September 11. 2015

U.S. Department of Transportation Federal Aviation Administration 

Docket Management System 

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

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

Aviation Regulations from 14 CFR part 21, subpart H; 14 C.F.R. 45.23(b);14 CFR 61.113(a) 

& (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 

91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b).

Dear Sir or Madam: 

Pursuant to Section 333 of FAA Modernization Act of 2012 and 14 CFR Part 11, Beefree Media, 

LLC, a newly formed triple bottom line business solutions and marketing agency hereby applies 

for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow structured and 

safe low altitude commercial operations of it’s Small Unmanned Aircraft Systems (“sUAS”) so 

long as such operations are conducted within and under the conditions and limitations outlined 

herein or as may be established by the FAA as required by Section 333. 

Sincerely, 

Jared Jacobs, 

Managing Partner, Beefree Media, LLC

Applicant Contact Information:

Jared Jacobs

Beefree Media, LLC

2312 N-Miami Ave

Miami, FL. 33145

PH: 937-657-8031

Email: jared@beefreemedia.com

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Table of Contents 

Glossary of Abbreviations ................................................................................... 3

List of Exhibits ................................................................................................... 4

Statutory Authority for Exemption ........................................................................ 5

Section 1: Introduction ........................................................................................ 6

Section 2: Unmanned Aerial Systems .................................................................... 6

Section 3: Unmanned Aircraft Pilot in Command (PIC) ............................................ 8

Section 4: Operation of the Unmanned Aircraft ...................................................... 9

Requested Exemptions from Regulations ..............................................................13

Public Interest ....................................................................................................17

Summary for the Federal Register ......................................................................... 18

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Glossary of Abbreviation 

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

FCC Federal Communications Commission 

MAAP Mid Atlantic Aviation Partnership

NAS National Airspace System 

NTSB National Transportation Safety Board

PIC Pilot in Command 

PQS Personnel Qualification System

SOP Standard Operating Procedures 

sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VLOS Visual Line of Sight

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List of Exhibits:

1.) Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log

2.) Beefree Media Motion Picture and Television Flight Operation Manual 

Please follow the link below to review the following DJI-Inspire 1 Manuals and Safety 

Guidelines.

www.dji.com/product/inspire-1/spec

1.) Inspire 1 Quick Start Guide (EN) v1.0

2.) Inspire 1 User Manual (EN) v1.0

3.) Inspire 1 Safety Guidelines v 1.0

4.) Inspire 1 Intelligent Flight Battery Safety Guidelines

5.) 1345 Propeller Locks Quick Start Guide

6.)Inspire 1 Maintenance Manual v 1.0

Please reference to the following tutorial videos for DJI Inspire 1 below.

www.dji.com/product/inspire-1/video

1.)DJI Inspire 1 – Unboxing and Preparing for Safe Flight

2.) DJI Inspire 1 Tutorial “Pilot App”

3.)DJI Inspire 1 Tutorial “Updating the Firmware”

4.)DJI Inspire 1 Tutorial “Dual Operator”

5.)DJI Inspire 1 Tutorial “How to Fly”

6.) DJI Inspire 1 Quick Start Guide

7.)DJI Inspire 1 Set Up & Demo Inc. Overview of Features of the App

8.)DJI Inspire 1 Flight Simulator for Apple App introduction 

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Statutory Authority for Exemption: 

Detailed in this document and the referenced DJI Publications and tutorials; the requested 

exemption would permit the operation of sUAS under controlled conditions in airspace that is: 

A.) limited 

B.) predetermined 

C.) controlled to access 

D.) Provide safety enhancements to the already regulated safety practices presently followed by 

manned aircraft as governed by the FAA.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibility to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act. 

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

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including sUASs, 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; CFR §91.203(a)(1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may 

operate in the National Airspace System without creating a hazard to the user, the public, or a 

threat to national security. In making this determination, the Secretary must consider: 

a.) The sUAS’s size, weight, speed and operational capability

b.) Whether the sUAS operates within the VLOS of the PIC

c.) Whether the sUAS operates outside of highly populated areas and away from close proximity 

to airports 

Reform Act §333(a). If the Secretary determines that a sUAS “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). 

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Section 1: Introduction 

Beefree Media is recognized as a pillar of support for community and small business 

development in South Florida. The mission of Beefree Media is to provide unmatched quality in 

our service to business and community development. Our objective on every mission is to serve 

as an example in regards to safety and professionalism to the public. 

Section 2: Unmanned Aerial Systems

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize 

risk to the NAS or to persons and property on the ground. Specifically, petitioners should describe the 

design and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft 

performance and performance limitations, operating procedures, and aircraft loading information in as 

much detail as possible. This could be provided in the petition or in an Aircraft Flight Manual or similar 

document. 

NOTE: The FAA will consider all information and data submitted by the petitioner that 

describes the UAS developmental and operational history. This could include statistical data or other 

documentation for the specific design and performance characteristics of the UAS, including the 

operational history and operational failure modes, obtained through previous Research & Development 

(R&D) and/or flight test activities, e.g. operations conducted under a COA, with a civil airworthiness 

certificate, or under other authorized operating conditions. 

2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, 

maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in 

the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document. 

NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may 

be separate documents or combined in a single document.

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS 

and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies 

with Federal Communications Commission (FCC) or other appropriate government oversight agency 

requirements. 

NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with 

FCC requirements upon request. 

Beefree Media will operate all sUAS under fifty-five pounds including payload within NAS 

aerospace with the experience of Beefree Media sUAS flight training. Beefree Media preflight 

procedures are designed to reduce risk and mitigate both mechanical and user error for 

maximum safety in the support of and in accordance with the FAA’s mission to provide the 

safest, most efficient aerospace system in the world. 

Prior to each flight the PIC will thoroughly reference and provide entry into the Beefree Media 

sUAS Safety Standard Operating Procedures Checklist and Pilot Log. If a situation arrises 

where the PIC finds operation procedure or the sUAS to be affected or incomplete, the PIC will 

reframe from operation until all necessary tasks, maintenance and alterations are performed 

insuring the proper conditions for a safe flight. All operations, maintenance and alterations will 

be documented by the PIC within the Beefree Media sUAS Safety Standard Operating 

Procedures Checklist and Log.

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All maintenance or alteration procedures will be logged within the Beefree Media sUAS Safety 

Standard Operating Procedures Checklist and Pilot Log as well as test flights for functionality in 

accordance to the manufactures guide. 

The radio frequency spectrum used for remote control and operation with the sUAS will comply 

with the Federal Communication Commission (FCC) and all other appropriate government 

oversight agency requirements. 

DJI Inspire 1

Beefree Media LLC. seeks an exemption to operate the DJI Inspire 1 sUAS for compensation or 

hire. The DJI Inspire 1 is comprised of a quad-rotor unmanned aircraft with four rotors powered 

by four lithium polymer battery powered electric motors including up to two handheld ground 

control stations.

Flight weight: approximately 6.5 pounds

Dimensions: 438mm x 451mm x 301mm 

Design and operational characteristics are provided in DJI Inspire 1 Operating Manual (Pages 

57-59). Beefree media PIC sUAS operators will conduct pre-flight inspections as documented in 

the Beefree Media sUAS Safety Standard Operation Procedure Checklist and Pilot Log as well 

as the DJI Inspire 1 Operating Manual (Page 49). 

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Section 3: Unmanned Aircraft Pilot in Command (PIC)

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for 

the operation of the UAS, including information such as: the level of airman certificate held; any 

applicable training related to the operation; and any minimum hours of flight experience required by the 

PIC(s), both total flight time and the time with the particular UAS. If the operation would use visual 

observers, petitioners should describe their roles and qualifications. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for 

the operation of the UAS. 

All sUAS operators including both the PIC and VO will have both a valid state drivers license 

and an applicable knowledge of and compliance with Agency regulations relative to the location 

of sUAS operation. Included in the sUAS operators applicable knowledge and compliance are 

the articles of the Title 14 Code of Federal Regulations segments below. 

