City of Shafter, UAV Petition for Exemption

U.S. Department of Transportation 

Docket Management System David Dow 

1200 New Jersey Avenue, SE GIS Analyst 

Washington, D.C. 20590 CITY OF SHAFTER 

 336 Pacific Ave. 

 Shafter, CA 93263 

 

BASIS FOR PETITION 

Petitioner, CITY OF SHAFTER , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) 

and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1, in the National Airspace System 

(NAS), and for an exemption from the requirements of :

14 C.F.R §§ 61.113(a) & (b) 

14 CFR 45.23(b) 

91.7(a), 

91.121, 

91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91 

Name and Address of the Petitioner 

The name and address of the Petitioner and point of contact is:

David Dow

GIS Coordinator

CITY OF SHAFTER

336 Pacific Ave. 

Shafter, CA 93263

OFFICE: (661)746-5000

Email: ddow@Shafter.com

PREFACE:

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, that includes UAS, from the 

requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any sections 44702 - 44716 of this title if the Administrator finds the exemption 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). 
City of Shafter, UAV Petition for Exemption

The CITY OF SHAFTER proposes to use one or more Unmanned Aerial Drones (DJI Inspire 1), for the following 

uses:

 Inspections of city-owned stormwater canal system

 Inspections of city-owned road rights of way

 Periodic inspections of city-funded infrastructure improvement projects

 Bridge inspections

 Aerial Photography for incorporation into a Citywide Geographic Information System (GIS)

 Aerial Photography and Videography for the creation of city promotional materials. 

 Assist with damage assessments or situational status reports during emergency response operations

 Evaluations within the city related to flora & fauna (vegetation & wildlife) issues.

 Support to law enforcement and fire departments during response operations.

 Assist with site security during city-sponsored events (ie. 4th of July, New Years, parades, etc.)

This aircraft has four rotors and four motors in a quadcopter configuration (X4). It is only capable of vertical 

takeoff and landings. This UAS weighs less than 55 lbs. including payload, can fly, under normal conditions at a speed of 

no more than 45 knots and has the capability to hover, and move in the vertical and horizontal plane simultaneously. 

This UAS is equipped with GPS and auto-return function to the predetermined safe landing area as well as allowing 

reading of magnetic interference that can cause loss off GPS signal. The UAS will operate only in line of sight and will 

operate only within the limits of city owned property, public rights of way, and public easements, or over private 

property with the express permission of the property owner. Such operations will be conducted to insure that the UAS 

will “not create a hazard to users of the national airspace system or the public.” (Reform Act Section 333 (b)).

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of 

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 

333 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). 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).

 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, that includes UAS, from the 

requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any sections 44702 - 44716 of this title if the Administrator finds the exemption 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).

RELIEF OVERVIEW 
City of Shafter, UAV Petition for Exemption

 Given the small size of the UAS involved and the restricted environment within which they will operate, the applicant 

falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the 

restricted areas in which the relevant UAS will operate, approval of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained 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, reduction in environmental impacts, including reduced emissions associated with allowing 

UASs for aerial inspections, surveying, photography and videography, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption.

 AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

CITY OF SHAFTER proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with 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 aerial inspections, surveying and photography and videography

operations conducted with conventional aircraft.

These limitations and conditions to which CITY OF SHAFTER agrees to be bound when conducting commercial 

operations under an FAA issued exemption include:

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a Pilot-In Command (PIC) and a Safety Observer (SO).

3. Maximum total flight time for each operational flight will be 30 minutes or less. Flights will be terminated at 25% 

battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated 

platform for which filming is planned.

5. Minimum crew for each operation will consist of the UAS Pilot and one Visual Observer.

6. The UAS will only operate within the defined project area, the boundaries of which will be determined by the UAS 

Pilot-In-Command (PIC) based on the site-specific activities and speed of the UAS required for the operation, and 

coordinated with the jurisdictional FAA FSDO and local government officials as applicable.

7. A briefing will be conducted in regards to the planned UAS operations prior to each day’s operation. It will be 

mandatory that all personnel who will be performing duties within the boundaries of the project be present for this

briefing.

8. The UAS Pilot and Safety Observer will be able to communicate by voice and/or two way radio communication 

system at all times.

9. The operations of the UAS will be limited to daylight-only operations.

10. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a predetermined location within the Project Perimeter and land safely.

11. The UAS will have the capability to abort flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

 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 and limited operating area associated with 

the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an 
City of Shafter, UAV Petition for Exemption

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

(f)) 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 particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as 

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without 

the restrictions and conditions proposed.

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

its operation, the CITY OF SHAFTER’s operation of DJI Inspire 1, UAS meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, the CITY OF SHAFTER requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an 

airworthiness certificate. CITY OF SHAFTER submits that the requested relief is proper since an equivalent level of safety 

will be ensured. CITY OF SHAFTER will use experienced personnel or technicians as needed to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, CITY OF 

SHAFTER will document and maintain all maintenance records for the DJI Inspire 1 UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: 

Pilot in command, is requested by CITY OF SHAFTER to the extent necessary to allow a Pilot in Command (PIC) meet or 

exceed the described requirements of operations set by manufacturer, and who has demonstrated, that the PIC is able 

to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

CITY OF SHAFTER seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, CITY OF 

SHAFTER submits that he will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by 

determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. 

CITY OF SHAFTER also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, 

as the DJI Inspire 1 will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 

1 will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, 

combined with CITY OF SHAFTER’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, 

will ensure a level of safety equivalent to Section 91.121. 

Additionally, CITY OF SHAFTER seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. CITY OF SHAFTER submits that safety will not be affected by operation of the 

DJI Inspire 1 during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power to fly for a total duration of approximately 30 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

 

EXTENT AND REASONING WHY CITY OF SHAFTER SEEKS RELIEF FROM THE LISTED SECTIONS ABOVE: 

1. Section 61.113(a) & b). 
City of Shafter, UAV Petition for Exemption

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is 

requested to the extent necessary to allow a PIC meet all requirements as described in the DJI Inspire 1 owner’s manual

to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, 

for compensation or hire, act as PIC 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. 

As set forth more fully below, CITY OF SHAFTER submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated that the PIC is able to 

safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures.

Further, CITY OF SHAFTER submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the 

grant of this Petition: (1) will be incidental to CITY OF SHAFTER’s business; and (2) will not carry passengers or property 

for compensation or hire. 

2. 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow CITY 

OF SHAFTER to determine that the DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents (i.e., the CITY OF SHAFTER Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). 

CITY OF SHAFTER seeks the requested relief because the DJI Inspire 1 UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, CITY OF SHAFTER will ensure that the DJI Inspire 1

UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance 

Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition 

for safe flight, as stated in the conditions and limitations below.

3. 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI 

Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires 

that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground 

level (AGL), CITY OF SHAFTER seeks the requested relief because the DJI Inspire 1 UA altimeter may be set on the ground 

to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent 

necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an 

equivalent level of safety will be maintained since the DJI Inspire 1 UA are equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS. 

4. 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent 

required to allow flights of the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 25 minutes to the first point of intended landing and, 
City of Shafter, UAV Petition for Exemption

assuming normal cruising speed, to fly after that for at least 5 minutes. CITY OF SHAFTER seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA

will severely constrain the practicality of any aerial video or still photo flight operations that CITY OF SHAFTER proposes 

to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating 

documents, and CITY OF SHAFTER ‘s proposed operating limitations, ensure that CITY OF SHAFTER will safely operate the 

battery powered DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration of 25 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

14 CFR 45.23(b) 

Marking of the Aircraft;

Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. UAV 

Field Services UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft. 

Regardless, UAV Field Services will mark its UAS in the largest possible lettering by placing the "N "number on its 

fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working with the UAV will 

see the markings. The FAA has previously issued exemptions to this regulation through- Exemption No 10167 and 

10700 

5. 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an 

airworthiness certificate, CITY OF SHAFTER requests relief from these Sections because the DJI Inspire 1 UAS do not 

require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly CITY OF SHAFTER will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the CITY OF SHAFTER aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, CITY OF SHAFTER will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

 

The Reasons for granting this request are entirely beneficial to the public and community as a whole. 

Granting the present Petition will further the public interest by allowing CITY OF SHAFTER to safely, efficiently, 

and economically perform aerial video and photographic surveys and inspections of construction sites, rights of way, 

utility easements, and other sites within the CITY OF SHAFTER, California. 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of 

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 

332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS 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.
City of Shafter, UAV Petition for Exemption

Reform Act § 333 (a). Lastly, id. 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).

 Given the small size of the UAS involved and the restricted sterile environment within which they will operate, the 

applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the 

FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the 

UASs and the restricted areas in which the relevant UAS will operate, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained 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, reduction in environmental impacts, including reduced emissions associated with 

allowing UASs for movie and television operations, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

 

REASONS BENEFICIAL TO THE PUBLIC/COMMUNITY 

1. The Public Will Benefit from Decreased Congestion of the NAS. 

The DJI Inspire 1 UA are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to 

perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the 

ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports 

caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA do not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the DJI Inspire 1 UAS produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-

30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an 

internal combustion engine. 

By using the DJI Inspire 1 UAS to perform aerial observation, the substantial risk to life and property in the air and 

on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI 

Inspire 1 UA (weighing approximately 6 pounds 8 ounces, at their maximum gross weights with length of 18 inches, 

widths of 17.5 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons). 
City of Shafter, UAV Petition for Exemption

3. Performing Aerial Video and Photography, Surveys and Inspections, Operations with the DJI Inspire 1 UAS Will 

Benefit the Economy. 

In addition to being safe and efficient, the DJI Inspire 1 UAS are also provides an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow the CITY OF 

SHAFTER, to provide quality services to the residents and businesses of the City and the Region at minimum costs. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, agencies must adopt new and alternative technology in continue to provide required 

services at reasonable costs. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only 

allows agencies & company’s greater operational flexibility compared to manned aircraft, but provides such flexibility 

without the high operational cost of a traditional manned aircraft. 

By operating the DJI Inspire 1 UAS, the CITY OF SHAFTER can maintain and hopefully improve our ability to 

operate and maintain critical infrastructure and at the same time collect important data for further development of 

system-wide modeling of water, water, stormwater and roadway systems as well as provide accurate and current data 

related to environmental issues such as ground cover, vegetation & wildlife habitats.

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, the CITY OF SHAFTER’s

proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be 

operated only in compliance with operating documents (i.e., the CITY OF SHAFTER Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the maximum altitude 

limitations as per the requirements of 14 C.F.R. § 91.119.

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY, OR HOW THE EXEMPTION 

WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH CITY OF SHAFTER 

SEEKS EXEMPTION. 

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 

(FMRA) Section 333. 

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

its operation, CITY OF SHAFTER’S operation of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

In seeking this exemption, CITY OF SHAFTER submits that the DJI Inspire 1 UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot 

certification requirement; and (c) the specific operating limitations. 

a. The Specifications of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. 

The DJI Inspire 1 UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat 

to national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications of The DJI Inspire 1 UAS. 

The technical specifications of the DJI Inspire 1 UAS are set forth in the DJI Inspire 1 User’s Manual 

Appendix Specifications Section attached.
City of Shafter, UAV Petition for Exemption

ii. The DJI Inspire 1 UAS Flight And Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. 

The DJI Inspire 1 UAS may be operated in GPS lock, IOC, and manual flight modes. A complete description 

of the flight and navigational modes of the DJI Inspire 1 UAS are included in the User Manuals.

iii. The DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss 

Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the DJI Inspire 1 UA does not reacquire control link data from the GCS, the UAs will 

assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 UA are set forth in the DJI Inspire 1

User Manual, attached.

iv. The DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control 

software is provided in the DJI Inspire 1 User Manual. 

b. Flights of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, CITY OF SHAFTER proposes to commercially operate DJI Inspire 1 UAS for the 

special purpose of conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the 

operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1

Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial 

video and photography. 

3. The UA may not be flown at an indicated airspeed exceeding 20 knots.

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

by the procedures specified in the operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAs 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. 

6. The use of first person view camera to satisfy the visual line of site by the PIC or safety observer (SO) is 

not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The SO 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 SO can perform the functions prescribed in the operating documents. 
City of Shafter, UAV Petition for Exemption

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and 

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

limitations contained in the grant of exemption and the procedures outlined in the operating documents, 

the conditions and limitations contained in the grant of exemption 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 upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for 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. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 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. The Ground Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

11. 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. The 

PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the UAS to 

service. 

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

17. The PIC must meet or exceed all requirements as set forth by manufacturer in order to justifiably 

operate the DJI Inspire 1, or hold an equivalent pilot license approved by the FAA. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS 

will be operated under the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be 
City of Shafter, UAV Petition for Exemption

logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s 

PICs are permitted under the terms of the 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 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will 

be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current 

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, 

and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter 

of agreement with the airport management must be made available to the Administrator upon request. 

21. 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. 

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location 

within the planned operating area and land or be recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents. 

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

there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 

25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA) prior to conducting any operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered 

in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 

C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

28. The UA must remain clear and yield the right of way to all manned aviation operations and activities at 

all times. 

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

30. All operations shall be conducted over publicly owned or controlled property. Any operation over 

privately owned property would require permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized representative will be obtained for 

each flight to be conducted.
City of Shafter, UAV Petition for Exemption

31. 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

THE CITY OF SHAFTER AFFIRMS ALL INFORMATION LISTED ABOVE TO BE TRUE AND BINDING UPON FAA’S 

FINDINGS OF EXEMPTION REGARDING COMMERCIAL OPPERATIONS OF LISTED UAS, UNTIL FURTHER NOTICE OF LAWS 

OR REGULATIONS DECIDED BY THE GOVERNEMENT/FAA. THANKYOU FOR YOUR CONSIDERATION.

David Dow

GIS Coordinator