UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

DOCKET OPERATIONS 

WEST BUILDING GROUND FLOOR, ROOM W12-140

1200 NEW JERSEY AVENUE, SE., WASHINGTON, DC 20590 

 Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

CONTRACTED-INFRARED TECHNOLOGY, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)

(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF THE 

DJI INSIRE 1 UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

 Submitted May 28, 2015 

 ROGER SELCH 

 1551 Highland Road 

 Winter Park, Florida 32789 

 EMail: cit.fly@gmail.com

 Tel: 407.275.0360

 
TABLE OF CONTENTS

 Page 

GLOSSARY OF ABBREVIATIONS .............................................................................3 

SUMMARY........................................................................................5 

INTRODUCTION AND INTERESTS OF PETITIONER .............................................5 

BACKGROUND .............................................................................................................6 

BASIS FOR PETITION ..................................................................................................7 

 NAME AND ADDRESS OF PETITIONER .........................................9 

 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH C-IT, LLC SEEKS 

 EXEMPTION...............................................................................9 

 

 THE EXTENT OF RELIEF AND THE REASON C-IT, LLC SEEKS THE 

 RELIEF ....................................................................................13 

 THE REASONS WHY GRANTING C-IT, LLC’S REQUEST FOR 

 EXEMPTION WOULD BE IN THE PUBLIC INTEREST........................16 

 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

 ADVERSELY AFFECT SAFETY......................................................20 

 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...33 

 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

 AVAILABLE TO SUPPORT C-IT'S REQUEST ......................................34 

CONCLUSION .....................................................................................34 

EXHIBITS...........................................................................................36 

2
GLOSSARY OF ABBREVIATIONS

 AGL Above Ground Level 

 AOI Area of Interest 

 ATC Air Traffic Control 

 ATO Air Traffic Organization

 CAD Computer Aided Design 

 C.F.R. Code of Federal Regulations 

 COA Certificate of Authorization

 C-IT Contracted-Infrared Technology, LLC 

 FAA Federal Aviation Administration 

 FAR Federal Aviation Regulations 

 FPV First Person View 

 GCS Ground Control Station 

 GPS Global Positioning System

 IOC Intelligent Orientation Control 

 LOL Loss of Link 

 NAS National Airspace System 

 NOTAM Notice to Airman 

 PIC Pilot In Command 

 RTH Return To Home 

 Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

 SOP Standard Operating Procedures 

 UA Unmanned Aircraft 

 UAS Unmanned Aircraft System

 Ultra HD 4K Ultra High Definition (3,840 by 2,160 resolution)

 VFR Visual Flight Rules 

 VLOS Visual Line of Site 

3
 VMC Visual Meteorological Conditions 

 VO Visual Observer 

 VTOL Vertical Takeoff and Landing 

4
SUMMARY

 Contracted-Infrared Technology, LLC seeks exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

C-IT to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial acquisitions and research over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

 Contracted-Infrared Technology, LLC (hereinafter referred to as “C-IT”) is a 9 year 

old company founded by Roger Selch, a USAF (20 years) veteran and pilot with both rotary 

and fixed wing experience as well as certified in Building Science and as a 3rd Level III 

(highest) Thermographer. His company is a well recognized company conducting ground 

and helicopter flight operations to collect aerial data and photographs for nearly a decade. CIT excels in collecting aerial imagery from manned and recently unmanned aircraft to 

provide digital data for various clients and applications to develop building side and above 

roof images, real-estate, CAD maps and infrared images for government and also nongovernment buildings. These include many sites like the USAF Academy USAF base in 

Colorado Springs, the Veterans Administration Hospital in Bonham TX and Walt Disney 

World in Orlando Florida. Currently, C-IT is flying manned helicopters and planes to collect 

this data significantly interrupting Control Tower air routing traffic efforts. The UAS can do 

this at about 400 feet AGL and above buildings with significantly less time, risk and danger. 

C-IT can provide a safer NAS air space with less air travel interruption, less liability risk and 

efficient technology use for the commercial purpose to collect aerial data and research for 

other mostly government but also other clients and the community it serves. 

5
 As set forth in this petition, C-IT seeks to commercially operate it’s UAS over certain 

areas of the United States for the purpose of conducting aerial acquisitions and research, 

continuing an established legacy that has always sought the highest standards of operations 

and safety. 

BACKGROUND 

Unmanned Aircraft System: DJI Inspire 1 UAS 

 C-IT seeks an exemption to operate the C-IT DJI Inspire 1 UAS for compensation or 

hire within the National Airspace System (NAS). The DJI Inspire 1 is a professional aerial 

4K high definition real time remote and First Person View (FPV) filmmaking and 

photography ready to fly platform. It is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with Ground Control Station (GCS) software which includes the Intelligent 

Orientation Control (IOC) while under optimum conditions has a maximum communication 

transmission distance of 2Km (6562 feet). The IOC “mode” includes flight distance limits 

(including altitude and distance), Point of Interest (POI) GPS locations, Course Lock (CL) 

and Home Lock (HL) to better secure the public safety. Redundant systems include the 

barometric sensor and Vision Positioning System for safer altitude limits which includes a 

ground focused digit camera and dual sonar to provide the safest altitude for take-offs and 

landings. The DJI Inspire UA has a maximum gross takeoff weight of about 7.5 pounds, 

while having an in-flight diameter of about 17.2 x 17.8 x 11.9 inches, a maximum speed of 

49 mph (43 knots) and about 18-22 minutes (depending on the battery model) flight time. 

