APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWING UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

Aero Images LLC requests an exemption from the following regulations as well as any additional regulations that may 

technically apply to the operation of the Inspire1:

14 CFR 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 than2 inches nor 

more than 6 inches high, the words “limited”, “restricted”, “light-sport”, “experimental”, or “provisional”, as 

applicable.

The Inspire1 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 would 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 Inspire1 marked 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, Exemption Nos. 10700, 8738, 10167, 10167A and 11428.

14 CFR 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, establish the procedural requirements for the issuance of airworthiness certificates as required by FAR 

91.203(a)(1). Given the size of the aircraft (under 7lbs.) 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 Inspire1 operated without an airworthiness certificate, under 

the conditions propose herein, will be at least as safe or safer, than a conventional aircraft (fixed wing or rotorcraft) with an 

airworthiness certificate. The Inspire1 weights less than 7 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 advanced 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 Inspire1 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 CFR 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, 

passenger and cargo, the Inspire1 in this case is remotely controlled with no passenger 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. Aero Images LLC respectfully proposes that operator requirements should take into the account the characteristics of the 

particular UAS. AI’s Inspire1 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 Inspire1 has a semi-autonomous navigation and control system comprised of a Ground Control Station (GCS) and 

autopilot system. All flights are pre-programmed with precision GPS guidance and do not require human intervention. Flight 

mission area and routing cannot be changed after launch. Flights are not directed by positive manual control, nor are evasive 

maneuvers. In the case of unplanned events, the operator inputs pre-programmed evasive maneuvers from the control unit, 

and the control unit executes the maneuver. Pre-programmed operator intervention 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 Inspire1 include the following:

 Autopilot detection of lost GPS or of insufficient satellites initiates an immediate spiral landing.

 Low power on the aircraft triggers escalation alarms at GCS at 35% and 10% levels.

 If the autopilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure begins.

 The Inspire1 is inherently unstable, so autopilot fail will result in very rapid exit from flight.

 Aircraft has an on-board failsafe that limits speed in the event of dive to approximately 14 m/s.

 The aircraft weighing less than 7 lbs., fully loaded, is constructed of composite material, which is intended to 

absorb impact energy.

 The motors are driven by pulse width modulated signals, not analog signals.

Given these safety features, Aero Images LLC proposes that operators of the Inspire1 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- recognize equivalents.

 Have completed the manufactures training program for operation of the UAS. 

Even though AI is placing this proposal, the operator for AIs Inspire1 holds an ATPL certification with current First 

Class Medical.

Aero Images LLC notes that the FAA has found that safety factors permitted operations 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 System (UAS) Operational 

Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 USC 44701(f) to waive the pilot 

requirements for commercial operations.

Given this conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the Inspire1 

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 Inspire1 (given 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 CFR 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 CFR 91.7(a): Civil Aircraft Airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy conditions. Should the exemption 

be granted allowing commercial operation of the Inspire1 without an airworthiness certificate, no standard will exist for 

airworthiness of the Inspire1. Given the size of the aircraft and the requirements that have presumably already been met in the 
SAC approval process for the Inspire1 (for instance, the Inspire1’s Maintenance & Inspection Manual and Safety Checklist), 

an equivalent level of safety will be achieved by insuring compliance with the Aero Images LLC manuals prior to each flight.

14 CFR 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 and Airplane or Rotorcraft Flight Manual is not required by Section 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 Inspire1, it has no ability or place to carry such a flight manual on the aircraft, not 

only because there is no pilot onboard, 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 2) at the ground

control point where the pilot flying the UAS will have immediate access to it.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 32827, 10700 and 11428.

14 CFR 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 Inspire1 is a remotely piloted aircraft and by design, does not have 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 is pre-programmed into the autopilot before flight and only under 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 experience and qualified pilots familiar with the Inspire1.

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 no be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Inspire1 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 Inspire1 is built.

Also, no flight will be taken without the permission of the landowner 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 operation 

conducted with aircraft or rotorcraft weighing far more than 7 lbs. and carrying flammable fuel, any risk associated with this 

operations will be far less than those currently allowed with conventional aircraft operating at or bellow 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 CFR 91.151(a): Fuel Requirements for Flights in VFR Conditions.
This regulation prohibits and 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 Inspire1 smart batteries provide approximately 50 minutes of powered flight. Without an exemption from 14 CFR 

91.151, the UASs flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed 

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

Aero Images LLC 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 the Inspire1 flights to 20 minutes would greatly reduce their utility. In the unlikely event 

that the Inspire1 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.

Aero Images LLC believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, 

which, allowing 40 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 CFR 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration.

This regulation provides as follow:

(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 Inspire1 fully loaded weights no more than 7 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 onboard 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 exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, and 11428.

14 CFR 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 airworthiness 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 Inspire1 will be accomplished by the owner/operator pursuant to the manuals, such as Exhibit 3, provided 

by Aero Images LLC. An equivalent level of safety will be achieved because the UAS is small in size, will operate in 

restricted predetermined areas, and is not a complex mechanical device. As provided in the attached User Manual and the 

Safety Checklist, the operator of Inspire1 will ensure that the UAS is in working order prior to initiating flight, perform 

require 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 AERO IMAGES LLC SECTION 333 EXEMPTION REQUEST

Aero Images LLC hereby pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the Inspire1 unmanned aircraft in precision aerial survey work. An exemption 

is requested from the following regulations:

 14 CFR Part 21

 14 CFR 45.23(b)

 14 CFR 61.113(a) & (b)

 14 CFR 61.133(a)

 14 CFR 91.7(b)

 14 CFR 91.9(b)(2)

 14 CFR 91.109(a)

 14 CFR 91.119

 14 CFR 91.151(a)

 14 CFR 91.203(a) & (b)

 14 CFR 91.405(a)

 14 CFR 91.407(a)(1)

 14 CFR 91.409(a)(2)

 14 CFR 91.417(a)