UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

FLIGHT EVOLVED, 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 INSPIRE 1 UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 

2012 (PUBLIC LAW 112-95)

Submitted on October 16, 2015 

Flight Evolved, LLC

523 W Main Street

Hamilton, MT 59840

701-290-0222
FAA	Petition	for	Exemption 2

Flight	Evolved,	LLC	– October	16,	2015

TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY 4 

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4 

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 6

FLIGHT EVOLVED, LLC SEEKS EXEMPTION 

THE EXTENT OF RELIEF FLIGHT EVOLVED, LLC SEEKS AND 9

THE REASON FLIGHT EVOLVED, LLC SEEKS THE RELIEF 

THE REASONS WHY GRANTING FLIGHT EVOLVED, LLC 10

REQUEST WOULD BE IN THE PUBLIC INTEREST 

THE REASONS WHY GRANTING THE EXEMPTION WOULD 12

NOT ADVERSELY AFFECT SAFETY 

CONCLUSION 21

APPENDIX A—DJI INSPIRE 1 TECHNICAL SPECIFICATIONS SHEET 

APPENDIX B—DJI INSPIRE 1 MANUAL 

APPENDIX C—FLIGHT EVOLVED, LLC MONTHLY MAINTENANCE LOG 
FAA	Petition	for	Exemption 3

Flight	Evolved,	LLC	– October	16,	2015

GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command

FMRA Section 333 FAA Modernization and Reform Act of 2012

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing 
FAA	Petition	for	Exemption 4

Flight	Evolved,	LLC	– October	16,	2015

SUMMARY 

Flight Evolved, 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 (UAS) pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA). This exemption will permit Jordan J. Rising, Co-Owner of Flight Evolved, LLC,

to operate a UAS for the commercial purpose of conducting aerial video and photography to be used 

in real estate, construction and engineering projects, special events (such as weddings and parties), 

sporting events, construction inspection purposes, 3D mapping and modeling, Hollywood-style 

videography, and other purposes as Flight Evolved, LLC may determine or may be requested from 

time to time that are allowed under local and Federal Law over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Flight Evolved, LLC is a limited liability company formed under the laws of the state of Montana by 

Jordan J. Rising. Mr. Rising resides in Hamilton, Montana. Mr. Rising (aged 27 years) is a licensed 

commercial helicopter pilot (Commercial Certificate # 003615342) and has four years of private and 

commercial rotorcraft experience. Mr. Rising also has a Bachelor of Science in Biological Sciences. 

Mr. Rising has long-standing interests in technology, professional photography and videography.

Mr. Rising has spent a good portion of his life engaged in cutting edge technology and using it as a 

tool to help him better professional services surrounding photography and videography. Additionally, 

Mr. Rising has an active interest in the aviation community through his commercial rotorcraft 

certificate and training in the policies and procedures of commercial rotorcraft operation. 

Mr. Rising’s objective is to provide aerial photography and videography services through their entity,

Flight Evolved, LLC, for a variety of commercial and public uses, including, but not limited to, the 

following: 

• Real estate assessments and photography/videography;

• Environmental remediation/reclamation projects;

• Engineering project evaluations (e.g., before/during/after inspections);

• Special events (e.g., weddings, private parties, golf tournaments, charity events);

• Documenting construction projects;

• 3D mapping and modeling for industrial, engineering, architecture, and real estate purposes; and

• Professional (Hollywood-style) productions for producers and other high-end entertainment 

projects. 

BACKGROUND 

UAS: DJI Inspire 1 UAS

Flight Evolved, LLC seeks an exemption to operate the DJI Inspire 1 UAS for compensation or hire 

within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft 

System (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. The DJI Inspire 1 UAS has a maximum gross weight of 6 pounds 7.5 ounces, a length of 
FAA	Petition	for	Exemption 5

Flight	Evolved,	LLC	– October	16,	2015

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 

knots. The DJI Inspire 1 UAS is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 

The DJI Inspire 1 UAS that will be operated by Flight Evolved, LLC 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. 

BASIS FOR PETITION 

Petitioner, Flight Evolved, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FMRA, Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the National 

Airspace System (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 speed, weight, size, and limited operating area associated with the UAS and 

its operation, Flight Evolved, LLC operation of the DJI Inspire 1 UAS meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Accordingly, Flight Evolved, LLC 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. Flight Evolved, LLC

submits that the requested relief is proper since an equivalent level of safety will be ensured. Flight 

Evolved, LLC will use experienced personnel or technicians to perform maintenance, alterations, or 

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

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

Furthermore, Flight Evolved, LLC will document and maintain all maintenance records for the DJI 

Inspire 1 UAS and will have those records available for inspection by government authorities, if 

requested. 

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

limitations: Pilot in Command (PIC), is requested by Flight Evolved, LLC to the extent necessary to 

allow a PIC holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight hour 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. 

Flight Evolved, LLC 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, Flight Evolved, LLC submits that they 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 the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual), and that the aircraft is in a condition for safe flight. 

Flight Evolved, LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude 

information, combined with Flight Evolved, LLC’s operation of the DJI Inspire 1 UAS within visual 

line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 
FAA	Petition	for	Exemption 6

Flight	Evolved,	LLC	– October	16,	2015

Additionally, Flight Evolved, LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Flight Evolved, LLC submits that safety will 

not be affected by operation of the DJI Inspire 1 UAS during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal 

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

In accordance with 14 C.F.R. § 11.81, Flight Evolved, LLC 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 and point of contact is: 

Flight Evolved, LLC

Jordan J. Rising, Co-owner

523 W. Main Street

Hamilton, Montana 59840

701-290-0222

Email: jordan@flight-evolved.com

B. The Specific Sections of 14 C.F.R. From Which Flight Evolved, LLC Seeks Exemption. 

1. Flight Evolved, LLC 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. Flight Evolved, LLC 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. Flight Evolved, LLC Seeks Exemption From The Requirements Of Section 91.121. 
FAA	Petition	for	Exemption 7

Flight	Evolved,	LLC	– October	16,	2015

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. Flight Evolved, LLC 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. Flight Evolved, LLC 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. Flight Evolved, LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1). 

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. Flight Evolved, LLC 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 
FAA	Petition	for	Exemption 8

Flight	Evolved,	LLC	– October	16,	2015

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. Flight Evolved, LLC 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: 

(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. 
FAA	Petition	for	Exemption 9

Flight	Evolved,	LLC	– October	16,	2015

(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 Flight Evolved, LLC Seeks and The Reason Flight Evolved, LLC

Seeks The Relief. 

1. Extent Of Relief Flight Evolved, LLC Seeks And The Reason Flight Evolved, LLC 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 (PIC), is requested to the extent necessary to allow a PIC holding a private pilot 

or higher level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour 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, Flight Evolved, LLC 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 

met certain flight-hour and currency requirements, demonstrating 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, Flight Evolved, LLC submits that all flights of DJI Inspire 1 UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Flight Evolved, LLC’s business; and (2) 

will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Flight Evolved, LLC Seeks And The Reason Flight Evolved, LLC 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 Flight Evolved, LLC to determine that the DJI Inspire 1 UAS are in airworthy condition prior 

to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the 

Flight Evolved, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). 

Flight Evolved, LLC 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, Flight Evolved, 

LLC will ensure that the DJI Inspire 1 UAS is in airworthy condition based upon its compliance with 

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

prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated 

in the conditions and limitations below. 
FAA	Petition	for	Exemption 10

Flight	Evolved,	LLC	– October	16,	2015

3. Extent Of Relief Flight Evolved, LLC Seeks And The Reason Flight Evolved, LLC 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 utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), Flight Evolved, 

LLC seeks the requested relief because the DJI Inspire 1’s altimeter may be set on the ground to 

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

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

the extent necessary to comply with the applicable conditions and limitations stated below. As more 

fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 UAS 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 UAS on the heads-up display of the GCS. 