61.51 Pilot logbooks

61.56 Flight review

91.111 Operating near other aircraft

91.113 Right-of-way rules: Except water operations

91.115 Right-of-way rules: Water operations

91.119 Minimum safe altitudes: General

The PIC in operation of the sUAS for a Beefree Media service must have a minimum of 10 hours 

of logged flight time with the specific sUAS make and model consistent with 14 CFR Section 

61.51(b) and 25 total hours of flight time. PIC and VO sUAS training and experience building 

flights are requested to occur under this grant of exemption. All sUAS flight training sessions 

will take place with the required distance from non-participants in accordance with the Title 14 

Code of Federal Regulations. In accordance with all FAA approved exemptions, A VO will be 

present on all operations to maintain Visual Line of Sight (VLOS) at all times while maintaining 

the ability to verbally communicate. The PIC will either maintain VLOS at all times or maintain 

the ability to achieve VLOS when a VO is present on operations. A VO will always be present on 

all operations.

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Section 4: Operation of the Unmanned Aircraft 

 6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how 

the proposed operation(s) would not adversely affect safety, or how they would provide a level of 

safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners 

should address any plans to implement clearly defined operational borders and procedures to 

ensure public safety, which includes persons and property both in the air and on the ground. This 

can be described in the petition, in an Operations Manual, or similar document. 

NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of flight, 

NAS safety considerations, and the safety of the non-participating persons and property during 

the operational period and within the operational area. 

 7. Petitioners should specify the proposed maximum operating speed and altitude, and describe 

minimum flight visibility and distance from clouds for their intended operation(s). Petitioners 

should describe potential hazards and safety mitigations associated with these proposed 

conditions. These issues can be addressed in the petition, an Operations Manual, or similar 

document. 

The sUAS will remain clear of and always yield the right of way to all other manned aerospace 

operations and activities. The multi-rotary sUAS operation will operate at altitudes no higher 

than 400 feet above ground level (AGL) nor flown in speeds exceeding design limitation of 43 

knots or 50mph. All altitudes will be reported to the ATC in feet. 

The PIC will always operate the sUAS with optimal battery power to return the sUAS to the 

predetermined (home) location with no less than 25% power remaining. The PIC will at all times 

operate the sUAS under Visual Meteorological Conditions (VMC) and will never operate the 

sUAS when visual conditions are less than 3 miles or 1500 feet. Operations will never occur at at 

night. The PIC will not operate the sUAS less than 500 feet below or less than 2,000 feet 

horizontally from a cloud. The PIC operating the sUAS will abort the flight in the event of 

unpredicted obstacles or emergencies. Upon the loss of GPS signal the PIC will return the sUAS 

to the predetermined (home) location or perform emergency landing and/or recovery measures as 

outlined in the Beefree Media Safety Standard Operating Procedures Checklist and Pilot Log.

A serial number will identify the sUAS proposed for exemption registered in accordance with 14 

CFR part 47.

45.1 to 45.33 - IDENTIFICATION AND REGISTRATION MARKING

47.1 to 47.71 - AIRCRAFT REGISTRATION

At all times the PIC will have access to appropriate documents in accordance with 14 CFR 

91.203 and 14 CFR 91.9. Upon request, law enforcement will have access and availability to 

these documents. Upon the occasion of a sUAS failing to maintain boundaries of operation as 

defined applicable, a report will be filed to the FAA UAS Integration Office (AFS-80) within 24 

hours. All incidents and accidents will be reported to the National Transportation Safety Board 

(NTSB).

91.203   Civil aircraft: Certifications required

91.9   Civil aircraft flight manual, marking, and placard requirements

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 8. Petitioners should describe the characteristics of the area of intended operation(s) and the 

associated potential hazards, in accordance with the statutory mandate under Section 333 

regarding proximity to populated areas. These issues can be addressed in the petition, an 

Operations Manual, or similar document. 

Operations of sUAS may be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special 

purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and 

essential persons are permitted when operationally necessary; but never so close to present an 

undue hazard.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, 

vehicles or structures owned by the land owner/controller when the land owner/controller grants 

such permission, and the PIC makes a safety assessment of the risk from operations and 

determines that it does not present an undue hazard to persons or property.

Flight operations will be conducted at least 500 feet from all nonparticipating persons unless 

barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS 

and/or debris in the event of an accident Beefree Media shall 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 sUAS, flight operations will cease immediately.

All operations of sUAS shall be conducted with the permission from the land owner/controller or 

authorized representative. Permission from the land owner/controller or authorized representative 

will be obtained for each flight to be conducted. 

 9. Petitioners should describe if they intend to operate in the proximity of any airports, in 

accordance with the statutory mandate under Section 333 regarding proximity to airports. 

The sUAS will 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 will be 

made available to the Administrator upon request.

 10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the 

statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to 

comply with his mandate. 

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC 

to be able to use their own vision to see the sUAS in real time and space unaided by any device 

other than corrective lenses.

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All sUAS operations must utilize a VO. The VO may be utilized 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. The PIC and VO 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 functions required.

The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will 

not be conducted during night as defined in 14 CFR 1.1. 

 11. Petitioners should describe any procedures they would implement for conducting a 

preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 CFR 

§ 91.7(b)) and that the planned operation can be completed safely. These procedures can be 

addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar document. 

Beefree Media will conduct preflight safety risk assessments to determine that the sUAS is in a 

condition for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be 

completed safely. Specific procedures are addressed in the DJI-Inspire 1 Manuals and Safety 

Guidelines as well as the Beefree Media sUAS Safety Standard Operating Procedures Checklist 

and Pilot Log. 

 12. If petitioners intend to conduct operations which have existing requirements to notify Flight 

Standards District Offices (FSDOs) prior to operations – such as motion picture and television 

filming, or pipeline and powerline patrol – petitioners should describe their intended coordination 

in this regard for their proposed operation(s). 

Beefree Media does not have existing requirements for a notification to Flight Standards District 

Offices (FSDOs). Upon the need for an operation requiring notification to the FSDO, Beefree 

Media will submit a written plan of activities that will be submitted to the local FSDO in 

reference to the Beefree Media MPTOM at least 3 days before aerial filming. The plan of 

activities will include a list of 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; 

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 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. 

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Images taken will be of individuals who have also consented to being 

filmed or otherwise have agreed to be in the area where aerial photography will take place. 

 13. The FAA intends to require entities who obtain an exemption under this process to also obtain a 

Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to 

conducting operation(s) in the NAS. The COA application is available here.

Beefree Media shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this requested grant of 

exemption. 

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Specific Regulation Requisition Exemption 

14 CFR 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 Beefree Media. LLC an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 V.S.C.§44701 (t) 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 sUAS. Our small UAS 

will be operated at low speed in a controlled environment, at least five miles from an airport and 

more than three miles from any densely populated area. An analysis of these criteria 

demonstrates that the sUAS 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 helicopter) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The DJI Inspire 1 to be operated hereunder is less than 8 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area. Like other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the operator and under the requirements and in compliance with 

local public safety requirements, to provide security for the area of operation. 

These safety enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to its size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and ability to carry 

an external load no greater than two pounds . 

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

This regulation requires certain experimental, provisionally certificated aircraft, or light-sport

category aircraft to be marked with letters between 2 inches and 6 inches high “limited,” 

“restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, 

cockpit, or pilot station. 

Even though the sUAS will not have an airworthiness certificate, an exemption would be needed 

as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAS, two-inch lettering would be 

impracticable.

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14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in Command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the pilot operating the sUAS to have completed sUAS 

flight training by reviewing each of the three DJI Inspire 1 manuals (attached to this document), 

review all DJI Inspire 1 tutorial videos listed at www.dji.com/product/inspire-1/video. The pilot 

would also perform a minimum of 200 flight cycles, 25 hours of total time as a sUAS roto-craft 

pilot and a minimum of 10 hours of piloting the Inspire 1 before performing the first “operational 

flight” under this exemption. Unlike a conventional aircraft that carries the pilot and passengers, 

the sUAS is remotely controlled with no living thing or cargo on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance. The risks 

associated with the operation of the sUAS are mitigated from the level of risk associated with 

commercial operations contemplated by Part 61 allowing operations of the sUAS as requested 

with a pilot who has met the minimum requirements stated above exceeding the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. 91.7(a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the DJI Inspire 1 Manuals, DJI 

Inspire 1 tutorials and the use of the Beefree Media sUAS Safety Standard Operating Procedures 

Checklist and Pilot Log prior to each flight, an equivalent level of safety will be provided. 

14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 

The sUAS, given its size and configuration 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 maintained by keeping the flight manual at the ground 

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

14 C.F.R. 91.103(b): Preflight Action 

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery 

requirements, checking takeoff and landing distances, and all other actions in the Preflight 

Checklist in the DJI Inspire 1 Manuals. These actions as well as those required within the 

Beefree Media sUAS Safety Standard Operating Procedures Checklist and Pilot Log will provide 

an equivalent level of safety. 

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14 C.F.R. 91.109: Flight Instruction 

Section 91.109 provides 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. By design, sUASs and remotely piloted aircraft do 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 FAA has previously approved exemptions for aircraft 

without fully functional dual controls. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via 

radio signals from the controller, and by the size and speed of the aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This 

exemption is for a multi-rotor craft that flies similarly to a helicopter, with vertical takeoff and 

vertical landing, which will typically operate at altitudes of 150 AGL, so an exemption may be 

needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL 

and will be in a restricted area with security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and any onsite 

personnel all affected individuals will be aware of the planned flight operations. Compared to 

flight operations with aircraft or rotorcraft weighing far more than the maximum 8 lbs. proposed 

herein and carrying flammable fuel, any risk associated with our operations is far less than those 

presently presented with helicopters and other conventional aircraft operating at or below 500 

AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these 

sUAS operations and the operations of conventional aircraft that must comply with Section 

91.119. 

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14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The 

Inspire 1 is limited to operations in predetermined and controlled environments, and has a 

limited range and flight time which require an exemption from 14 CFR 91.151(a). 

The battery powering the Inspire 1 provides approximately 18 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, DJI Inspire 1 flights would not be 

possible. Given the limitations on the DJI Inspire 1 proposed flight area and the location of its 

proposed operations within a predetermined area, a time frame of 14 minutes for flight in 

daylight VFR conditions is reasonable allowing 25% battery power to remain upon returning to 

the predetermined (home) location. These restrictions will be more than adequate to return the 

DJI Inspire 1 to its planned landing zone from anywhere in its limited operating area.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration the regulation 

provides in part: 

(a) Except as provided in 91.715, no person may operate a civil aircraft unless it has within it 

the following: 

(1) An appropriate and current air worthiness 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 DJI Inspire 1 fully loaded weighs no more than 8lbs and is operated without an onboard 

pilot. Therefore there is no ability or place to carry certification and registration documents or to 

display them on the DJI Inspire 1. 

An equivalent level of safety will be achieved by keeping these documents at the ground flight 

control point where the pilot flying the sUAS will have immediate access to them; to the extent 

they are applicable to the sUAS.

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections 

These regulations require 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 ... ,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to Beefree Media. Maintenance will be accomplished by the PIC.

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Public Interest 

Beefree Media is a leading triple bottom line business solutions and marketing agency providing 

a valuable support and service to industry whose business model supports economic growth, 

environmentally sustainable solutions or mitigations, and community enhancement. Our image in 

the public eye locally is very well recognized and growing expediently. It is our commitment to 

maintain a positive image with the public by managing all operations as a concrete example in 

regards to safety, compliance, communication, and efficiency. Beefree Media will provide our 

vastly expanding local market here in South Florida a safe, well trained and professional solution 

based option to comply with FAA regulation while pursuing their unique sUAS needs. 

The applicant proposes that the exemptions 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. 

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A Summary That Can Be Published in The Federal Register, Stating: 

The Rules From Which Beefree Media, LLC. Seeks Exemption:

Beefree Media, LLC seeks exemption from the requirements of 14 CFR part 21, subpart H; 14 

C.F.R. 45.23(b);14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 

91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b).

Conclusion 

As set forth above, Beefree Media Solutions, LLC seeks an exemption pursuant to 14 CFR 11 

and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe 

commercial operation of the DJI Inspire 1 sUAS. By granting this Petition, the FAA will allow 

Beefree Media, LLC to safely, effectively and efficiently commercially operate the designated 

DJI Inspire 1 sUAS. 

Submitted on September 16, 2015

Thank you for this submission request.

Sincerely, 

Jared Jacobs

Beefree Media, LLC

2312 N-Miami Ave

Miami, FL. 33145

PH: 937-657-8031

Email: jared@beefreemedia.com

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