The DJI Inspire 1 UA is equipped with four electric motor propellers driven by one Lithium 

Polymer battery. 

 The DJI Inspire 1 UA that will be operated by C-IT will be registered in accordance 

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. 

6
BASIS FOR PETITION

 Petitioner, C-IT pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, entitled 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

operate the DJI Inspire 1 UAS in the NAS and for an exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). 

 In consideration of the size, weight and speed, as well as the limited area of intended 

operation associated with the unmanned aircraft, C-IT’s use of the DJI Inspire 1 UAS meets 

the conditions of the FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

 Accordingly, C-IT 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. 

 C-IT submits that the requested relief is proper since an equivalent level of safety will 

be ensured. C-IT will use manufacturer trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the manufacturer’s maintenance manual. Furthermore, C-IT 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 C-IT to the extent necessary to 

allow a Pilot in Command (PIC) holding a private or higher level pilot certificate, and an 

airman medical certificate, and who has completed the DJI Inspire 1 UAS training and 

7
currency requirements, to conduct the proposed UAS flight operations for compensation or 

hire. C-IT submits that the conditions and limitations set forth herein will ensure the safety 

of the NAS, as well as the safety of persons and property on the ground. 

 C-IT seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, C-IT submits that it will ensure that the DJI Inspire 1 

UAS is in an airworthy condition prior to every flight, by determining that the UAS is in 

compliance with its type design pursuant to the DJI Inspire 1 User and Maintenance Manual, 

and that the aircraft is in a condition for safe flight. 

 C-IT also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric altimeter 

onboard. However, as described in the Background Section, the IOS mode with altitude 

information from the DJI Inspire 1 UA will be provided to the PIC via Global Positioning 

System (GPS) and a radio communications telemetry data link, which downlinks from the 

UA to the PIC for active monitoring of the flight path. This altitude information, combined 

with C-IT’s operation of the DJI Inspire 1 UA within visual line of sight, will ensure a level 

of safety equivalent to Section 91.121. 

 Additionally, C-IT seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. C-IT submits that safety will not be 

affected by operation of the DJI Inspire 1 UA during daylight hours under visual flight rules 

(VFR) and visual meteorological conditions (VMC), with enough battery power to fly for a 

total duration of 13 minutes and to fly after for at least five minutes (i.e., 27 percent battery 

power remaining). Optional replacement batteries extend these times. The DJI Inspire is also 

equipped to Return To Home (RTH) or to the PIC location with a one button command or for 

lost communications as well as audio and visual low battery warnings. 

8
In accordance with 14 C.F.R. § 11.81, C-IT provides the following information in 

support of its petition for exemption: 

A. Name And Address of The Petitioner. The name and address of the Petitioner is: 

 C-IT, Inc. 

 1551 Highland Road 

 Winter Park, FL 32789

 The point of contact for this Petition & specific contact information is as follows: 

 Roger Selch

1551 Highland Road 

 Winter Park, FL 32789

 Tel: 407-275-0360 

 Email: cit.fly@gmail.com 

B. The Specific Sections Of 14 C.F.R. From Which C-IT Seeks Exemption. 

1. C-IT Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b). 

 Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

 command, subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) 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. 

2. C-IT Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. C-IT Seeks Exemption From The Requirements Of Section 91.121. 

9
 Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

 (a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

 of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating-- 

(1) Below 18,000 feet MSL, to-- 

 (i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; or 

 (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

 airport or an appropriate altimeter setting available before departure.

 4. C-IT Seeks Exemption From The Requirements Of Section 91.151(b). 

 Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following: 

 (b) No person may begin a flight in a rotorcraft 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, to fly after that 

 for at least 20 minutes. 

 5. C-IT Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft— 

(a) 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[.] 

 6. C-IT Seeks Exemption From The Requirements Of Section 91.407(a)(1). 

10
 Section 91.407, entitled Operation after maintenance, preventive maintenance, 

 rebuilding, or alteration, subsection (a)(1), states the following: 

 (a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-- 

 (1) It has been approved for return to service by a person authorized under § 43.7 of 

 this chapter[.] 

7. C-IT Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

 91.409(a)(2). 

 Section 91.409, entitled Inspections, subsection (a), states the following: 

 (a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -- 

 (1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or 

 (2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter. 

 8. C-IT Seeks Exemption From The Requirements Of Sections 91.417(a) 

 And 91.417(b). 

 Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

 (a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

 registered owner or operator shall keep the following records for the periods specified 

 in paragraph (b) of this section: 

 (1) Records of the maintenance, preventive maintenance, and alteration and records 

 of the 100-hour, annual, progressive, and other required or approved inspections, as 

 appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include-- 

11
 (i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and 

(ii) The date of completion of the work performed; and 

 (iii) The signature, and certificate number of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 

 (i) The total time in service of the airframe, each engine, each propeller, and each 

rotor. 

 (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, 

and appliance. 

 (iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

 (iv) The current inspection status of the aircraft, including the time since the last 

 inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

 (v) The current status of applicable airworthiness directives (AD) and safety 

 directives including, for each, the method of compliance, the AD or safety directive 

 number and revision date. If the AD or safety directive involves recurring action, the 

time and date when the next action is required. 

 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

 alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances. 

 (b) The owner or operator shall retain the following records for the periods 

prescribed: 

 (1) The records specified in paragraph (a)(1) of this section shall be retained until the 

 work is repeated or superseded by other work or for 1 year after the work is 

performed. 

 (2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

12
 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

 chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent Of Relief C-IT Seeks And The Reason C-IT Seeks The Relief. 

 1. Extent of Relief C-IT Seeks And The Reason C-IT Seeks Relief From Section 

61.113(a) And (b). 

 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 holding a private or 

higher level pilot certificate, a current and valid airman medical certificate, and who has 

completed the DJI Inspire 1 UAS or other training and currency requirements, 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, C-IT 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, through the DJI Inspire 1 UAS training and currency requirements, that 

the PIC is able to safely operate 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, C-IT 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 C-IT’s business; and 

(2) will not carry passengers or property for compensation or hire. 

13
2. Extent of Relief C-IT Seeks And The Reason C-IT Seeks Relief From Section 

 91.7(a). 

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

extent required to allow C-IT to determine that the DJI Inspire 1 UAS is in an airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the DJI Inspire 

1 User Manual, and that the aircraft is in a condition for safe flight. 

 C-IT 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, prior to 

every flight, C-IT will ensure that the DJI Inspire 1 UAS is in an airworthy condition based 

upon a visual inspection, in order to determine that the UA and its components are in 

compliance with its type design and operating documents (i.e., the DJI Inspire 1 User 

Manual, GPS, and IOC software), and that the aircraft can be operated safely pursuant to the 

conditions and limitations stated herein. 

3. Extent of Relief C-IT Seeks And The Reason C-IT Seeks Relief From Section 

 91.121. 

 Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Inspire 1 UAS, which utilizes a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC. C-IT seeks the requested relief because the DJI Inspire 1 UA does 

not utilize a typical barometric altimeter onboard that may be set as contemplated by Section 

91.121. As more fully set forth below, an equivalent level of safety will be maintained since 

the DJI Inspire 1 UA is 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 iPad or iPhone 

using the latest Apple iOS Operating system.

 

 4. Extent Of Relief C-IT Seeks And The Reason C-IT Seeks Relief From Section 

91.151(b). 

14
 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 13 minutes and to fly after for at least five minutes (i.e., 27 

percent battery power remaining). Optional replacement batteries extend these times. The 

DJI Inspire is also equipped to Return To Home (RTH) or to the PIC location with a one 

button command or for lost communications as well as audio and visual low battery 

warnings. C-IT 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 acquisition and research flight operations that C-IT 

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 User Manual, and C-IT’s proposed operating limitations, ensure that C-IT 

will safely operate the battery powered DJI Inspire 1 UA during daylight hours under VFR, 

with enough battery power to fly for a total duration of 13 minutes to the first point of 

intended data gathering and, assuming normal cruising speed, to fly after that for at least five 

minutes (i.e., 27 percent battery power remaining). 

5. Extent Of Relief C-IT Seeks And The Reason C-IT Seeks Relief From 

 Sections 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, C-IT requests relief from these 

Sections because the DJI Inspire 1 UAS does not require an airworthiness certificate. As set 

forth more fully below, the DJI Inspire 1 UAS meets the conditions of Section 333 of the 

FMRA for operation without an airworthiness certificate. Accordingly, C-IT will use 

manufacturer trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

15
manufacturer’s maintenance manual. Furthermore, C-IT will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

D. The Reasons Why Granting C-IT’s Request For Exemption Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

 Granting the present Petition will further the public interest by allowing C-IT to 

safely, efficiently, and economically perform aerial acquisitions and research over areas of 

the United States, commercially, in support of government and non-government entities, real 

estate, agriculture, and to conduct research and scientific studies. Additionally, use of the DJI 

Inspire 1 UAS will decrease NAS congestion, avoid commercial flight rerouting for landing 

and take off delays, reduce liability risks, reduce pollution, increase safety and provide 

significant benefits to the economy. Notably, the benefits of C-IT’s proposed operation of the 

DJI Inspire 1 UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From The Aerial Acquisition And Research 

 Performed. 

