1

October, 10 2015

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590

RE: ROECK AERIAL SERVICES

REQUEST AN EXEMPTION 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 DJI Inspire 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

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

Andrew Roeck

Founder

Roeck Aerial Services

3656 Bridgeport Way W

Apt A102

University Place, WA 98466

734-927-2107

Anroeck@gmail.com
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TABLE OF CONTENTS

Page 

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 ROECK AERIAL SERVICES

SEEKS EXEMPTION............................................................................................................7

THE EXTENT OF RELIEF ROECK AERIAL SERVIES SEEKS AND THE REASON ROECK 

AERIAL SERVICES SEEKS THE RELIEF.......................................................................10

THE REASONS WHY GRANTING ROECK AERIAL SERVICES REQUEST WOULD BE IN 

THE PUBLIC INTEREST ...................................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO ROECK AERIAL SERVICES

WOULD NOT ADVERSELY AFFECT SAFETY................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......................19

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT ROECK AERIAL SERVICES REQUEST..........................................................19

CONCLUSION........................................................................................................................19

APPENDICES........................................................................................... 20
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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

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

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
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SUMMARY

Roeck Aerial Services 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 (DJI INSPIRE 1) pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Roeck Aerial 

Services to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial surveying, mapping, data collection, remote sensing, education and research, 

monitoring, emergency management, inspections, filmmaking and photography of construction 

sites, residential and commercial real estate, civil landscapes, and surveillance over certain areas 

of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

The objective of Roeck Aerial Services and our Unmanned Aircraft System (DJI Inspire 1) aerial 

operations is to provide a more affordable, high-quality production system for a variety of 

governmental, commercial, public, and residential uses including:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Private and governmental training 

• Aid civil engineering

• Inspections

• Monitoring

• Filmmaking and photography

• Aid Civil Engineering

• Remote Sensing

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1, UAS

Roeck Aerial Services seeks an exemption to operate DJI Inspire 1 system for compensation or 

hire within the NAS. The DJI Inspire 1 Station (GCS) utilizing electronic tablet or smart phone 

systems. The DJI Inspire 1 has a maximum gross weight that is fewer than 55 pounds and a 

maximum speed of under 50 mph. Maximum flight time is approximately 18 minutes

BASIS FOR PETITION

Petitioner, Roeck Aerial Services, 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, 
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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 §§ 61.23 (a) & (c), 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, Roeck Aerial Services operation of 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. 

The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s 

certificates (discussed above) to operate a UAS with a U.S. issued driver’s license, in lieu of an 

FAA issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport 

pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver’s license. The 

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

Roeck Aerial Services requests relief from Sections 14 C.F.R §§ 61.113(a) & (b) proposing that 

the PIC must hold at least a Sport Pilot Certificate.

Accordingly, Roeck Aerial Services 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. 

Roeck Aerial Services seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

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

C.F.R. Part 21, Subpart H. As such, Roeck Aerial Services submits that they will ensure that the 

DJI Inspire 1 UAS is in an airworthy condition, prior to every flight.

Roeck Aerial Services 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 UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with Roeck Aerial Service’s operation of the DJI Inspire 1 UAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, Roeck Aerial Services seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Roeck Aerial Services 

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 18 minutes. Battery power indicators 

are also able to show exactly how much battery power is left, as well as how much time is 

needed to return safely back to point of take off.
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In accordance with 14 C.F.R. § 11.81, Roeck Aerial Services 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:

Andrew Roeck

3656 Bridgeport Way W

Apt A102

University Place, WA 98466

(734) 927-2107

Anroeck@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which ROECK AERIAL SERVICES Seeks 

Exemption. 

1. ROECK AERIAL SERVICES 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. ROECK AERIAL SERVICES 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. ROECK AERIAL SERVICES Seeks Exemption From The Requirements Of Section 

91.121. 

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--
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(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. ROECK AERIAL SERVICES 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. ROECK AERIAL SERVICES 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. ROECK AERIAL SERVICES 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. ROECK AERIAL SERVICES Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 
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Section 91.409, entitled Inspections, subsection (a), states the following:

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

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

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

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

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

with part 21 of this chapter. 

8. ROECK AERIAL SERVICES 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. 
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(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 ROECK AERIAL SERVICES Seeks And The Reason ROECK 

AERIAL SERVICES Seeks The Relief. 

1. Extent Of Relief ROECK AERIAL SERVICES Seeks And The ROECK AERIAL 

SERVICES 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 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 ROECK AERIAL SERVICES 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 
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PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption.

Further, ROECK AERIAL SERVICES 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 ROECK 

AERIAL SERVICES business; and (2) will not carry passengers or property for compensation or 

hire. 

2. Extent Of Relief ROECK AERIAL SERVICES Seeks And The Reason ROECK 

AERIAL SERVICES 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 ROECK AERIAL SERVICES 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., DJI Inspire 1 Instruction Manual). 

