Alacrity Productions, Inc.

4152 Arbor Lane

Eagan, MN 55122

U.S. Department of Transportation

Federal Aviation Administration

October 21st, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 

45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 

91.109; 14 CFR 91.119(C); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 

91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) 

and (2); 14 CFR 91.417(a)

and (b)

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) 

Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, 

Alacrity Productions, Inc which owns and operates an Unmanned Aircraft System 

(UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of its UAS, so long as such 

operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. Commercial 

operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would operate in the following manner:

Aerial photography and/or video for public and/or private use including real 

estate, architecture, surveying, engineering and other related professional 

activities. Aerial video and/or photography for public and/or private use including 

television, public events, private events, cinematography and news gathering.

Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority.

Alacrity Productions, Inc operates one Inspire1 (4) blade quadcopter

Weighing 6.47 pounds. The UAS has a maximum airspeed of 49.21miles per 

hour and uses a remote controller on an operating on frequency of 5.725~5.825 

GHz / 2.400~2.483 GHz and range of up to 5 km or 3.1 miles (unobstructed, free 

of interference) when FCC compliant. Up to 3.5 km or 2.1 miles (unobstructed, 

free of interference) when CE compliant. The Inspire1 is equipped with built in

ground support technology that allows it to fly utilizing global positioning system 

(GPS) for stability, tracking, safe flight mode, and a return to home feature in the 

event of loss of remote control signal or critical low battery.
All flights start with a preflight safety check and all flight data are recorded. The 

Inspire1 is equipped with a gimbal-mounted camera that sends a live video signal 

to the controller allowing the person in control (PIC) to monitor real-time video. 

Flight data, speed height, distance, battery level and general aircraft conditions 

are also displayed during operation. The Inspire1 battery has a flight time of 

approx 18 minutes and is, therefore, always returned to original takeoff point and 

always flown utilizing visual line of sight (VLOS). The Inspire 1 maximum range is

400ft vertical. Our request for exemption would allow us to offer unique aerial 

photography and videography services to our clientele.

UAS Safety Operating Parameters

We will abide by the following additional operating conditions under this 

exemption, which ensures a level of safety during UAS flight including operating 

the UAS below 400 feet and within a radius of 1,000 feet from PIC always 

maintaining VLOS and obtaining permission from the owner/controller of any 

vessels, vehicles and structures when operations may be conducted closer than 

500 feet to any such vessels, vehicles or structures. We will conduct a safety

assessment of the risk of operating closer to those objects and determine that it 

does not present an undue hazard. Other safety operating parameters include:

Operate the UAS for 1520 minutes per flight. Land UAS prior to the 

manufacturer's recommended minimum level of battery power.

Operate the UAS during daylight hours only within VLOS. Utilize the UAS’ GPS 

flight safety feature whereby it hovers and then slowly lands if communication 

with the PIC is lost or battery becomes critically low. Always obtain all necessary 

permissions prior to operation.

Have procedures in place to abort flights in the event of safety breaches or 

potential danger. Review weather reports prior to flight and never operate UAS in 

unsafe conditions, high wind, low clouds or conditions that hinder visibility.

Only operate in safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and densely populated areas.

Also conduct extensive preflight inspections and protocols during which safety 

carries primary importance.

The PIC will also have a minimum of five hours logged on this craft and 10 hours 

minimum flying UAS quadcopters under varying conditions and environments 

and will follow all safety protocol of Alacrity Productions, Inc as well as guidelines 

of 14 CFR §61.51(b) having the ability to safely operate the UAS in a manner 

consistent with the operating documents, including evasive and emergency 

maneuvers and maintaining appropriate distances from people.
Specific Exemptions Requested

Given the size, weight, speed and limited operating area associated with the 

UAS, an exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) 

and 14 CFR 91.203(a) and (b) (certifications required), subject to certain 

conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR Part 11 and Section 333 of P.L. 11295

(Section 333). We request an exemption from 14 CFR 45.23 Marking of the 

Aircraft because the UAS will not have a cabin, cockpit or pilot station on which 

to mark certain words or phrases. 

Further, the two-inch lettering is difficult to place on such a small aircraft with 

dimensions smaller than the minimal lettering requirement. Regardless of this, 

we can mark the UAS in the largest possible lettering by placing the word 

“Experimental” on its fuselage as required by 14 CFR 45.29(f) so that anyone will 

see the markings.

We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges 

and Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots 

or passengers nor property. The Risks attendant to the operation of the UAS is 

far less than the risk levels inherent in the commercial activities outlined in 14 

CFR §61. The operation and limitations in the flight operation manual (FOM) will 

equate to the safe operations of the UAS.

We request an exemption from 14 CFR 91.7(a) which prohibits the operation of 

an aircraft without an airworthiness certificate, since there is currently no 

certificate applicable to our operation, this regulation is inapplicable. We request 

an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)2) 

and 14 CFR 91.417(a) and (b) Maintenance inspections since they only apply to 

aircraft with an airworthiness certificate. However, as a safety precaution, we will 

perform a preflight inspection of the UAS before each flight as outlined in the

attached operating documents.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft 

FOM in the aircraft, however, since there are no pilots or passengers on board 

the aircraft, and given its size, this regulation is inapplicable. We believe an 

equivalent level of safety will be achieved by maintaining a safety/flight manual 

with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated 

Instrument Flight and Certain Flight Tests. The regulation states that “no person 

may operate a civil aircraft that is being used for flight instruction unless that 

aircraft has fully functioning dual controls. Although the Hexo+ is capable of 

dual/linked controls, we will be operating with a single remote controller.

We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes 

for the operation of civil aircraft, but allows helicopters to be operated at lower 
altitudes in certain conditions. We will not operate our UAS above the altitude of 

400 feet above ground level (AGL) and will also only operate in safe areas away 

from the public and traffic, thus “providing a level of safety at least equivalent to 

or below those in relation to minimum safe altitudes.” Given the size, weight and 

maneuverability and speed of the UAS, an equivalent or higher level of safety

will be achieved.

We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is 

inapplicable since the UAS utilizes electronic GPS with a barometric sensor. We

request an exemption from 14 CFR 91.151(a) Fuel Requirements for Flight in 

visual flight rules (VFR) conditions. The UAS is 100 percent electric and two low 

battery alerts are issued – per the operating documents, the UAS will be landed 

at the first alert. Also, our flights will last only 15 minutes each and the UAS

has an automated function, which results in immediate landing when a low 

battery is detected.

The PIC will not begin a flight unless, considering wind and forecast weather 

conditions, there is enough power to fly to the first point of intended landing and, 

assuming normal cruising speed, land the UAS with 30 percent battery power 

remaining.

Summary

We will comply with all of the following conditions and limitations should this grant 

of exemption be provided:

1. Operations will be limited to the following aircraft described in the operating

documents which is a quadcopter weighing less than seven pounds: 

2. The UAS will not be flown at an indicated airspeed exceeding 45 mph.

3. The UAS will be operated at an altitude of no more than 400 feet AGL, as 

indicated by the procedures specified in the operating documents.

4. The UAS will be operated within VLOS of the PIC at all times.

5. All operations may utilize a visual observer (VO. The UAS will be operated 

within the VLOS of the VO at all times. The VO and PIC will be able to 

communicate verbally at all times. The PIC will be designated before the flight 

and will not transfer his or her designation for the duration of the flight. The PIC 

will ensure that the VO can perform the functions prescribed in the operating 

documents.

6. The operating documents will be accessible during the UAS operations and 

made available to the Administrator upon request. Any revisions to the operating 

documents will be presented to the Administrator upon request.
7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the UAS will not be operated until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The 

Ground Control Station will be included in the preflight inspection. All 

maintenance and alterations will be properly documents in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight

characteristics, e.g. replacement of a flight critical component, will undergo a 

functional test flight. The PIC who conducts the functional test flight will make an 

entry into the aircraft records.

9. The preflight inspection section in the operating documents will account for all

discrepancies, i.e. inoperable components, items or equipment not already 

covered in the relevant sections of the operating documents.

10. We will follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection and life limit requirements.

11. We will carry out maintenance, inspections and recordkeeping

requirements, in accordance with the operating documents. Maintenance, 

inspection and alterations will be noted in the aircraft records, including total flight 

hours, description of work accomplished and the signature of the authorized 

person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer's Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections.

14. The PIC will also meet the flight review requirements specified in 14 CFR 

61.56 in an aircraft in which the PIC is rated on.

15. Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate listing videos (or similar 

operations), the PIC will have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot operating the 

make and model of the UAS to be used in operations.

16. The PIC will not operate the UAS for the purpose of aerial

videography/cinematography and augmenting real estate listing videos (or similar

operations), unless the PIC has demonstrated and logged in a manner consistent 

with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner 

consistent with the operating documents, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures.
17. UAS operations will not be conducted during night hours, as defined in 14 

CFR 1.1 All operations will be conducted under visual meteorological conditions 

(VMC).

18. The UAS will not operate within five nautical miles of an airport reference 

point as denoted on a current FAApublished aeronautical chart.

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than three statute miles from 

the PIC.

20. If a UAS loses communications or loses its GPS signal, it will return to a

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

21. The PIC will abort a flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

22. The PIC will not begin a flight unless, considering wind and forecast weather

conditions, there is enough power to fly at a normal cruising speed to the 

intended landing point and land the UAS with 30 percent battery power 

remaining.

23. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UAS will comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements.

24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be 

available

to the PIC at the Ground Control Station of the UAS at any time the UAS is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.

25. The UAS will remain clear and yield the right of way to all manned aviation

operations and activities at all times.

26. The UAS will not be operated by the PIC from any moving device or vehicle.

27. The UAS will not be operated over congested or densely populated areas 

unless contracted out to do events.

28. Flight operations will be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS and/or debris in the event of an accident. We will 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 UAS, flight operations must cease immediately.

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.

c. Operations near to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per 14 CFR 91.119(a).

29. All operations will be conducted over private or controlled access

property with permission from the landowner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

30. Any incident, accident or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable certificate 

of authorization (COA) will be reported to the FAA’s UAS Integration Office 

(AFS80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB 

website: www.ntsb.gov .

On behalf of Alacrity Productions, Inc., I would like to thank you for your 

consideration in granting this exemption.

Steven D. Johnson

President

Alacrity Productions, Inc.

AIRCRAFT – DJI Inspire1

Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 4500 m (Default altitude limit: 120 m above takeoff point
Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510H

Propeller Model DJI 1345T

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Power Spectral Density 9.06mW/MHz