UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

i BUSINESS TECHNOLOGIES, LLC FOR AN EXEMPTION SEEKING RELIEF FR OM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATION S SECTIONS 61.113(a) & (b), 91.7(a), 91.121 , 91.151(b ), 91.405(a), 91.407(a)( 1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

DJI INSPIRE 1 UNMANNED AIRCR AFT SYSTEM PURSUAN T TO SECTION 333 OF THE F AA MODERNIZATION AND REFORM ACT OF 2012 ( PUBLIC LAW 112

- 95)

Submitted on February 11
, 201 5

G REGORY S

. W INTON , E SQ

. J ARED M. A LLEN , E SQ

. T HE A VIATION L AW F IRM 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorneys for Petitioner2 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................. 3

SUMMARY

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ................. 4

BACKGROUND

................................ ................................ ................................ ................. 4

BASIS FOR PET ITION

................................ ................................ ................................ ...... 5

NAME AND ADDRESS OF PETITIONER

................................ ................................ . 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH i BUSINESS TECHNOLOGIES, LLC SEEKS EXEMPTION

................................ .......................... 8

THE EXTENT OF RELIEF i BUSINESS TECHNOLOGIES, LLC SEEKS AND THE REASON i BUSINESS TECHNOLOGIES, LLC SEEKS THE RELIEF

.......... 1 1

THE R EASONS WHY GRANTING i BUSINESS TECHNOLOGIES, LLC 'S REQUEST WOULD BE IN THE PUBLIC INTEREST

................................ ............ 1 4

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ .............. 1 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

.......... 3 2

ANY ADDITIONAL INFORMATION, VI EWS, OR ARGUMENTS AVAILABLE TO SUPPORT i BUSINESS TECHNOLOGIES, LLC 'S REQUEST

.......................... 3 3

CONCLUSION

................................ ................................ ................................ ................. 3 33 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Con trol
ATO Air Traffic Organization
C.F.R. Code of Federal Regulation s COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal A viation Regulation
FCC Federal Communication s Commission
GCS Ground Control Station
GPS Global Positioning System
NAS National Airspace System
NOTAM Notice to Airm e n PIC Pilot I n Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System

VFR Visual Flight Rules
VLOS Visual Line of S ight
VMC Visual Meteorologica l Conditions
VO Visual Observer
VTOL Vertical Takeoff and Landing4 SUMMARY

iBusiness Technologies, LLC seeks exemption from the requirements of 14 C.F.R §§

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

91.417(a) & (b) , to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA)

. This exem ption will permit iBusiness
Technologies, LLC to operate an Unmanned Aircraft System (UA S ) for the com mercial purpose

of conducting aerial acquisitions within the National Airspace System ( NAS )

.

INTRODUCTION AND INTERESTS OF THE PETITIONER
iBusiness Technologies, LLC (hereinafter referred to as “iBusiness Technologies”)
provides advanced mob ile and aerial technologies which enable companies to operate more
efficiently and achieve competitive advantages in their respective markets.

BACKGROUND
Unmanned Aircraft System: DJI Inspire 1 UAS

iBusiness Technologies seeks an exemption to operate the DJI I nspire 1 UAS (Inspire 1

UAS) for compensation or hire within the National Airspace System ( NAS )

. The Inspire 1 UAS
is comprised of a vertical takeoff and landing (VTOL) U nmanned A ircraft (UA) and a
transportable G round C ontrol S tation (GCS) . The Inspire 1 UA has : a maximum gross weight of
approximately 14 pounds; approximate dimensions of a length of 17 inches
, width of 18 inches,

and height of 12 inches ; and maximum speed of approximately 43 knots . The Inspire 1 UA is
equipped with four rotors
, each dr iven by a Lithium Polymer b attery powered electric motor.

The Inspire 1 UA that will be operated by iBusiness Technologies will be registered in

accordance with 49 U.S.C. 44103
, Registration of Aircraft
, as well as 14 C.F.R Part 47, Aircraft5

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

.
BASIS FOR PETITION

Petitioner, iBusiness Technologies, LLC
, by and through undersigned counsel, pursuant
to the provisions of t he Federal Aviation Regulations ( 14 C .F.R. § 11.61) and the FAA

Moder nization and Reform Act of 2012 (FMRA) Section 333, Special Rules for Certain
Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the
Inspire 1 UAS with in the N ational A irspace S ystem (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).