ROECK AERIAL SERVICES seeks the requested relief because the DJI Inspire 1 UAS do not 

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

ROECK AERIAL SERVICES will ensure that the DJI Inspire 1 UAS are in airworthy condition 

based upon its compliance with the operating documents (i.e. 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.

3. Extent Of Relief ROECK AERIAL SERVICES Seeks And The Reason ROECK 

AERIAL SERVICES 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), ROECK AERIAL SERVICES seeks the requested relief because the DJI Inspire 1 UA’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 are 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. 
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4. Extent Of Relief ROECK AERIAL SERVICES Seeks And The Reason ROECK 

AERIAL SERVICES 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 18 minutes. ROECK AERIAL SERVICES 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 ROECK AERIAL SERVICES 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 ROECK AERIAL SERVICES’s proposed operating 

limitations, ensure that ROECK AERIAL SERVICES 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 18 minutes.

5. Extent Of Relief ROECK AERIAL SERVICES Seeks And The Reason ROECK 

AERIAL SERVICES 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, ROECK AERIAL SERVICES requests relief from 

these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set 

forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, ROECK AERIAL SERVICES 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., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, ROECK 

AERIAL SERVICES will document and maintain all maintenance records for the DJI Inspire 1

UAS. 

D. The Reasons Why Granting ROECK AERIAL SERVICES 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 ROECK AERIAL 

SERVICES to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, events and civic landscape 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 ROECK 

AERIAL SERVICES’s proposed operation of the DJI Inspire 1 UAS will be realized without 

implicating any privacy issues. 
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1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Inspire 1 UAS are 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

do 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 produce 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 

10-30 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. Aside from the lack of flight crew members 

located onboard the aircraft, the DJI Inspire 1 UAS (weighing less than 55 pounds at their 

maximum gross weight with diagonal dimension of less than 23 inches, and with no fuel on 

board), has less physical potential for collateral damage to life and property on the ground, and in 

the air, compared to the manned aircraft that typically conduct similar operations.

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 are 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 ROECK AERIAL SERVICES, to 

remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising 
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cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

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

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

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

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the DJI Inspire 1 UAS, companies such as ROECK AERIAL SERVICES, 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, 

ROECK AERIAL SERVICES’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. 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 ROECK AERIAL SERVICES Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UAS Meet 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, ROECK AERIAL SERVICES’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 
15

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 (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, ROECK AERIAL SERVICES 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 are set forth by the DJI Inspire 1 User 

Manual.

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain 

Within A Defined Operational Area. 

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation. 

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

Certificated Pilot in Command. 

ROECK AERIAL SERVICES video production staff will be the only persons to act as a pilot in 

command (PIC) of the DJI Inspire 1 UAS. 
16

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

Would Not Adversely Affect Safety.

ROECK AERIAL SERVICES 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 that the PIC is able to safely operate the DJI Inspire 1

UAS in a manner consistent with the exemption.

Considering ROECK AERIAL SERVICES’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, ROECK AERIAL 

SERVICES submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for ROECK AERIAL 

SERVICES’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. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). 

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, ROECK AERIAL SERVICES 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 

ROECK AERIAL SERVICES’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. 
17

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 UAS; (2) the 

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

operations. Accordingly, ROECK AERIAL SERVICES 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 18 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.

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. 

Preventive maintenance on the UAS will be performed using the methods, techniques, and 

practices prescribed in the operating documents (i.e. DJI Inspire 1 Instruction Manual). The PIC 

will limit maintenance performed to repairing small cracks, replacing a propeller, checking 

electrical connections and updating software and firmware for the on-board computer. Any 

further maintenance will be performed by the manufacturer or their designated repair facility.

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

ROECK AERIAL SERVICES will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 
18

In consideration of ROECK AERIAL SERVICES’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Inspire 1 UAS, ROECK AERIAL 

SERVICES 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, ROECK AERIAL SERVICES 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 for Roeck Aerial Services 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).
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• A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which ROECK AERIAL SERVICES Seeks Exemption: 

ROECK AERIAL SERVICES 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 ROECK AERIAL SERVICES

Seeks: 

This exemption will permit ROECK AERIAL SERVICES 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 

ROECK AERIAL SERVICES’s Request. 

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

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

may operate safely in the NAS. As such, ROECK AERIAL SERVICES’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, ROECK AERIAL SERVICES will operate the DJI Inspire 1 UAS

safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise 

pose a threat to national security. 

CONCLUSION

As set forth herein, ROECK AERIAL SERVICES 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 ROECK AERIAL SERVICES to safely, 

efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, ROECK AERIAL SERVICES respectfully 
20

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 Roeck Aerial Service 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 10, 2015

Respectfully submitted,

Andrew Roeck

Founder

3656 Bridgeport Way W

Apt A102

University Place, WA 98466

(734)927-2107

Appendices:

A – Link to DJI Inspire 1 Manual: Click on link below

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf