To: Federal Aviation Administration

From: Innovative Airworks, LLC

Subj: Section 333 Exemption Request, Docket (No. FAA-2015-0663)

To whom it may concern,

The following letter is in response to a notice that Innovative Airworks, LLC 

received in regards to its Section 333 exemption request. The notice stated that the 

FAA could not further process my request until three (3) bulleted subjects were further 

explained. They were public interest, equivalent level of safety, and additional 

information. The information is explained below.

PUBLIC INTEREST

Approval of exemptions allowing Innovative Airworks, LLC to commercially

operate UAV’s for training enhances safety while reducing risk. New untrained UAV 

operators create a greater risk because they do not have to knowledge or ability to fly 

safe missions, adhere to best safety practices (BSP’s), and typically have little or no 

knowledge of the National Airspace System. Properly training new UAV operators with a 

structured curriculum will greatly benefit the public by drastically reducing UAV 

accidents that pose a threat to life safety and property. 

EQUIVALENT LEVEL OF SAFETY

Innovative Airworks, LLC proposes that the exemption requested herein apply to 

civil aircraft that have the characteristics and that operate within the limitations listed 

herein. These limitations provide for at least an equivalent or even higher level of safety 

to operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe protocols followed by flight 

instruction operations conducted with helicopters and other conventional aircraft.

Innovative Airworks, LLC will be bound by the following limitations when conducting its 

UAV operations under an FAA issued exemption:

1. The UAV will weigh less than nine (9) pounds.
2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 150 minutes. Flights will 

be terminated at 20% battery power reserve should that occur prior to the 150 minute 

limit.

4. Flights will be operated at an altitude of no more than 500 feet AGL. 

5. Flight operations will be conducted 5 miles from an airport and at least 3 miles from 

any city or densely populated area, which are depicted in yellow on VFR sectional 

charts.

6. Flight operations within 5 miles of an airport require notification and approval from the 

local Flight Standards District Office and airport controller.

7. Flight operations will occur during daylight hours and under visual meteorological 

conditions only.

8. Minimum crew for each operation will consist of the UAV pilot and visual observer.

9. The UAV instructor pilot will be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical.

10. The pilot and visual observer will have been trained in the operation of the UAV.

11. The pilot and visual observer will at all times be able to communicate by voice 

and/or text.

12. Flight operations will be conducted at least 500 feet from all non-participating 

persons, vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect non-participating persons

from debris in the event of an accident. The pilot will ensure that non-participating 

persons remain under such protection. If a situation arises where non-participating 

persons leave such protection and are within 500 feet of the UAV, flight operations will 

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land

owner/controller has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and;

c. Operations near the pilot or visual observer do not present an undue hazard to the 

pilot or visual observer.

15. If the UAV loses communication or loses its GPS signal, the UAV will have the 

capability to return to a safe, pre-determined location and land.
16. The UAV will have the capability to abort flight in case of emergencies. 

ADDITIONAL INFORMATION

It is the goal of Innovative Airworks, LLC to provide a safe and structured 

environment for new and experienced UAV operators to train in. Innovative Airworks, 

LLC will train UAV pilots on various areas of UAV operations. Best safe practices, safe 

UAV flying technics, knowledge of Federal Aviation Regulations and the National 

Airspace System are some of the items that will be taught to the new operators. Initial 

UAV flight training will use the DJI Innovations Phantom 1. Innovative Airworks, LLC 

already has one Phantom 1 registered aircraft (N554NS) and is in negotiations to 

purchase nine more. John King, the owner of Innovative Airworks, is a FAA certified, 

instrument rated, commercial pilot and has over five years of experience of building and 

flying UAVs. 

Let’s face it, any man or woman can go online and buy a UAV for a few hundred 

dollars and have it shipped to their home. Once it has arrived, they can remove it from 

the box and usually start it right up. Next thing you know, they are flying it three 

thousand feet in the air in the possible flight path of a manned aircraft. We cannot let 

that happen!! It is our responsibility to ensure that new UAV operators know the laws 

and know how to fly safe.

Thank you for your consideration.

Regards,

/s/

John King

Innovative Airworks, LLC