4. Extent Of Relief Flight Evolved, LLC Seeks And The Reason Flight Evolved, LLC Seeks 

Relief From Section 91.151(b). 

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

the extent required to allow flights of the battery powered DJI Inspire 1 UAS during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 4.5 minutes. Flight Evolved, LLC seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAS

will severely constrain the practicality of any aerial video or still photo flight operations that Flight 

Evolved, LLC proposes to conduct pursuant to this Petition. 

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

Inspire 1 operating documents, and Flight Evolved, LLC proposed operating limitations, ensure that 

Flight Evolved, LLC will safely operate the battery powered DJI Inspire 1 UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough 

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

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

5. Extent Of Relief Flight Evolved, LLC Seeks And The Reason Flight Evolved, LLC 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, Flight Evolved, LLC 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 FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Flight Evolved, LLC will use trained technicians to perform 

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

practices prescribed in the UAS operating documents (i.e., the Flight Evolved, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, Flight Evolved, LLC will document and maintain all maintenance records for DJI 

Inspire 1 UAS. 

D. The Reasons Why Granting Flight Evolved, LLC Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 
FAA	Petition	for	Exemption 11

Flight	Evolved,	LLC	– October	16,	2015

Granting the present Petition will further the public interest by allowing Flight Evolved, LLC to 

safely, efficiently, and economically perform aerial video and photography of real estate, 

environmental / engineering projects, social events, construction projects, sporting events, and 

Hollywood-style projects over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Flight Evolved, LLC’s proposed 

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

1. 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. It would also reduce noise 

and air pollution, as well as increase the safety of life and property in the air and on the ground. 

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

airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS does not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

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

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

benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and electric 

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

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 gallons per 

hour of leaded aviation fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS’ are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 UAS to perform aerial 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 UAS (weighing approximately 6 

pounds 7.5 ounces at its maximum gross weight, with lengths 17.3 inches, widths of 17.7 inches, and 

with no fuel on board), has less physical potential for collateral damage to life and property on the 

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

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography 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 similar aerial operations. As such, operation of the DJI Inspire 1 

UAS will allow United States based companies, like Flight Evolved, LLC, 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. 
FAA	Petition	for	Exemption 12

Flight	Evolved,	LLC	– October	16,	2015

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. 

By operating the DJI Inspire 1 UAS, companies such as Flight Evolved, LLC, 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; and allows companies 

to invest in research and development in order to remain competitive both in the United States and 

abroad. 

4. There Are No Privacy Issues. 

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

Flight Evolved, LLC’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy 

issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating 

documents (i.e., the Flight Evolved, LLC Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law 

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

minimum altitude requirements of 14 C.F.R. § 91.119. 

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 Flight Evolved, LLC 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 operating area associated with the unmanned 

aircraft and its operation, Flight Evolved, LLC’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 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 
FAA	Petition	for	Exemption 13

Flight	Evolved,	LLC	– October	16,	2015

(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, Flight Evolved, LLC submits that the DJI Inspire 1 UAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 

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

The DJI Inspire 1 UAS 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. 

The technical specifications of the DJI Inspire 1 UAS is set forth by the DJI Inspire 1 Specifications 

and Data Sheet, attached hereto as Appendix A and B. 

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 both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided at 

pages 12-16 and 45-50 of the DJI Inspire 1 User Manual, attached hereto as Appendix C and D. 

iii. The DJI Inspire 1 UAS Is Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds 

or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control link data from the 

GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home 

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A 

complete description of the Failsafe Functions of the DJI Inspire 1 UAS is set forth at pages 13 

through 15 of the DJI Inspire 1 User Manual, attached hereto as Appendix C and D. 

iv. The DJI Inspire 1 GCS And Its Operation. 

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

software is provided at pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Inspire 1 User 

Manuals are attached hereto as Appendix C and D. 

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Flight Evolved, LLC will only utilize FAA certificated pilots who possess a current and valid airman 

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

observer will assist all pilots during flight time. 

c. Flights Of DJI Inspire 1 UAS Will Be Conducted 
FAA	Petition	for	Exemption 14

Flight	Evolved,	LLC	– October	16,	2015

Pursuant To Specific Operating Limitations. 

In seeking this exemption, Flight Evolved, LLC proposes to commercially operate a DJI Inspire 1 

UAS for the special purpose of conducting aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations: 

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

in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight:

DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant. 

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

aerial video and photography. 

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

4. The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

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

and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

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

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed 

in the operating documents. 

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

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

camera or other instruments. 

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

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

conditions and limitations contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in 

its operating documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, then the

operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 

If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 
FAA	Petition	for	Exemption 15

Flight	Evolved,	LLC	– October	16,	2015

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. 

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

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

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

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

replacement, inspection, and life limit requirements. 

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

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

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

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

UAS to service. 

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

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

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third-class medical 

certificate. 

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

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

with how the UAS will be operated under the exemption, including evasive and emergency 

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

PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). 

Flights for the purposes of training the operator’s PICs are permitted under the terms of the 

exemption. However, training operations may only be conducted during dedicated training sessions. 

During training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

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

must be conducted under visual meteorological conditions (VMC). If flight at night is required, a 

special request will be made at the FAA office closest to proposed area of operations. Flights under 

special visual flight rules (SVFR) are not authorized. 

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

current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as required 

by the operator’s COA. The letter of agreement with the airport management must be made 

available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 
FAA	Petition	for	Exemption 16

Flight	Evolved,	LLC	– October	16,	2015

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined 

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

documents. 

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

with the operating documents. 

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UAS with 25% battery power remaining. 

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

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

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

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

registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

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

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

government oversight agency requirements. 

28. The documents required fewer than 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 UAS is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

29. The UAS must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or 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 500 feet of the UA, flight operations must cease immediately and/or; 

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

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an undue hazard, 

and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with permission from 
FAA	Petition	for	Exemption 17

Flight	Evolved,	LLC	– October	16,	2015

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

authorized representative will be obtained for each flight to be conducted. 

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. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety. 

Flight Evolved, LLC 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, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Considering Flight Evolved, LLC’s proposed area of operations, and the operating limitations set 

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

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the DJI Inspire 1 UAS, Flight Evolved, LLC submits that the additional manned 

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

skills necessary for Flight Evolved, LLC’s specific proposed flight operations. Despite this request for 

exemption, Mr. Rising, as Co-Owner of Flight Evolved, LLC, is a commercially certified pilot and 

does, in fact, bring the additional manned airmanship experience of a commercially certified pilot.

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, 11150, 11153, 

11156, 11158, 11159, 11160, 11161). 

Flight Evolved, LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or 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. Specifically, the PIC must have 

accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the exemption). In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

Flight Evolved, LLC’s proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 
FAA	Petition	for	Exemption 18

Flight	Evolved,	LLC	– October	16,	2015

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption 

No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive rather than 

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and 

the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption 

No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct 

the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that 

was obtained in compliance with applicable regulations would satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building flights the 

PIC is required to operate the UAS with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. Accordingly, Flight Evolved, LLC will ensure safe operations by 

not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

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

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

3. 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, Flight Evolved, LLC will ensure that the DJI Inspire 1 UAS is in an airworthy condition 

based upon the UAS’s compliance with its operating documents and as stated in the conditions and 

limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) 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, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring 

of the flight path and altitude. This altitude information, combined with Flight Evolved, LLC’s 

operation of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, 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 zero altitude initiation point is 

automatically established by the UAS at ground level. 

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, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 
FAA	Petition	for	Exemption 19

Flight	Evolved,	LLC	– October	16,	2015

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, 

Flight Evolved, LLC will ensure that it will safely operate the battery powered DJI Inspire 1 UAS

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 4.5 minutes. 

Here, as in Exemption No. 11109, 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, safety will be 

ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when 

the UAS experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. At the critically 

low battery level, the DJI Inspire 1 UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating 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, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. 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, Flight Evolved, LLC submits that the 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 Flight Evolved, LLC will 

use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the operating documents (i.e., the Flight 

Evolved, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction 

Manual). 

Furthermore, Flight Evolved, LLC 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 operating 

documents, Flight Evolved, LLC will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manual is attached hereto 

as Appendix C and D; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as 

Appendix E. 

Likewise, the exemption sought will not adversely affect safety because Flight Evolved, LLC will use 

trained technicians to perform maintenance, alterations or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed by the operating documents. 

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 trained technicians. Maintenance will be documented and maintained utilizing the 

monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning 

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 
FAA	Petition	for	Exemption 20

Flight	Evolved,	LLC	– October	16,	2015

considered. 

In consideration of Flight Evolved, LLC’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1 UAS, Flight Evolved, LLC 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, 11150, 11153, 

11156, 11157, 11158, 11159,11160, 11161). 

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

In accordance with Section 333 of the FMRA and 14 C.F.R. § 21.16 entitled Special Conditions, 

Flight Evolved, LLC 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 safe operation of the UAS for the limited purpose 

of conducting aerial video and photography over certain areas of the United States for compensation 

or hire. 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 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 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). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which Flight Evolved, LLC Seeks Exemption: 

Flight Evolved, LLC 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 Flight Evolved, LLC Seeks: 

This exemption will permit Flight Evolved, LLC to commercially operate a UAS for the purpose of 

conducting aerial video and photography over certain areas of the United States. 
FAA	Petition	for	Exemption 21

Flight	Evolved,	LLC	– October	16,	2015

• Any Additional Information, Views, Or Arguments Available To Support Flight Evolved, 

LLC. 

This Petition is made pursuant to the FMRA Section 333, which directs the Secretary of 

Transportation to determine if certain UAS may operate safely in the NAS. As such, Flight Evolved, 

LLC’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, Flight Evolved, LLC 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. The co-owner and chief UAS pilot, Jordan Rising, is an instrument and 

commercially FAA rated rotorcraft pilot that is diligent on safety and a major advocate of the NAS 

and its continued safety. 

CONCLUSION 

As set forth herein, Flight Evolved, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FMRA, which will permit safe operation of the DJI Inspire 1 UAS commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FMRA, while also advancing the 

interests of the public, by allowing Flight Evolved, LLC 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 FMRA, Section 333, 

Flight Evolved, LLC 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 Flight Evolved, LLC to 

operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Dated: October 16, 2015

Respectfully submitted,

Flight Evolved, LLC, 

By: _________________________

 Jordan J. Rising, Member

Flight Evolved, LLC

523 W. Main Street

Hamilton, Montana 59840

701-290-0222
FAA	Petition	for	Exemption 22

Flight	Evolved,	LLC	– October	16,	2015

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Flight Evolved, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set parameters 

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no 

higher than a predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location information to the PIC 

via the linked monitor (smart phone/tablet devices). 

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model – T600 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 18 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 17 14” x 17 34” x 12” 

2.2.2 Gimbal 2.2.2.1 

Model – ZENMUSE X3 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 
FAA	Petition	for	Exemption 23

Flight	Evolved,	LLC	– October	16,	2015

2.2.2.4 Angular Vibration Range - ±0.030 

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 2.2.3.1 Name – X3 

2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 

2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

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

FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

2.2.4 Transmitter 

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

2.2.4.6 Battery – 600mAh LiPo 2S 
FAA	Petition	for	Exemption 24

Flight	Evolved,	LLC	– October	16,	2015

APPENDIX – B

DJI INSPIRE 1 USER MANUAL 
FAA	Petition	for	Exemption 25

Flight	Evolved,	LLC	– October	16,	2015

APPENDIX – C

FLIGHT EVOLVED, LLC MONTHLY MAINTENANCE LOG