to consider whether certain UASs may 

operate safely in the NAS before completion of the rulemaking required under Section 332 of

the Reform Act. In making this determination, the Secretary is required to determine which 

types of UASs do not create a hazard to users of the NAS or the public or pose a threat to 

national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system.” Id. §333(c) (emphasis added).

5

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections

5 Applicant submits that this provision places a duty on the Administrator to not only process 

applications for exemptions under Section 333, but for the Administrator, if he deems the 

conditions proposed herein require modification in order to allow approval, to supply conditions

for the safe operation of the UAS. DroneWorks welcomes the opportunity to consult with FAA

staff in order to address any issues or concerns that this proposal may raise that they believe

may require modification.
Exhibit 4 and also being submitted on a confidential basis.

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44702-44716 of this title if the Administrator finds the exemption is in the 

public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). 

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended;

the strong equivalent level of safety surrounding the proposed operations; and the significant 

public benefit, including enhanced safety and cost savings associated with transitioning to UASs 

for aerial survey photography. Accordingly, the applicant respectfully requests that the FAA 

grant the requested exemption without delay.

Mandatory Operating Conditions

Grant of the exemption to DroneWorks will be subject to the following mandatory conditions,

which are based upon operating conditions set forth for operation of UAS by public entities

pursuant to Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR

charts.

• Operations to be conducted over private or controlled-access property.

• Permission from land owner/controller required before commencing any flight.

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical 

miles (NM).

o Cylinder walls may be expanded by observer with ability to control aircraft.

• Operations to occur during daylight hours.

6 DroneWorks is submitting under a request for confidentiality the following documents in

support of this exemption application for the i1: 1) Safety Checklist (Exhibit 1); 2) Training

Manual (Exhibit 2); and 3) Maintenance & Inspection Manual for the i1 (Exhibit 3). DroneWorks

submitted these documents on a confidential basis to the FAA as part of the SAC application

process under Part 21. See also “User Guide – DroneWorks i1 Aerial Imaging Solution,” 

attached as Exhibit 4 and also being submitted on a confidential basis
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• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds.

• Operator will file a NOTAM for each flight.

• All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies.

Operator Requirements

DroneWorks respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. Certain UASs, such as the DroneWorks i1, are 

characterized by a high degree of pre-programmed control and various built-in technical 

capabilities that limit the potential for operation outside of the operating conditions set forth 

above.

The i1 has a semi-autonomous navigation and control system comprised of a Ground Control 

Station (GCS) and auto-pilot system. All flights are pre-programmed with GPS guidance and do 

not require human intervention. Flight mission area and routing can be changed after

launch. Flights can be directed by positive manual control, as well as evasive maneuvers. In

the case of unplanned events, the operator inputs evasive maneuvers from the control unit and

the control unit executes that maneuver. Pre-programmed operator interventions also include

diversion to the right; initiation of holding at present position; suspension of mission; fly back to

launch point; fly to point and hold; abort mission and land; and emergency power cut off and

land (Flight Termination System).

7

Additional automated safety functions and safety enhancing features of the i1 include the 

following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate 

spiral landing.

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels.

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, auto 

pilot-return to home procedure begins.

• Aircraft has an on-board failsafe that limits speed in the event of dive to 

approximately 14 m/s.

7 DroneWorks staff have performed over 1,245 flights, logging more than 200 hours of flight 

time with the predecessor of the i1, the PV2. Development of the i1 included 100 early 

demo/beta flights. These flights amounted to about 25 hours. There have been about 300 

training flights for the i1, totaling about 75 hours. DroneWorks does not keep data on flights

conducted by customers, but they are estimated to have reached well over 1,000 hours.
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• The aircraft, weighing less than 6 lbs., fully loaded, is constructed of Carbon Fiber,

or similar material to keep the craft as light as possible.

8

• The motor is driven by a pulse width modulated signal, not an analog signal.

Given these safety features, DroneWorks proposes that operators of the i1 should not be

required to hold a commercial or private pilot certification. Instead, operators should be

required to:

• have successfully completed, at a minimum, FAA private pilot ground instruction 

and passed the FAA Private Pilot written examination or FAA-recognized 

equivalents;

• have completed the manufacturer’s training program for operation of the UAS. The 

manufacturer’s training program will have been satisfactorily reviewed through the 

SAC process.

DroneWorks notes that the FAA has found that safety factors permitted operation of UASs by 

operators with these qualifications in the case of operations pursuant to public COAs when the 

mandatory operating conditions specified above were present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the 

requirements for and privileges associated with the grant of airmen’s certificates. 49 USC

§44701 (f).

* * *

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of a small unmanned vehicle conducting precision aerial surveys.

Approval of the exemption allowing commercial operations of the i1 for precision survey work 

will enhance safety by reducing risk. Conventional aerial survey operations, using jet or

piston-powered aircraft present risks associated with vehicles that weigh in the neighborhood of

5,000 to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in some cases, 

cargo. Such aircraft must fly to and from the survey location. In contrast, a i1 weighing less

than 6 lbs. and powered by batteries eliminates a portion of that risk given the reduced mass

and lack of combustible fuel carried on board. The i1 is carried to the survey location, not 

flown there. The i1 will carry no passengers or crew and, therefore, will not expose any

individuals to the risks associated with manned aircraft flights.

Additionally, no national security issue is raised by the grant of the requested exemptions. 

Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no 

explosives or other dangerous materials, the i1 poses no threat to national security.

8 DroneWorks has calculated the potential energy in flying the i1. Based on a maximum speed

in descent of 2m/s built into the autopilot and the i1’s mass of 5.5lbs, these calculations yield

300 Joules of energy. Applying the Canadian regulatory standard of energy/area, the i1 is 

calculated to be 5.9 J/cm2. Canada is proposing to apply no regulation to a UAS below 15

J/cm2.
The operation of the i1, weighing less than 6 lbs., for precision surveys in

accordance with the strict conditions outlined above, will provide an equivalent level 

of safety supporting the

grant of the exemptions requested herein, including exempting DroneWorks from the

requirements of

Part 21.

The i1’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size,

weight, speed, operating capabilities, lack of proximity to airports and populated areas,

operation within visual line of sight, and national security—and its showing of an

equivalent level of safety as it may relate to the requirement for a pilot’s license, 

provide more than adequate justification for the grant of the requested exemptions

allowing commercial operation of the i1 in the commercial precision aerial survey

business.

Very

truly

yours,

 Luis Cardenas

.

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

DroneWorks requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of the i1:

14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:

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.

The i1 has no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” 

can be placed. Given the size of the UAV, two-inch lettering will be impossible. The word 

“Experimental” will be placed on the forward fuselage in compliance with § 45.29(f).

The equivalent level of safety will be achieved by having the i1 marked on its forward 

fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV 

will see the identification of the UAS as “Experimental.” The FAA has issued the following 
exemptions to this regulation to DroneWorks. Exemption No. 10700, and to others, including

Exemption Nos. 8738, 10167 and 10167A.

14 C.F.R. 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 (5.5lbs.) 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 i1 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 i1
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weighs less than 6 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 i1 construction with absorbent material provides at

least an equivalent 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 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the i1 in this case is remotely controlled with

no passengers or property of others on board. Section 61.133(a) requires an individual with a

commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. 

DroineWorks respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. DroneWorks’ i1 has a high degree of pre-programmed 

control and various built-in technical capabilities that strictly limit the potential for operation 

outside of the operating conditions set forth in the exemption application.

The i1 has a semi-autonomous navigation and control system comprised of a Ground Control 

Station (GCS) and auto-pilot system. All flights can pre-programmed with precision GPS 

guidance and do not require human intervention. Flight mission area and routing can be 

changed after launch. In the case of unplanned events, the operator inputs evasive maneuvers

from the control unit, and the control unit executes that maneuver. Pre-programmed operator

interventions include diversion to the right; initiation of holding at present position; suspension of

mission; fly back to launch point; fly to point and hold; abort mission and land;

and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the i1 include the 

following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate 

spiral landing.

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels.

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing 

procedure begins.

• Aircraft has an on-board failsafe that limits speed in the event of dive to 

approximately 2m/s.

• The aircraft, weighing less than 6 lbs., fully loaded, is constructed of Carbon Fiber 

or similar material
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• The motor is driven by a pulse width modulated signal, not an analog signal.

Given these safety features, DroneWorks proposes that operators of the i1 should not be

required to hold a commercial or private pilot certification. Instead, operators should be

required to:

• have successfully completed, at a minimum, FAA private pilot ground instruction 

and passed the FAA Private Pilot written examination or FAA-recognized 

equivalents;

• have completed the manufacturer’s training program for operation of the UAS. The 

manufacturer’s training program will have been satisfactorily reviewed through the 

SAC process.

DroneWorks notes that the FAA has found that safety factors permitted operation of UASs by 

operators with these qualifications in the case of operations pursuant to public COAs where the 

mandatory operating conditions specified above are present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to 

waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the i1

without a private pilot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the i1 (given its size, speed, operational capabilities,

and lack of combustible fuel) are so diminished from the level of risk associated with private

pilot operations or commercial operations contemplated by Part 61 with conventional aircraft 

(fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or 

exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not 

rise to the level of requiring a commercial pilot to operate the aircraft under

§ 61.133(a).

14 C.F.R. § 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 the i1 without an

airworthiness certificate, no standard will exist for airworthiness of the i1. Given the size of the

aircraft and the requirements that have presumably already been met in the SAC approval 

process for the i1 (for instance, the I1’s Maintenance & Inspection Manual and Safety Checklist), 

an equivalent level of safety will be achieved by insuring compliance with the DroneWorks

manuals prior to each flight.
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14 C.F.R. § 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 and configuration of the i1, it has 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 (see, e.g., User 

Guide, Exhibit 4) at the ground control point where the pilot flying the UAS will have immediate 

access to it. The FAA has issued to DroneWorks and others the following exemptions to this 

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,

10602, 32827, and 10700.

14 C.F.R. § 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 i1 is a remotely piloted aircraft and by design, has 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 can be pre-programmed into the auto pilot 

before flight and only in unusual circumstances will the pilot input control functions to alter the 

pre-programmed flight. If instruction is accomplished through a training program, as set forth in 

Exhibit 2, an equivalent level of safety will be assured. 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. The equivalent level 

of safety will be achieved by the manufacturer providing the training as outlined, for example, in

Exhibit 2 and through the use of experienced and qualified pilots familiar with the i1.

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.

As set forth herein, the i1 will never operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional
charts. Because aerial survey 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 the i1 is 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 survey flights. Compared to aerial survey operations conducted 

with aircraft or rotorcraft weighing far more than 5.5 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 small-UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. § 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 i1 batteries provide approximately 30 minutes of powered flight. Without an exemption from

§ 14 CFR 91.151, the UAS’s flights would be limited to approximately 20 minutes in length. 

Given the limitations on its proposed operations and the location of those proposed operations,

a longer time frame for flight in daylight VFR conditions is reasonable.

DroneWorks 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 small 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. Additionally, limiting i1 flights to 20 minutes would greatly reduce their

utility. In the unlikely event that the i1 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.

DroneWorks believes that an equivalent level of safety can be achieved by maintaining 10

minutes of reserve fuel, which, allowing 30 minutes of flight time, would be more than adequate

to return the UAS to its planned landing zone from anywhere in its operating area.

14 C.F.R. § 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 i1 fully loaded weighs no more than 6 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 C.F.R. § 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.

Maintenance of the i1 will be accomplished by the owner/operator pursuant to the manuals, 

such as Exhibit 3, provided by DroneWorks. 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. As provided in the attached 

Maintenance Manual and the Safety Checklist, the operator of i1 will ensure that the UAS 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.

APPENDIX B 

SUMMARY OF DRONEWORKS SECTION 333 EXEMPTION REQUEST

DroneWorks hereby provides pursuant to Part 11 a summary of its exemption

application to allow commercial operation of the i1 unmanned aircraft in precision aerial 

survey work. 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(b);

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

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

14 C.F.R. 91.119;

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).