I n consideration of the size, weight, speed, and limited operating area associated wit h the
unmanned aircraft and its operation, iBusiness Technologies ’ operation of the 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. P art 21, Subpart H.

Acc ordingly
, iBusiness Technologies 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.

i Business Technologies submits that the requested relief is proper since an equivalent
level of safety will be ensured. iBusiness Technologies will perform maintenance, alteration s , or
preventive maintenance on the UAS using the methods, techniques, and pr actices prescribed in

the operating documents (i.e.
, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start

Guide
, the Inspire 1 UAS Safety Guidelines
, the OpenPilot Preflight Checklist
, the Intelligent
Flight Battery Safety Guidelines , and the iBusi ness SOP ) , or will u tilize manufacturer authorized6

s upport services to perform maintenance, alteration s , or preventive maintenance on the UAS

. Furthermore, iBusiness Technologies will document and maintain all maintenance records for

the Inspire 1 UAS.

Relief from certain requirements of Section 61.113(a) and (b)
, entitled Private pilot
privileges and limitations: Pilot in command
, is requested by iBusiness Technologies to the
extent necessary to allow operation of the Inspire 1 UAS by a Pilot in Com mand ( PIC ) hold ing a
private pilot certificate, as well as a n airman medical certificate, and who has demonstrated, by
meeting m inimum flight

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

the Inspire 1 UAS in a manner consistent wi th this exemption, including evasive and emergency
maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

iBusiness Technologies seeks relief from Section 91.7(a) , entitled Civil aircraft

airworthiness
, because the Inspire 1 UAS does not require an airworthiness certificate in

accordance with 14 C.F.R. P art 21, Subpart H. As such, iBusiness Technologies submits that it

will ensure that the Inspire 1 UAS is in an airworthy condition
, prior to every flight
, by

determi ning that the UAS is in compliance with the operating documents (i.e.
, the Inspire 1 UAS
User Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelines, the
OpenPilot Preflight Checklist
, the Intelligent Flight Battery Safety Guideli nes , and the iBusiness

SOP ) , and that the aircraft is in a condition for safe flight

.
iBusiness Technologies also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings
, because t he altitude reporting equipment of the Ins pire 1 UAS

i s set to zero feet above ground level ( AGL )
, rather than local barometric pressure or field

altitude
, before each flight. T he a ltitude information of the Inspire 1 UA is provided to the PIC

via a barometric pressure sensor, Global Positioning S ystem ( GPS ) equipment
, and a radio7

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

. A level of safety equivalen t to Section 91.121 will be ensured as

t he altitude of the Inspire 1 UA w ill be reported to air traffic control ( ATC ) in feet above ground

level ( AGL )
, and iBusiness Technologies will operate the Inspire 1 UA within visual line of
sight
, at or below 400 feet AGL.
Additionally, iBusiness Technologies seeks an exemption from the requirements of

Section 91.151( b ), entitled Fuel requirements for flight in VFR conditions

. iBusiness
Technologies submits that safety will not be affected by operation of the Inspire 1 UA 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 a fter that for at least 4.5 minutes (i.e., 25

percent battery power remaining )

. In accordance with 14 C.F.R. § 11.81, iBusiness Technologies provides the following
information in support of its petition for exemption:

A. Name A nd Address Of T he Petitioner.

The name and address of the Petitioner is:

iBusiness Technologies, LLC B ox 364 Wynnewood, PA 19096

- 0364
The point of contact for this P etition and specific contact information is as follows:
Gregory S. Winton, Esq. The Aviation Law Firm 1997 Annapolis Exchange Parkway
, Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 | Fax: (866) 568

- 9886 Ema il: Greg@aviationlawexperts.com8

B. The Specific Sections Of 14 C.F.R. From Which iBusiness Technologies Seeks Exemption.

1. iBusiness Te chnologies 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 th e following, in relevant part:
( a) No person who hol ds 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 comp ensation 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. i Business Technologies 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 condit ion.

3

. iBusiness Technologies 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 a ltitude 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 mil es 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;9

4

. iBusiness Technologies Seeks Exemption From The Requirements Of Section 91.151 ( b )

.
Section 91.151
, entitled Fuel requirements for flight in V FR conditions
, subsection ( b ),

state s 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, ass uming normal cruising speed, to fly after that for at least 20 minutes.

5

. iBusiness Technologies Seeks Exemption F rom T he R equirement O f Section 91.405(a)

.
Section 91. 405
, entitled Maintenance required
, subsection ( a )
, states the follow ing :

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 par t 43 of this chapter [.]

6

. iBusiness Technologies Seeks Exemption F rom The Requirements Of Section 91.407(a)(1)

.
Section 91. 407
, entitled Operation after maintenance, preventive mainte nance,
rebuilding, or alteration , subsection (a)(1)
, state s the fol lowing:
(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

. iBusiness Technologies Seeks Exemption F rom The Requirements Of Sections 91.409(a)(1) A nd 91.409( a)(2 ).

Section 91.409
, entitled Inspections , subsection (a)
, state s 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; or10 (2) An inspecti on for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8

. iBusiness Technologies Seeks Exemption From The Requirements Of Section s 91.417(a) A nd 91.417 (b)

.
Section 91.417
, entitled Maintenance records , subsectio ns (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 o f 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 th e 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, in cluding 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, th e 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.11 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter f or 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 thi s 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 th e 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 iBusiness Te chnologies Seeks And The R eason iBusiness Technologies Seeks The Relief

.
1. Extent O f Relief iBusiness Technologies Seeks And The Reason iBusiness Technologies Seeks Relief From Section 61.113(a) And (b)

. Relief from Section 61.113(a) and (b) ent itled Private pilot privileges and limitations:

Pilot in command
, is requested to the extent necessary to allow a PIC holding a private pilot

certificate , as well as a current and valid FAA issued 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 re quested since the limitations set for th 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, iBus iness Technologies submits that an equivalent level of
safety will be maintained because no PIC will be allowed to operate the Inspire 1 UAS unless
that PIC has met certain flight

- hour and currency requirements, demonstrat ing that the PIC is12

able to safely operate the Inspire 1 UAS in a manner consistent with the operations spe cifications

as s et forth h erein , including evasive and emergency maneuvers, as well as maintaining
appropriate distances from people, vessels, vehicles and structures.

Fur ther, iBusiness Technologies submits that all flights of the Inspire 1 UAS
, conducted
by the PIC pursuant to the grant of this Petition : (1) will be incidental to iBusiness Technologies ’

business; and (2) will not carry passengers or property for compensat ion or hire.

2. Extent O f Relief iBusiness Technologies Seeks And The Reason iBusiness Technologies Seeks Relief From Section 91. 7(a)

.

R elief from Section 91. 7( a) entitled Civil aircraft airworthiness
, is requested to the extent
required to allow iBu siness Technologies to determine that the Inspire 1 UAS is in an airworthy

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

documents (i.e.
, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start Guide, the
Inspire 1 UAS Safety Guidelines, the OpenPilot Preflight Checklist
, the Intelligent Flight Battery
Safety Guidelines , and the iBusiness SOP )

.
iBusiness Technologies seeks the requested relief because the Inspire 1 UAS does not
require an air worthiness cer tificate in accordance with 14 C

. F

. R

. P art 21, Subpart H

. Therefore,

iBusiness Technologies will ensure that the Inspire 1 UAS is in an airworthy condition based

up on its compliance with the operating documents prior to every flight, and further, determin e
that the aircraft is in a condition for safe flight, as stated in the conditions and limitations below.

3

. Extent O f Relief iBusiness Technologies Seeks And The Reason iBusiness Technologies Seeks Relief From Section 91. 121

.
Relief from Section 91 .121, entitled Altimeter settings , may be required to allow flight
operations of the Inspire 1 UAS, because t he Inspire 1 UA ’s a ltitude reporting equipment may be

set on the ground to zero feet AGL
, rather than local barometric pressure or field altitude
, before13

each flight. The Inspire 1 UAS utilizes a barometric pressure sensor , GPS equipment, and a
radio communications telemetry data link to downlink altitude information from the UA to t he

PIC at the ground control station ( GCS )

. Considering the limited altitude of the proposed operations, relief from 14 C

. F

. R

. §

91.121 is sought to t he extent necessary to comply with the applicable conditions and limitations

stated below. As more fully set forth herein
, a level of safety equivalent t o Section 91.121 will
be ensured as the altitude of the Inspire 1 UA will be reported to air traffic control (ATC) in feet
above ground level (AGL), and iBusiness Technologies will operate the Inspire 1 UA within
visual line of sight, at or below 400 feet AGL.

4

. Extent O f Relief iBusiness Technologies Seeks An d The Reason iBusiness Technologies Seeks Relief From Section 91.151( b )

.

R elief 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 Inspire 1 UA duri ng
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 (i.e., 2 5 percent battery power remaining )

.
i Business Technologies seeks the requested relief because without an exemption from Section

91.151( b ), the flight time duration of the battery power ed Inspire 1 UA will severely constrain
the practicality of any aeria l acquisition and research flight operations that iBusiness
Technologies propose s to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the Inspire 1 UAS, the
Inspire 1 UAS operating documents , and iBusi ness Technologies ’ proposed operating

limitations
, ensure that iBusiness Technologies will safely operate the battery powered Inspire 1

UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules14

( VFR )
, with enough battery power to fly, f or 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

(i.e., 2 5 percent battery power remaining )

.
5

. Extent O f Relief iBusiness Technologie s Seeks And The Reaso n iBusiness Technologies Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd 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 wit h an airworthiness certificate, iBusiness Technologies requests relief from

these Sections because the Inspire 1 UAS does not require an airworthiness certificate. A s set

forth more fully below, the Inspire 1 UAS meets the conditions of FMRA Section 3 33
, for
operation without an airworthiness certificate

. Accordingly, iBusiness Technologies will
perf orm maintenance, alteration s , or preventive maintenance on the UAS using the methods,
techniques, and practices prescribed in the operat ing documents (i.e.
, the Inspire 1 UAS User
Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelines, the
OpenPilot Preflight Checklist
, the Intelligent Flight Battery Safety Guidelines
, and the iBusiness

SOP ) , or will utilize manuf acturer authorized s upport services to perform maintenance,

alteration s , or preventive maintenance on the UAS. Furtherm ore, iBusiness Technologies w ill

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

D

. The Reasons Why Granting iBusiness Technologies ’ Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole

.
Gr anting the present Petition will further the public interest by allowing iBusiness
Technologies to safely, efficiently, and economically perform aerial acquisition s within the NAS
, commercially, in support of th e real estate indust ry , land survey industry , and construction
industry

. Additionally, use of the Inspire 1 UAS will decrease congestion of the NAS, reduce
pollution, and provide significant benefits to the economy. Notably, the benefits of iBusiness15

Technologies’ proposed operation of the Inspire 1 UAS will be realized without implicating any
privacy issues.

1. The Public Will Benefit From The Aerial Acquisition s Performed.

iBusiness Technologies submits this Petition to commercially operate the Inspire 1 UAS

and perform aerial acquisition within the NAS , in support of the real estate industry, surveying
industry, and construction industry . The Inspire 1 UAS will provide safe, efficient, and
economical aerial acquisition operations to further each of these fields, which are critical to the

well

- being of the general public.
The specific operations that iBusiness Technologies will perform with the Inspire 1 UAS
demonstrate how the requested exemption will directly benefit the above

- r efere nced industries
and the public. In the real estate industry
, aerial i magery performed by the Inspire 1 UAS will be
used to augment real estate listings. In the land surveying industry, the Inspire 1 UAS may be
used in support of agriculture, scie ntific studies, wildlife monitoring, forestry operations
, mining,
and the oil and gas industries

. The Inspire 1 UAS will also be operated by iBusiness
Technologies to aid in facility inspections and the planning of new construction sites.

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

The Inspire 1 UA is battery powered and serves as a safe, efficient, and economical
alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

amount of manned ai rcraft needed to perform aerial acquisitions, an exemption allowing the use

of a Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air
pollution, a nd 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 Inspire16

1 UA does not require an airport to takeoff or land. Likewise, a red uction of manned aircraft
conducting aerial survey missions would result in fewer aircraft that must be handled by air
traffic control during the ground, takeoff, departure, arrival, and landing phases of flight
operations.

3

. The Public Will Benefit Fr om The Safety And Efficiency Of The Inspire 1 UAS.
Conducting aerial acquisitions with the Inspire 1 UAS, instead of manned aircraft, will
greatly benefit the public by drastically reducing the levels of air and noise pollution generated
during trad itional aerial survey flight operations. By using battery power and electric motors, the
Inspire 1 UAS produces no air pollution, and is the most viable environmentally conscious
alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are
typically utilized for aerial acquisitions, and burn approximately 20

- 30 gallons per hour of leaded

aviation fuel. The Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions , also

r educes noise pollution, as the UA is propelled by battery powered electric motors, rather than an
internal combustion engine.
By using the 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 wit h traditional manned aircraft
flight operations, will be substantially reduced or completely eliminated. Aside from the lack of
flightcrew members located onboard the aircraft, the Inspire 1 UA (weighing approximately 14
pounds at its maximum gross weight with a length of 17 inches
, width of 1 8 inches, and with no
fuel on board), has less physical potential for collateral damage to life and property on the ground,
and in the air, compared to the manned aircraft that typically conduct aerial acquisitions (w eighing
approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a
fuel capacity of 180 gallons).17

4

. Performing Aerial Acquisition Operations With The Inspire 1 UAS Will Benefit The Economy.

In addition to b eing safe and efficient, the Inspire 1 UAS is also an economical
alternative to using manned aircraft to conduct aerial acquisitions . As such, operation of the
Inspire 1 UAS will allow United States based companies, like iBusiness Technologies , to remain
competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of
aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out
leaded aviation fuels, U.S. owned and operated companies must adop t new and alternative
technology in order to remain competitive. Operating the battery powered Inspire 1 UAS is one
such technology that not only allows companies greater operational flexibility compared to
manned aircraft, but provides such flexibility w ithout the high operational cost of a traditional

manned aircraft.
By operating the Inspire 1 UAS, companies such as iBusiness Technologies
, 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 Inspire 1 UAS, provides a stable
workforce that increases consumer spending; improves local, state, and federa l tax revenues; and
allows companies to invest in research and development in order to remain competitive both in

the United States and abroad.

5

. There Are No Privacy Issues

. Similar to the manned aerial acquisition flight operations that have been condu cted for

d ecades, iBusiness Technologies’ proposed operation of the Inspire 1 UAS will not implicate any
privacy issues. Specifically, the Inspire 1 UAS will be operated p ursuant to the speci fic

conditions and limitations set forth herein , and in accordance with the Federal Aviation18

Regulations, inclu ding the minimum altitude requirements of 14 C.F.R. § 91.119. Most
significantly, the Inspire 1 UA will not be operated closer than 500 feet to any person, vessel,

vehicle, or structure, which is not directly involved in the operation

.
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 iBusiness Technologies Seeks Exemption.

1. Reasons Why The Inspire 1 UAS Meets The C onditions Of The FAA Modernizatio n 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, iBusiness Technologies ’ operation of the In spire 1 UAS

meets the conditions of FMRA Section 333
, and will not require an airworthiness certificate in
accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets for th 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 othe r 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 o f 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).19

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely i n the national airspace system, the Secretary sha ll establish requirements for the safe ope ration of such aircraft systems in the national airspace system.

I n seeking this exemption, iBusiness Technologies submits that the Inspire 1 UAS can
operate safely in the NAS pursuant to FMRA Section 333, as dem onstrated by : ( a ) the

characteristics of the Inspire 1 UAS ; ( b ) the pilot certification requirement; ( c ) the specific
operating limitations ; and (d) the iBusiness “ Standard Operating Procedures (SOP) A nd

Policies

. ”

a . The Specifications Of The Inspire 1 UA S Demonstrate Its

Safe Characteristics.

The 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

. Techni cal Specifications Of The Inspire 1 UAS.
The technical specifications of the Inspire 1 UAS are set forth at pages 57 through 60 of
the Inspire 1 User Manual, attached hereto as Exhibit A. Exhibit A contains proprietary

information and is to be held in a separate file p ursuant to 14 C.F.R. § 11.35(b) 1

.

ii

. The Inspire 1 UAS Autonomous Flight A nd Navigation Modes Enable T he UAS To Remain Within A De fined O perational A rea.

The Inspire 1 UAS may be operated in both manual and autonomous flight modes. A
complete description of autonomous flight modes is provided at page s 12 , 16 and 27 of Inspire 1

User Manual , attached hereto as Exhibit A. Exhibit A contains proprietary information and is to
be held in a separate file pursuant to 14 C.F.R. § 1 1.35(b).

1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included in the Federal Docket Management System (FDMS).20 iii

. The Inspire 1 UAS Is D esigned For Automatic Return To Home Point Or Automatic Landing In The Event Of Loss Of The Control Link Or Navigation.
A complete description of the Failsafe Functions of the Inspire 1 UAS is set forth at

p ages 13 through 17 of the Inspire 1 User Manual, attached hereto as Exhibit A

. Exhibit A
contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. §

11.35(b).

iv . The Inspire 1 GCS And Its Operation.
The Inspire 1 ground control station (GCS) is comprised of at least one remote controller
, as well as a mobile device supporting the s ystem software , known as the DJI Pilot App

. A
complete description of the operation and specifications of the Inspire 1 remo te controller is
provided at page s 23 through 33 of the Inspire 1 User Manual. A complete description of the
operation and specifications of DJI Pilot App is provided at pages 40 through 4 3 of the Inspire 1

User Manual. The Inspire 1 UAS is compliant with all Federal Communication s Commission

(FCC) requirements
, and the radio frequency spectrum used for operatio n and control of the UA

is set forth at page 58 of the Inspire 1 UAS U s er manual. The Inspire 1 User Manual is to be
held in a separate file pursuant to 14 C.F.R. § 11.35(b)

.

b

. Flight Operations Of The Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot i n Command With A Safety Observer.

iBusiness Technolo gies will only utilize certificated p ilot s who possess a current and

valid FAA issued a irman m edical c ertificate to act as a pilot in command (PIC) of the Inspire 1
UAS. Additionally, a safety observer will assist all pilots during flight operations

.21 c . F light s Of The Inspire 1 UAS Will B e Conducted Pursuant To S pec ific Operating L imitations.
In seeking this exemption, iBusiness Technologies proposes to commercially operate the
Inspire 1 UAS for the special purpose of conducting aerial acquisitions within the NAS
, pursuant

to the following specific operating limitations:
1. Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents, a rotorcraft weighing 14 poun ds or less at maximum gross weight : Inspire 1 Unmanned Aircraft System. 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 acquisitions

. 3. The UA may not be flown at an indicated airspeed exceeding 43 knots.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operati ng documents. All altitudes reported to ATC must be in feet AGL.
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lense s, as specified on the PIC’s FAA

- issued airman medical certificate.
6. The use of first person view (FPV) by the PIC or visual observer ( VO ) is not permitted.
7. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 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 VO can perform the functions prescribed in the operating documents.
8. The VO must not perform any other duties beyond assisting the PIC with seeing and

a voiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption ta ke precedence and must be followed. Otherwise, the operator22

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 presen t 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 wou ld affect the basis upon which the FAA granted this exemption, then the operator must petition for amendment to the grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the oper ating documents.
10. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the n ecessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight mu st 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 oper ator 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 per son returning the UAS to service.
15. Each UAS 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 di scovered 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 crit eria and demonstrates the ability to safely operate the UAS in a manner23

