1 

### UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Docket ID: FAA-2015-2828

IN THE MATTER OF THE PETITION FOR EXEMPTION OF

Petitioner’s Name: WILLIAM TAEK LIM

dba William Lim Real Estate Group, Inc

Federal Employer ID 45-3693049

Address: 10472 San Andreas Dr, Rancho Cucamonga, CA 91737

Phone: 909

‐ 239

‐ 2006

Email: pruwill@gmail.com

FAA Private License Number: 570610106

Ratings & Limitations: Single Engine Land, VFR

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 operations of a DJI Inspire 1 Unmanned Aircraft

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Public Law 112

‐ 95)



### Submitted on October 23, 20152 

### AMENDMENT

Previously proposed use of DJI Phantom Vision 2+ UAS on June 8, 2015

is now changed to

DJI Inspire 1 UAS3 

### TABLE OF CONTENTS

Page



### GLOSSARY OF ABBREVIATIONS 4

SUMMARY 5

INSTRODUCTION AND INTEREST OF PETITIONER 5

BACKGROUND 5

BASSIS FOR PETITION 7

NAME AND ADDRESS OF PETITIONER 7

THE SPECIFIC SECTION OF 14 C.F.R FROM WHICH PETITIONER 7

THE EXTENT OF RELEIF PETITIONER SEEKS AND THE REASON

PETITIONER SEEKS THE RELEIF 10

THE REASON WHY GRANTING PETITIONER’S REQUEST WOULD

BE IN THE PUBLIC INTEREST 13

THE REASON WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY 15

CONCLUSION 254 

### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

A V 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

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

SO Safety Observer

SOP Standard Operating Procedures

U A Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing5 

## SUMMARY

William Taek Lim d/b/a William Lim Real Estate Group, Inc ("Petitioner") 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 Petitioner to

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography for the development, management, marketing, surveying, appraisal and sale of real estate

over certain areas of the United States.



## INTRODUCTION AND INTEREST OF THE PETITTIONER

William Taek Lim d/b/a William Lim Real Estate Group, Inc is a real estate brokerage located in Rancho

Cucamonga, California and serving its clientele by providing cutting edge marketing and media services.

On behalf of and in cooperation with its clients, its principals, owners and affiliates, William Taek Lim

d/b/a William Lim Real Estate Group, Inc engages in various real estate

‐ related functions, including the

marketing and sale of residential and commercial real estate, property management, real estate

development, property inspections, construction and public relations. Petitioner has an interest in using

the DJI Inspire 1 unmanned aircraft system (UAS) to perform the following functions, which are

commercial in nature: • Real Estate Videography and Photography • Standing Timber Videography and

Photography • Land survey & Appraisals • Property and Equipment Inspections • Construction sites

—

Before & After • Creation of Commercial Messages for Internet and Television. • Increase Public

knowledge of UAS and Promote Safe UAS operations.



## BACKGROUND

Unmanned Aircraft System: Inspire 1 UAS

Petitioner seeks an exemption to operate a DJI system for commercial purposes within the NAS.

The DJI Inspire I is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Groimd Control

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross

weight of 6 pounds 7.5 oxmces, a length of 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 I UAS that will be operated by Petitioner 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, William Taek Lim d/b/a William Lim Real Estate Group, Inc

, pursuant to the

provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and

Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate the DJI Inspire 1 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

unmanned aircraft and its operation, Petitioner's, operation of a 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, Petitioner 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.

Petitioner submits that the requested relief is proper since an equivalent level of safety will be

ensured. Petitioner 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, Petitioner will document and maintain all maintenance records for the DJI Inspire I UAS.

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

limitations: Pilot in command, is requested by Petitioner to the extent necessary to allow a Pilot in

Command (PIC) holding a sport pilot or higher level certificate, as well as a valid U.S. driver's license, and

who has demonstrated, by meeting minimum flight

‐ hour and currency requirements, that the PIC is

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

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

and structures.

Petitioner seeks relief from Section 91.7(a), entitled C/v/7 aircraft airworthiness, because the DJI

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

As such. Petitioner 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.

Petitioner 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, altitude

information of the DJI Inspire lUAs will be provided to the PIC via Global Positioning System (GPS)

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

active monitoring of the flight path. This altitude information, combined with Petitioner's operation of7 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.

Additionally, Petitioner seeks an exemption from the requirements of Section 91.151(b), entitled

Fuel requirements for flight in VFR conditions. Petitioner 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, Petitioner 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:

William Taek Lim d/b/a William Lim Real Estate Group, Inc

,

10750 Civic Center Dr., Rancho Cucamonga, CA 91730

(909) 239

‐ 2006

Email: pruwill@gmail.com



## B. The Specific Sections of 14 C.F.R. From Which Petitioner Seeks Exemption.

1. Petitioner Seeks Exemption From The Requirements Of Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of

airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. Petitioner 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—8 (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.

3. Petitioner 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.

4. Petitioner Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled 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)(l)(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.

5. Petitioner 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

6. Petitioner 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[.]

7. Petitioner Seeks Exemption From The Requirements Of Section 91.407(a)(1)9 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[.]

8. Petitioner 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 die 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.

9. Petitioner 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:10 (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.

(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 Petitioner Seeks And The Reason Petitioner Seeks The

Relief.

1. Petitioner Seeks Exemption From The Requirements Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by Petitioner, an

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

Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of11 the size, weight, speed, operational capability, and proximity to airports and populated areas of the

particular UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate

without the restrictions and conditions of the proposed UAS operations.

2. Extent Of Relief Petitioner Seeks And The Reason Petitioner 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 pilot or higher level

certificate, as well as a U.S. driver's license, and who has met certain flight

‐ hour and currency

requirements, to conduct the proposed UAS flight operations for commercial purposes.

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: (I) 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. Petitioner 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, Petitioner 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 Petitioner's business; and (2) will not carry

passengers or property for compensation or hire.

3. Extent Of Relief Petitioner Seeks And The Reason Petitioner 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 Petitioner to determine that the DJI Inspire 1 UAS is in airworthy condition prior to every flight

by ensuring that the UAS is in compliance with the operating documents (i.e., the Petitioner's Aerial

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

Petitioner 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, Petitioner 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.12 4. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seek s 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 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), Petitioner seeks

the requested relief because the DJI Inspire 1 UAS 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 UA on the heads

‐ up display of the GCS.

5. Extent Of Relief Petitioner Seeks And The Reason Petitioner 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. Petitioner 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 Petitioner 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 Petitioner's proposed operating limitations, ensure that Petitioner 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.

6. Extent Of Relief Petitioner Seeks And The Reason Petitioner 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. Petitioner 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, Petitioner will use trained technicians to perform maintenance, alterations,

or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in13 the UAS operating documents (i.e.. Petitioner's Aerial Operations Manual, Monthly Maintenance

Log, and DJI Inspire 1 + Instruction Manual). Furthermore, Petitioner will document and maintain all

maintenance records for the DJI Inspire 1 UAS.



## D. The Reasons Why Granting Petitioner Request 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 Petitioner to safely, efficiently,

and economically perform various real estate

‐ related functions, including the marketing and sale of

residential and commercial real estate, property management, standing timber appraisal, fire

prevention, real estate development, property inspections, construction and public relations.

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 Petitioner'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 serve as a safe, efficient, and economical alternative to

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

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air

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

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

airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 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 intimal combustion engine.14 By using the DJI Inspire 1 UAS's 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 length of 17.3 inches, width 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 UASs 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

UASs will allow United States based companies, like Petitioner, to remain competitive and

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fiiel 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 UASs 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 UASs, companies such as Petitioner, 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,

Petitioner’s proposed operation of the DJI Inspire 1 UASs will not implicate any privacy issues.

Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e.,

the Petitioner's 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. § 91.119.15 

## 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 Petitioner 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. Petitioner's operation of the DJI Inspire 1 UAS meet the

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with

14 C.F.R. Part 21, Subpart H.

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 rulemaking 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 (I).

(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. Petitioner 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.16 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 are set forth by the DJI Inspire 1

Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UASs To

Remain Within A Defined Operational Area.

The DJI Inspire 1 UASs 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 are provided

at pages 12

‐ 18 and 45

‐ 52 of the DJI Inspire 1 User Manual, attached hereto as Exhibit B.

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

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 for the DJI Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manual,

attached hereto as B.

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 24 through 34 of the DJI Inspire 1 User Manual attached

hereto as Exhibit B.

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

Pilot in Command With A Safety Observer.

Petitioner will only utilize certificated pilots who possess a current and valid U.S. driver's license

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 Pursuant to Specific Operating Limitations.

In seeking this exemption, Petitioner proposes to commercially operate the 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:17 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 UA 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 1 8

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

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained in

the grant of exemption take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. It is the operator's responsibility to track such

revisions and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for extension

or amendment to the grant of exemption. If the operator determines that any update or

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

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

Office (AFS

‐ 80) may be contacted if questions arise regarding updates or revisions to the

operating documents.

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

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the

aircraft is prohibited from operating until the necessary maintenance has been performed

and the UAS is found to be in a condition for safe flight. The Ground Control Station must be18 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.19 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

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

‐ determined

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

operating documents.

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

accordance with the operating documents.

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

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

point and land the UA with 25% battery power remaining

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

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

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

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

conducted in accordance with airspace requirements in the ATO issued COA including class

of airspace, altitude level and potential transponder requirements.

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

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

‐ Number)

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

practicable.

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

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

appropriate government oversight agency requirements.

28. The 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 UA 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;20 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 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

(h) Would Not Adversely Affect Safety

Petitioner 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 2 1 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 Petitioner'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, Petitioner submits that the additional maimed airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for Petitioner's

specific proposed flight operations.

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.

II062,11063,11064, 11065,11066,11067,11080,11109,11110, 11112,11136,11138,11150, 11153, 11156,

11158, 11159,11160,11161).

Petitioner 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

ciurency 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.

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

Petitioner' proposed operations. The Administrator has held that prior documented flight experience21 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

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 2

2 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 UA with appropriate

distances in accordance with 14 C.F.R 91.119.



### Exemption No. 11138 at page 15.

Accordingly, Petitioner will ensure safe operations by not allowing any PIC to operate the DJI Inspire I

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. Petitioner 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.22 The equivalent level of safety established by Section 91.121 will be maintained because the

altitude information of die 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 Petitioner'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 UASs 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.

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 UASs; (2) the

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

Accordingly, Petitioner 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 UASs 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 P 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).23 

## 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. Petitioner submits that the equivalent level of safety with regard to

the regulatory maintenance and alteration requirements established 2 4 by Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Petitioner will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the

me&ods, techniques, and practices prescribed in the operating documents (i.e., the Petitioner's Aerial

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

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

Since the DJI Inspire 1 UASs will be inspected as prescribed by the operating documents,

Petitioner 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 Exhibit B; a copy of the

DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Petitioner 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 considered.

In consideration of Petitioner's proposed operating limitations, the operating documents, and

the technical aspects of the DJI Inspire 1 UAS's, Petitioner 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 FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, Petitioner requests that the FAA prescribe special

conditions for the intended operation of the DJI Inspire 1 UASs, which contain such safety standards that24 the Administrator finds necessary to establish a level of safety equivalent to that established 2 5 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 for Leading Edge's intended operation of the DJI Inspire 1 UAS,

which contains 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 Petitioner Seeks Exemption:

William Taek Lim d/b/a William Lim Real Estate Group, 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),

and91.417(a) & (b).



## A Brief Description Of The Nature Of The Exemption Petitioner Seeks:

This exemption will permit William Taek Lim d/b/a William Lim Real Estate Group, Inc, to commercially

operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.



## Any Additional Information, Views, Or Arguments Available To Support

Petitioner's Request.25 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, Petitioner'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. Petitioner will operate the DJI Inspire 1 UASs

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. Petitioner 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

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 FAA Modernization and Reform Act of

2012, while also advancing the interests of the public, by allowing Petitioner to safely, efficiently, and

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

WHERFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act of 2012, Section 333, William Taek Lim d/b/a William Lim Real Estate Group, Inc. respectfully

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

Section 61.113(a) & (b), 91.7(a). 91.121, 91.151(b). 9L405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b). and permit William Taek Lim d/b/a William Lim Real Estate Group, Inc. to operate the

DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain

areas of the United States.

Respectfully submitted,

William Taek Lim d/b/a William Lim Real Estate Group, Inc.

______________________________

William Lim

President of William Lim Real Estate Group, Inc

10750 Civic Center Dr, Rancho Cucamonga, CA 91730

(909) 239

‐ 2006

pruwill@gmail.com26 

## EXHIBIT

‐ A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Petitioner 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 parameter 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

Aircraft 2.2.1.1 Model

‐ T600

2.2.1.2 Weight (Battery Included)

‐ 61bs 7.529loz (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 1/4" x 17 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: 1IW27 2.2.2.3 Operating Current

‐ Static: 750mA; In Motion: 900mA

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 N a m e ‐ X 3

2.2.3.2 Model

‐ FC350 2.2.3.3 Total Pixels

‐ 12.76M

2 8 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:

1920xl080p24/25/30/48/50/60: HD: 1280x720p24/25/30/48/50/60

2.2.3.10 Operating Temperature Range

‐ 320F

‐ 1040F (OOC

‐ 400C)

2.2.4 Transmitter

2.2.4.1 N a m e ‐ C I

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 2S28 

## E X H I B I T

‐ B

DJI Inspire 1 Manufacturer's User Manual

User manual can be found at:

http://download.dji

‐ innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf29 

## EXHIBIT

– C

Monthly Maintenance Log

Month

_______ Year

________

UAS #

_ _

_

_

_

_

_

_ Date Issue

Discovered Date Issue

Addressed Issue Description &

Maintenance

Conducted Maintenance

Performed by: Print

& Sign



### Software

Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration

Dampening

Other: