October 6, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., S.E.

Washington DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of FAA Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 

11, Aeroworks Productions, LLC. DBA Hardcore Drones, seeks an exemption from the Federal 

Aviation Regulations detailed below for the DJI Phantom 3 Professional, DJI Inspire 1, DJI 

Inspire Pro, DJI Matrice 100, Yuneec H920 Tornado, Yuneec Q500, 3DR X8, 3DR Solo, 3DR 

AERO, 3DR IRIS+, Aero-X and Aeryon Labs SkyRanger UAS. The largest of these systems, the 

Yuneec H920 Tornado, has a maximum gross takeoff weight of 11 lbs. All of the proposed UAS 

with the exception of the 3DR AERO are multi-rotor aircraft with electric propulsion. The 3DR 

AERO is a fixed wing aircraft and also powered by electric propulsion. These UAS are all 

commercially available platforms from DJI, 3DR and Yuneec, with a proven track record and 

have been approved for flights in the National Airspace under several different FAA Certificates 

of Authorization (COA).

Name and address of the applicant:

Aeroworks Productions, LLC. DBA Hardcore Drones

Adam Andrews

7740 29th Ave

Kenosha WI 53143

Phone: (262) 455-5135

E-mail: adam@aeroworksproductions.com

The requested exemption would allow Aeroworks Productions, LLC. DBA Hardcore Drones to 

pursue commercial interests in aerial data collection using small unmanned aircraft systems. 

The systems proposed will be used to conduct data gathering for agricultural applications, aerial 

inspections, mapping, surveying, R&D search and rescue, and product demonstrations. The 

team at Aeroworks Productions, LLC. DBA Hardcore Drones will operate in accordance with 

FAA N 8900.227 and utilize both a Pilot in Command and a ground-based visual observer. 

Aeroworks Productions, LLC. DBA Hardcore Drones will also utilize emergency, lost link, and 
lost communication procedures that are available upon request. All flights under these 

exemptions will be conducted with the following restrictions:

1. The sUAS will weigh less than 55 lbs.

2. Flight will be conducted within line of sight of a pilot/“operator” and/or observer.

3. Maximum total flight time for each operational flight will be 60 minutes. Flights will be 

terminated at 20% battery power reserve should that occur prior to the 60 min. limit.

4. Flights will be operated at an altitude of no more than 500 feet, the sUAS will not be 

operated more than 100’ above the highest point on the structure.

5. Minimum crew for each operation will consist of the sUAS pilot/“Operator” and the Visual 

Observer.

6. Flights will be operated at a lateral distance of at least 50 feet from any inhabited structures, 

buildings, vehicles, vessels or people not associated with the operation.

7. A safety briefing will be conducted in regard to the planned sUAS operations prior to each 

flight activity. It will be mandatory that all personnel involved with the operational duties of 

the flight be present for this briefing. 

8. The Pilot/“Operator” and observer will have been trained in operation of sUAS operations 

and received up-to-date information on the particular sUAS to be operated.

9. The Pilot/“Operator” will have a FAA pilots certificate and at least a Class 2 medical 

certificate.

10. Observer and Pilot/“Operator” will at all times be able to communicate by voice, radio and/or 

text.

11. Written and/or oral permission from the relevant property holders or property representatives 

will be obtained.

12. If the sUAS loses communications or loses its GPS signal, the sUAS will have the capability 

to return to a pre-determined location and land autonomously.

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather 

or emergencies.

The regulations from which the exemption is requested are as follows. The Appendix contains 

details of Aeroworks Productions, LLC. DBA Hardcore Drones operations related to showing an 

equivalent level of safety for these exempt regulations.

• 14 C.F.R. Part 21, Subpart H • 14 C.F.R. §91.203(a) and (b) • 14 C.F.R. §45.23(b)

• 14 C.F.R. §61.23(a)

• 14 C.F.R. §61.113(a) and (b) • 14 C.F.R. §61.133(a)

• 14 C.F.R. §91.7(a)

• 14 C.F.R. §91.9

• 14 C.F.R. §91.109(a)

• 14 C.F.R. §91.119

• 14 C.F.R. §91.121

• 14 C.F.R. §91.151(a)

• 14 C.F.R. Subpart E (§91.401 - §91.417)
UAS Overview

Aeroworks Productions, LLC DBA Hardcore Drones is submitting this request for exemption for 

the following sUAS aircraft:

DJI Phantom 3 Professional

DJI Inspire 1

DJI Inspire 1 Pro

DJI Matrice 100

Yuneec H920 Tornado

Yuneec Q500

3DR X8

3DR Solo

3DR Aero

3DR IRIS+ 

Aeryon Labs SkyRanger

Aero-X

The largest of these systems, the Yuneec H920 Tornado, has a maximum gross takeoff weight 

of 11 lbs. These commercially available systems from DJI, 3DR, Aeryon Labs and Yuneec have 

been shown to be reliable and have all been approved aircraft on other current exemptions. 

Aeroworks Productions, LLC DBA Hardcore Drones has expertise and knowledge in the 

operations of these systems. We will utilize training and operational procedures that follow the 

guidelines presented in N 8900.227.

Aeroworks Productions, LLC DBA Hardcore Drones is planning on using the proposed UAS to 

pursue further commercial applications. The proposed UAS are multi-rotor and fixed wing 

aircraft with electric propulsion. Aeroworks Productions, LLC DBA Hardcore Drones proposes 

that the small size and weight of the UAS included in this request for exemption, flown under the 

guidelines of N 8900.227, will have an equivalent level of safety to manned aircraft performing 

similar missions.

Public Interest

The petitioner, Aeroworks Productions, LLC. DBA Hardcore Drones, will be utilizing the 

proposed sUAS in a variety of applications that generally require expensive full-sized aircraft to 

complete. Small, light, unmanned aerial vehicles offer a myriad of benefits over the use of fullsized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced 

agriculture, film and still photography just to name a few. Replacing significantly larger manned 

aircraft carrying crew and flammable fuel with small UAS carrying no passengers, crew or 

flammable fuel, creates a much greater margin of safety for the pilots and crew. By granting the 

petitioners requested exemptions, the FAA will help drive development of safe and successful 

commercial UAS operations and will advance the public knowledge base for such operations. 

Petitioners is committed to sharing data from its commercial UAS operations and serving as a 

resource for future UAS research operations. Thus the FAA a good cause to grant this petition.
Additional Information

The fact that Aeroworks Productions, LLC pilots hold FAA pilot certificates demonstrates that 

they have a high regard to safe operations with an understanding of FAR’s, pre-flight 

inspections, maintenance and repair, operations within airspace as well as being trained to high 

safety standards. Under the requested exemption, Aeroworks Productions, LLC. DBA Hardcore 

Drones, insures that all operators have completed a small unmanned aircraft systems (sUAS) 

education and training program including all applicable regulations and guidance documents; 

including aeronautical background information such as charts, NOTAM’s and aircraft circulars, 

radio communications and procedures, human factors and crew resource management, basic 

small UAS aerodynamics, weather factors, airmanship and decision making and safe operating 

procedures.

Aeroworks Productions, LLC DBA Hardcore Drones requests an exemption under Section 333 

to enable safe commercial UAS operations for the activities stated. By approving these 

exemptions the FAA will create benefits to the areas mentioned that is ultimately in the public 

interest. Please contact us if you require additional information or clarification.

Best Regards,

Adam Andrews

Director of Operations

Aeroworks Productions, LLC

DBA Hardcore Drones

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Aeroworks Productions, LLC. requests an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the sUAS System:

 

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the DJI Inspire 1, DJI Phantom 3, DJI Matrice 

100, DJI Inspire 1 Pro, Yuneec H920 Tornado, Yuneec Q500, Aeryon Labs Sky Ranger, 3DR 

X-8, 3DR IRIS+, 3DR AERO, 3DR Solo and Aeroworks Aero-X sUAS under either or both of the 

following provisions: 

21.191 Experimental certificates

Experimental certificates are issued for the following purposes: 

(a) Research and development, Testing new aircraft design concepts, new aircraft, equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) 

Showing compliance with regulations Conducting flight tests and other operations 

to show compliance with the airworthiness regulations including flights to show compliance for 

issuance of type and supplemental type certificates, flights to substantiate major design 

changes, and flights to show compliance with the function and reliability requirements of the 

regulations. Since the experimental certificate can be used for commercial purposes
such as market surveys, sales demonstrations, and customer crew training, we would expect 

that an experimental certificate would permit our commercial purpose as well. The aircraft will 

not carry persons or property, will not carry fuel, and will only fly under strict operational 

requirements. Combined with the UA's light weight, being constructed primarily of foam, carbon 

fiber, and/or plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an experimental 

airworthiness certificate is not appropriate for this application, then we request an exemption of 

14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, 

citing the equivalent level of safety outlined in the previous paragraph.

 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

“EXPERIMENTAL” in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on 

the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the 

aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's 

registration information at the ground station. Finally, we will display at the ground station a high 

contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 

inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the 

banner should be visible to anyone that observes the aircraft and chooses to investigate its 

point of origin. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in 

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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. Our proposed operations require that the PIC 

must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot 

carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct a business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation; the 

documentation would not be available to the crew during flight operations. To obtain an 

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved 
sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is 

in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The sUAS System ground 

based control station consists of a small hand-held radio transmitter and while it does not offer a 

second set of "controls", both the student and instructor can, and will, operate the single set of 

controls simultaneously. With both student and instructor having "hands-on" the controls during 

flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of 

safety. 

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of 

persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to 

the items listed. Operations will only be flown over property or persons where permission has 

been obtained and careful pre-planned has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore we maintain that due to the small size of the UAS, 

the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which 

should be considered in granting the exemption.

 

14 CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft. The sUAS will always fly below 500 feet AGL and 

will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An 

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio 

from the sUAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAS are battery operated and the 

maximum duration of flight from a single battery charge is 12-45 (depending on which sUAS) 

minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". We also request exemption from the 30 min 

reserve and ask that our reserve will be to fly the mission to the point of intended landing and 

have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required 

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew." With our largest vehicle, the Yuneec H920 
Tornado, at a maximum gross weight of 11 pounds, the sUAS is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at 

the ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." The 

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, 

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC 

is limited to repairing small cracks, replacing a propeller, checking electrical connections and 

updating software and firmware for the on-board computer. All other maintenance will be 

performed by the manufacturer or their designated repair facility. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity 

of the aircraft, the PIC can ensure an equivalent level of safety.