C-IT submits this Petition to commercially operate the DJI Inspire 1 UAS and 

perform aerial acquisition and research throughout areas of the United States, in support of 

government (and non-government like health care and department stores) entities, real-estate 

to include CAD mapping, support for building and infrastructure management assessments. 

The DJI Inspire 1 UAS will provide safe, efficient, and economical aerial acquisition and 

research to further each of these fields, all of which are critical to the well being of the 

general public. 

 The specific operations that C-IT will perform with the DJI Inspire 1 UAS 

demonstrate how the requested exemption will directly benefit the above-referenced 

industries and the general public as a whole. 

Realestate 

16
In the field of Realestate, C-IT's operation of the DJI Inspire 1 UAS will be used to assess 

and improve land-use design and marketing, sales and CAD topography analysis. 

Specifically, C-IT's ability to use the DJI Inspire 1 UAS to perform high definition image and 

video data capture flight operations via the GPS IOC will positively identify buildings for 

anomalies using my Building Science certification, CAD topography mapping and infrared 

comparison analysis and reporting. This data establishes the required baseline images 

necessary to access follow-on intrusive studies and as further employment for the public 

community. This ability to accurately re-create the exact same GPS derived flight patterns 

will provide invaluable data without the undue risk that I currently use with conventional 

manned aircraft. The C-IT DJI Inspire 1 UAS technology and automation make this effort 

faster with less people involved, resulting in less risk for people, equipment and land 

(environmental, agricultural and animals) as well as a safer NAS for the public.

Building Infrastructure 

In the field of Building Science, C-IT's operation of the DJI Inspire 1 UAS will be used to 

assess and improve building design, construction and repair from weather induced damage 

like water intrusions as well as to improving building energy conservation. Specifically, CIT's ability to use the DJI Inspire 1 UAS to perform high definition image and video data 

capture flight operations via the GPS IOC will positively identify building anomalies for 

building science analysis, research and repair. This effort significantly reduces the public’s 

cost to identify specific window, wall and roof repairs instead of replacing all related 

construction, only the specific damaged area will need repair. Identifying water, wind (and 

other) damage from the outside is paramount to identifying the source to understand the 

Building Science repair options. This data establishes the required baseline images to access 

further employment to access follow-on intrusive studies and support infrared comparison 

analysis, energy surveys and reporting. This aerial study in non-intrusive and my reports 

lead to employment for intrusive (core-sampling) clients for the public community. This 

ability to accurately re-create the exact same GPS derived flight patterns will provide 

invaluable data without the undue risk I currently use flying conventional manned aircraft. 

17
The C-IT DJI Inspire 1 UAS technology and automation make this effort faster with less 

people involved, resulting in less risk for people, equipment and land (environmental, 

agricultural and animals) as well as a safer NAS for the public.

 2. The Public Will Benefit From Decreased Congestion Of The NAS. 

 The DJI Inspire 1 UAS is battery powered and serves 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 public safety of life 

and property in the air and on the ground. 

 Furthermore, this will reducing the number of manned aircraft, it’s congestion and air 

traffic controllers time reducing aerospace and public liability and risk. The DJI Inspire 1 

UAS does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial survey 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. 

 3. 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 survey flight operations. By using battery power 

and electric motors, the DJI Inspire 1 UAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, internal combustion engine 

helicopter or a plane that is typically utilized for these aerial acquisitions, while burning 

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

aerial acquisitions, also reduces noise pollution (as I often get low altitude helicopter noise 

18
complaints from college students), as the UA is propelled by battery powered electric motors, 

rather than an internal combustion engine. 

 By using the DJI Inspire 1 UAS to perform aerial acquisitions, 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 7.5 pounds at its maximum gross weight with a diameter of 23 

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 aerial acquisitions (weighing up to 2,500 pounds with a rotor diameter or wingspan 

up to 33 feet, a length of 33 feet, and a fuel capacity up to 75 gallons). 

 4. Performing Aerial Acquisition Operations With The DJI Inspire 1 UAS 

Will Benefit The Economy. 

 In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical 

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the 

DJI Inspire 1 UAS will allow United States based companies, like C-IT, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost 

of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered DJI 

Inspire 1 UAS is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft and support personal. 

By operating the DJI Inspire 1 UAS, companies such as C-IT can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which 

will ultimately contribute to growth of the U.S. economy. Improved financial performance of 

U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax revenues; 

19
and allows companies to invest in research and development in order to remain competitive 

both in the United States and abroad. 

5. There Are No Privacy Issues. 

 Similar to the manned aerial acquisition flight operations that have been conducted 

for decades, C-IT’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 accordance with 

the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

§ 91.119. Most significantly, the DJI Inspire 1 UA will not be operated closer than 100 feet 

to any person, vessel, vehicle, or structure, which is not directly involved in the operation to 

collect data and images mostly around and directly above buildings. 

E. 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 C-IT Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UAS Meets The Conditions Of The FAA 

 Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited geographical areas associated 

with the unmanned aircraft and its proposed flight operations, C-IT’s operation of the DJI 

Inspire 1 UAS meets the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a hazard 

to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, 

FMRA Section 333 states the following, in part: 

 (a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation shall 

20
determine if certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the plan and rule making required by section 332 of this Act or 

the guidance required by section 334 of this Act. 

 (b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-- 

 (1) which types of unmanned aircraft systems, if any, as a result of their size, 

 weight, speed, operational capability, proximity to airports and populated 

 areas, and operation within visual line of sight do not create a hazard to users 

 of the national airspace system or the public or pose a threat to national 

 security; and 

 (2) whether a certificate of waiver, certificate of authorization, or 

 airworthiness certification under section 44704 of title 49, United States Code, 

 is required for the operation of unmanned aircraft systems identified under 

 paragraph (1). 

 (c) Requirements for Safe Operation.--If the Secretary determines under this section 

 that certain unmanned aircraft systems may operate safely in the national airspace 

 system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

 In seeking this exemption, C-IT 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. 

 2. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics. 

a. The DJI Inspire 1 UAS does 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. 

21
 The technical specifications of the DJI Inspire 1 UAS are set forth at pages 

 57-60 of the DJI Inspire 1 User Manual (dated 2014.12), attached hereto as 

 Exhibit A. 

 ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation 

 Modes Enable The UAS To Remain Within A Defined Operational Area. 

 The DJI Inspire 1 UAS may be operated in either the semi-autonomous or 

 fully-autonomous flight modes. In its basic configuration, the DJI Inspire 1 

 UAS autonomous flight mode features include a GPS Position and Altitude 

 Hold, and a Return To Home (RTH) function. While utilizing the GPS 

 Position and Altitude Hold feature, the UA will automatically hold its 

 position, altitude and heading. The RTH function commands a direct route to 

 the original point of launch, where the UA will perform an autonomous 

 landing. This UAV has three modes; a Smart RTH by depressing one button, a 

 Low Battery RTH where the aircraft will automatically return to home if no 

 action is taken after a 10 second countdown and Failsafe RTH when Aircraft 

 will return to home immediately after communications is lost for 3 seconds.

 A complete description of the GPS Position and Hold function of the DJI 

 Inspire 1 UAS is provided at pages 27-28 of the DJI Inspire 1 User Manual, 

 referenced in an internet link hereto as Exhibit A. 

 iii. The DJI Inspire 1 UAS Is Designed For Automatic Return To 

 Home Or Auto-Land In The Event Of Loss Of The Control Link 

 Or Navigation. 

 According to the manufacturer of the DJI Inspire 1 UAS, in the unlikely event of a 

low battery condition or loss of the control link, the UA will automatically land or return to 

the point of launch. An altitude threshold can also be programmed, so that the UA will not 

exceed a preset altitude. 

Through the GCS, the PIC may select whether the UA will return to the point of launch or 

automatically land in the unlikely event of the loss of the control link. If the automatic 

landing feature is selected, the UA will begin a slow, safe, automatic descent to landing if the 

22
control link is lost. Through feedback via on-board inertia sensors, the UA motors are turned 

off and the rotors stop spinning, when the UA touches down upon landing. 

 Upon a loss of the control link, if the return to point of launch is selected, the UA will 

begin to return to the point of launch, in a direct line. Once the UA returns to the point of 

launch, it will hover to begin the manual landing process, or, if the control link has not been 

reestablished, the UA will automatically land. If the control link is reestablished during a 

loss of control link situation, the PIC may begin to manually control the UA. 

 Additionally, the PIC will receive audible and visual alerts in the event of degradation 

of the GPS signal or control link. If weak GPS satellites are within range of the DJI Inspire 1 

UAS, the PIC will receive an audible and visual “Low or No GPS Warning”, which will also 

disable the GPS Position and Hold feature, as well as the RTH feature. Likewise, the DJI 

Inspire 1 UAS will provide an audible and visual warning to the PIC at the GCS if the control 

link is lost, while the UA enters failsafe mode and either begins to return to the point of 

launch, or automatically lands, depending upon the PIC’s previous settings. Once the control 

link is reestablished, the PIC will be notified through audible and visual alerts on the remote 

controller and the iOS device. Flight Mode P-GPS is GPS and Vision Positioning are 

available in the aircraft is using GPS for positioning. 

 A description of the fail-safe systems of the DJI Inspire 1 UAS is referenced hereto as 

Exhibit B, pager 45-48. 

 iv. The DJI Inspire 1 GCS And Its Operation. 

 A complete description of the operation and specifications of the DJI Inspire 1 UAS 

and flight control software is provided in the DJI Inspire 1 User Manual. A copy of the DJI 

Inspire 1 User Manual is referenced hereto as Exhibit B, Chapter titled, Flight, page 44-51. 

 b. Flight Operations Of The DJI Inspire 1 UAS Are Limited To The Line Of 

 Sight Of A Certificated Pilot in Command FPV with A Safety Observer. 

23
C-IT, LLC will only utilize certificated pilots who possess a valid and current airman medical 

certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally, during 

FPV, a safety observer will assist all pilots. 

c. Flights Of The DJI Inspire 1 Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, C-IT proposes to commercially operate the DJI Inspire 1 

for the special purpose of conducting aerial acquisitions over areas of United States, 

pursuant to the following specific operating limitations: 

 1) Operations authorized by this grant of exemption are limited to the following 

 aircraft described in the operator’s manual which is a quad rotor aircraft weighing less 

 than 8 pounds for take-off weight for the DJI Inspire 1 Unmanned Aircraft System. 

 Proposed operations of any other aircraft will require a new petition or a petition to 

amend this grant. 

 2) The UA may not be flown at an indicated airspeed exceeding 43 knots. 

 3) The UA must be operated at an altitude reported to ATC for the coordinated set 

time above ground level (AGL) or building, as indicated by the procedures specified in the 

operator’s manual and reported to ATC in feet AGL. 

4) The UA 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. 

 5) All FPV operations must utilize a visual observer (VO). The VO may be used 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 must be designated 

before the flight and cannot transfer his or her designation for the duration of the flight. 

 6) The operator’s manual and this grant of exemption must be maintained and made 

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

and limitations in this exemption and the procedures outlined in the operator’s manual, the 

conditions and limitations herein take precedence and must be followed. Otherwise, the 

24
operator must follow the procedures as outlined in its operator’s manual. The operator may 

update or revise its operator’s manual. 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. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted this exemption, then the operator must petition for amendment 

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operator’s manual. 

 7) Prior to each flight the PIC must inspect the UAS to ensure 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. 

 8) 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 in accordance with the operator’s manual. The PIC who 

conducts the functional test flight must make an entry in the UAS aircraft records of the 

flight. The requirements and procedures for a functional test flight and aircraft record entry 

must be added to the operator’s manual. 

9) The preflight inspection must account for all discrepancies, i.e. inoperable 

components, items, or equipment, not covered in the relevant preflight inspection sections of 

the operator’s manual. 

 10) The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements, with particular 

attention to flight critical components that may not be addressed in the manufacturer’s 

manuals. 

 11) C-IT must carry out their maintenance, inspections, and record keeping 

requirements in accordance with the operator’s manual. Maintenance, inspection, and 

25
alterations must be noted in the aircraft logbook, including total flight hours, description of 

work accomplished, and the signature of the authorized UAS technician or PIC returning the 

UAS to service. 

12) C-IT UAS technicians must receive and document training referenced in the 

operator’s manual. 

13) Each UAS operated under this exemption must comply with all manufacturer 

System and Safety Bulletins. 

14) C-IT maintenance personnel must make a record entry in the UAS logbook or 

equivalent document of the corrective action taken against discrepancies discovered between 

inspections. 

15) The PIC must possess at least a private pilot certificate and a third-class airman 

medical certificate. 

 16) The operator may not permit any PIC to operate unless that PIC has 

demonstrated, through the training and currency requirements set forth in the operator’s 

manual, that the PIC is able to safely operate the UAS in a manner consistent with how the 

UAS will be operated under this exemption, including evasive and emergency maneuvers and 

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

 17) 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). Flights 

under special visual flight rules (SVFR) are not authorized. 

 18) The UA may not operate without ATC coordination within 5 nautical miles of the 

airport reference point as denoted on a current FAA-published aeronautical chart. 

20) 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. 

21) If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property and land, or be 

recovered in accordance with the operator’s manual. 

 22) The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator’s manual. 

26
23) The PIC is prohibited from beginning a UAS flight unless (considering wind and 

forecast weather conditions and assuming normal cruising speed) there is enough power to 

fly to the first point of intended landing prior to utilizing battery reserve power. 

 24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

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

exemption. This COA will also require the operator to request issuance of a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation unless COA authority approves. Often the Prog Chart weather data is not available 

unlit 48 hours in advance.

25) All aircraft operated in accordance with this exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as 

large as practicable. 

26) 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. 

 27) The documents required pursuant to 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official upon 

request. 

28) The UA must remain clear and yield the right of way to all other 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) The UA may not be operated over congested or densely populated areas. 

Ultimately, it is the PIC’s responsibility to maintain the minimum safe altitudes required by § 

91.119. 

 31) Flight operations must be conducted at least 100 feet from all nonparticipating 

persons (persons other than the PIC or VO), vessels, vehicles, and structures unless: 

27
 a. Barriers or structures are present that sufficiently protect nonparticipating persons 

 from debris in the event of an accident. The operator must ensure that 

 nonparticipating persons remain under such protection. If a situation arises where 

 nonparticipating persons leave such protection and are within 100 feet of the UA, 

flight operations must cease immediately and/or; 

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

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

risk of operating closer to those objects and; 

 c. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, 

per § 91.119(a). 

 32) All operations shall be conducted over private or controlled-access property with 

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

land owner/controller or authorized representative will be obtained prior to the beginning of 

every flight. 

 33) 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. 

 3. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety. 

C-IT submits that the equivalent level of safety established by Section 61.113(a) and (b) will 

be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that 

PIC has demonstrated, through the DJI Inspire 1 UAS training and currency requirements, 

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. 

Considering C-IT’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those 

28
of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the DJI Inspire 1 UAS, C-IT submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for C-IT’s specific proposed flight operations. 

Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) 

specific to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138). 

As in Exemption No. 11109, C-IT will not allow any PIC to operate the DJI Inspire 1 

UAS unless that PIC has demonstrated through the DJI Inspire 1 UAS training and currency 

requirements, 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. 

 A complete description of the DJI Inspire 1 UAS Training and Qualification 

requirements is set forth in Exhibit D. Exhibit D contains proprietary information and is to be 

held in a separate file pursuant to 14 C.F.R. § 11.35(b). Exhibits to this Petition contain 

proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included 

in the Federal Docket Management System (FDMS). 

4. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

 Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior 

to every flight, C-IT will ensure that the DJI Inspire 1 UAS is in an airworthy condition 

based upon the aircraft’s conformity to its type design, including compliance with its 

operating documents (i.e., the DJI Inspire 1 User Manual and the DJI Inspire System 

Maintenance Manual), and that the UA is in a condition for safe flight, as stated in the 

conditions and limitations contained herein. 

5. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

29
 The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Inspire 1 UA will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UA to 

the PIC remote controller for active monitoring of the flight path and altitude. This altitude 

information, combined with C-IT’s operation of the DJI Inspire 1 UA within visual line of 

sight will ensure a level of safety equivalent to Section 91.121. The altitude information will 

be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a 

calibration zero altitude initiation point is automatically established by the UAS. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138). 

6. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

 Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, C-IT will ensure that it will safely operate the 

battery powered DJI Inspire 1 UA during daylight hours in VMC conditions, under VFR, 

with enough battery power to fly for a total duration of at least 13 minutes to the first point of 

intended data collection and, assuming normal cruising speed, to fly after that for at least five 

minutes (i.e., 27 percent battery power remaining). 

 C-IT hereby submits that the technical specifications of the DJI Inspire 1 UAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, 

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, an equivalent level of safety will be ensured as the DJI Inspire 1 UAS provides 

audible and visual warnings to the PIC when the UA reaches Low Warning (20 percent) and 

Critical Warning (10 percent) of battery power remaining. 

 Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and operating 

30
limitations of the UAS are considered. Relief has been granted for manned aircraft to operate 

at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 

5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 

specific to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138). 

7. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

 Affect Safety. 

 In seeking this exemption, C-IT submits that an equivalent level of safety with regard 

to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because C-IT will use 

manufacturer trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

manufacturer’s maintenance manual. Furthermore, C-IT will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

 Since the DJI Inspire 1 UAS will be inspected as prescribed by the manufacturer’s 

maintenance manual, C-IT will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The DJI Inspire System Maintenance 

Manual sets forth airworthiness requirements for the UA, including preflight inspections, 

post flight inspections and at 500 electric motor flight hours.

 Likewise, the exemption sought will not adversely affect safety because C-IT will use 

manufacturer trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

manufacturer’s maintenance manual. The DJI Inspire System Maintenance Manual details 

procedures for inspection, firmware upgrades, motor testing, and motor replacement. A 

complete description of the DJI Inspire 1 UAS maintenance requirements is set forth in the 

31
DJI Inspire System Maintenance Manual, attached hereto as Exhibit B. Exhibit B contains 

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI 

Inspire 1 UAS will be performed by manufacturer trained technicians, which will document 

and maintain maintenance records for the UAS. 

Significantly, previous exemptions granted by the FAA concerning the DJI Inspire 1 UAS 

and Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish 

that safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. 

In consideration of C-IT’s proposed operating limitations, the DJI Inspire 1 User 

Manual, and the technical aspects of the DJI Inspire 1 UAS, C-IT submits that safety will not 

be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) 

and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138). 

 8. The FAA May Prescribe Any Other Conditions For Safe Operation. 

 In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, C-IT requests that the FAA 

prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, which 

contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

 Such special conditions will permit C-IT’s safe operation of the UA for the limited 

purpose of conducting aerial acquisitions over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

32
whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or 

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or 

propeller because of a novel or unusual design feature of the aircraft, aircraft 

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16. 

 Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for C-IT’s intended operation of the DJI Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level 

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which C-IT Seeks Exemption: 

33
 C-IT, Inc. seeks exemption from the requirements of 14 C.F.R Sections 

 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption C-IT Seeks: 

This exemption will permit C-IT, Inc. to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial acquisitions and research over 

certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support C-IT’s 

Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, C-IT’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, C-IT will operate the DJI Inspire 1 UAS safely in the NAS, 

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security. 

CONCLUSION

As set forth herein, C-IT seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for 

the limited purpose of conducting aerial acquisitions over certain areas of the United States 

for compensation or hire. By granting this Petition, the FAA Administrator will be fulfilling 

the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

34
advancing the interests of the public, by allowing C-IT to safely, efficiently, and 

economically operate the DJI Inspire 1 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, C-IT respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), and permit C-IT to operate the DJI Inspire 1 UAS commercially 

for the purpose of conducting aerial acquisitions and research over certain areas of the United 

States. 

Dated: May 28, 2015 Respectfully submitted, 

____________________________ 

Roger Selch

1551 Highland Road

Winter Park, Florida 32789 

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EXHIBIT 

 TAB 

ALL TECHNICAL SPECIFICATIONS OF THE DJI INSPIRE 1 UAS..................A 

(REF: http://www.dji.com/product/inspire-1/spec) 

DJI INSPIRE 1 USER MANUAL (EN) v1.2 15May2015..................................B 

(Go to interest link: http://www.dji.com/product/inspire-1/download for 64 pages.)

DJI INSPIRE 1 MAINTENANCE MANUAL V 1.0 28 Feb 2015........................C 

INSPIRE 1 TRAINING AND QUALIFICATIONS REQUIREMENTS........................D 

36
TAB A 

ALL TECHNICAL SPECIFICATIONS OF THE DJI INSPIRE 1 UAS 

REF: http://www.dji.com/product/inspire-1/spec 

Model T600 (Inspire 1) 

3510 motors and 1345 propellers 

T47 Factory default battery 4500mAh & optional T48 is 5600mAh 

Weight (Battery Included) – 2935 g 6.47lbs 

Takeoff Weight 3400 g or 7.5lbs (see wiki.com 

Diagonal Size 559mm (22.01in) to 581mm (22.87in) 

Hovering Accuracy (GPS mode) Vertical:0.5 m, Horizontal:2.5m 

Max Angular Velocity: Pitch: 300°/s, Yaw: 150°/s 

Max Tilt Angle: 35° 

Max Ascent Speed: 5 m/si 

Max Descent Speed: 4 m/s 

Max Speed: 22 m/s (ATTI mode, no wind) = 49.2mph = 42.8Kts 

Max Flight Altitude: 4500 m. or 14,764 feet 

Max Wind Speed Resistance: 10 m/s or 22.4mph 

Max Flight Time: Approximately 18 minutes 

Indoor Hovering: Enabled by default 

Camera: X3, Model FC350i 

Resolution: 12.0 MP 

FOV (Field of View): 94° 

CMOS: Sony EXMOR 1/2.3” 

Lens: f/2.8 (20 mm equivalent) 9 Elements in 9 groups, Aspherical lens element, Antidistortion filter, UV filter 

Still Photography Modes: Single shoot, Burst shooting (BURST: 3/5/7 frames,AEB: 3 or 5 

bracketed frames at 0.7EV Bias), Time lapse 

HD Video Recording Modes: UHD (4K): 4096x2160p24/25,3840x2160p24/25/30 

FHD: 1920x1080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

Max Bitrate of Video Storage: 60 Mbps 

Supported File Formats: FAT32/exFAT 

Photo: JPEG,DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported SD Card Types 

SD/SDHC/SDXC Micro SD 

Max capacity: 64 GB. Speed: Class 10 or higher. A UHS-1 type micro-SD card is 

recommended, because the fast read and write capability of these cards enables you to store 

high-resolution video data. 

Battery: 6000 mAh LiPo 2S

37
TAB B 

DJI INSPIRE 1 USER MANUAL (EN) v1.2 15May2015 

(Go to interest link: http://www.dji.com/product/inspire-1/download for 64 pages.) 

A complete description of the DJI Inspire 1 UAS User Manual is set forth in the DJI Inspire 

User Manual, linked hereto as Exhibit B. Exhibit B contains proprietary information and is to 

be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

38
TAB C 

DJI INSPIRE 1 MAINTENANCE MANUAL V 1.0 28 Feb 2015 

A complete description of the DJI Inspire 1 UAS maintenance requirements is set forth in the 

DJI Inspire System Maintenance Manual, attached hereto as Exhibit C. Exhibit C contains 

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

39
40
41
TAB D 

INSPIRE 1 TRAINING AND QUALIFICATIONS REQUIREMENTS

A complete description of the DJI Inspire 1 UAS Training and Qualification requirements is 

set forth in Exhibit D. Exhibit D contains proprietary information and is to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b). Exhibits to this Petition contain proprietary 

information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included in the 

Federal Docket Management System (FDMS). 

 

License/Certification/Training Course Title and Date for Roger Selch 

Private Pilot, Airplane Single Engine Land, 23 September 1988 

Medical Certificate Second Class, 13 February 2015 

Drone-Bootcamp, 8 hours, http://aboveitallvideo.com/drone-bootcamp, 15 February 2015 

DJI New Pilot Experience, 4 hours 25 April 2015 

Infrared Training Center, ID#24094 Certified Level III Thermographer, 21 May 2007 

Infrared Training Center, ID#24094 Certified Building Science, 26 June 2009 

Service-Disabled Veteran-Owned Small Business (SDVOSB) 

42