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 st ructures. PIC qualification flight hours must be logged in a manner consistent with 14 C

. F

. R

. § 61.51(b). The VO is also required to complete the operator’s training requirements. A record of training must be documented and made available upon request by t he Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building), are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated trainin g 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). 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 wi th a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
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 th e 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 con ditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 2 5 % battery power remaining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (C OA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airm e n (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.24

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 fo r 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 under 14 C

. F

. R

. 91.9 and 91.203 must be available to the PIC at the G round 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 opera tions and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. The UA may not be operated over congested or densely populated areas.
32. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, VO, 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 de bris 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 ceas e 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 t hose objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).
33. All operations shall be conducte d 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.

34. 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 to25

the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the N ational Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

d. Operation Of The Inspire 1 UAS Will Be In Accordance With Standard Operating Procedures And Policies

.

“ Standard Operating Procedures (SOP) And Policies ” will regulate iBusiness
Technologies ’ operation of the Inspire 1 UAS and will significantly contribute to maintaining the
level of safety contemplated by the regulations from which iBusiness Technologies now seeks

relief.

T he “ Standard Operating Procedures And Policies
, ” which c ontain proprietary

information, a re attached hereto as Exhibit F , and is to be held in a separate file pursuant to 14

C.F.R. § 11.35(b).

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Af fect Safety.

iBusiness Technologies 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 Inspire 1

UAS unless that PIC has demonstrated , by meeting minimum f light

- hour and currency
requirements
, that the PIC is able to safely operate the Inspire 1 UAS in a manner consistent with

th e exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and str uctures.
Considering iBusiness Technologies ’ 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 Inspire 1 UAS, iBusiness Technologies submits
that the additional manned airmanship experience of a commercially certificated pilot would not26

correlate to the airmanship skills necessary for iBusiness Technologies ’ specific proposed flight
operations.

T he 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
, 1 1063
, 11064
, 11065
, 11066
, 11067
, 11080
, 11109
, 11110, 11112
, 11136, 11138 , 11150,

11153 , 11156, 11158, 11159, 11160, 11161 , 11170, 11171, 11172 ).

iBusiness Technologies will not allow any PIC to operate the Inspire 1 UAS unless that

PIC has demonstrated , by meeting minimum f light

- hour requirements or the Inspire 1 UAS
training and currency requirements, that the PIC is able to safely operate the Inspire 1 UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and
maintaining appropriate dist ances from people, ve ssels, vehicles and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours
logged as a UAS pil ot with a multi

- rotor UAS (with a minimum of 5 hours of those hours as a
UAS pilot operating the same make and model of UAS to be used for operations under the
exemption ). In addition to the hour requirements, the PIC must accomplish 3 take

- offs and

landi ngs of the Inspire 1 UA in the preceding 90 days (for currency purposes).
As in Exemption Nos. 11062
, 11138, and 11153, prior documented flight experience that
was obtained in compliance with applicable regulations will ensure an equivalent level of safety
during iBusiness T echnologies ’ proposed operations. The Administrator has held that prior
documented flight experience that was obtained in compliance with applicable regulations would

ensure safe operations , stating as follows:
In Exemption No. 11062, the FAA required tha t prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated27

and logged, in a manner consistent with 14 C

. F

. R

. 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at leas t 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 und er the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 take

- offs 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 a re 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 sa tisfy 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 o perate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.
Accordingly, iBusiness Technologies will ensure safe operations by not allow ing any PIC
to operate the Inspire 1 UAS unless that PIC has demonst rated
, by meeting minimum flight

- hour
and currency requirements
, that the PIC is able to safely operate the 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 Fr om 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
, iBusiness Technologies will ensure that the Inspire 1 UAS is in an
airworthy condition based up on the UAS’s compliance with its operating documents and as

stated in the proposed conditions and limitations herein

. Additionally, t he FAA has previously granted reli ef from Section 91. 7(a) specific to
UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption28

Nos. 11062, 11063 , 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112 , 11136, 11138
, 11150, 11153
, 11156, 11157, 111 58, 11159, 11160, 11161 , 1116 6, 11167, 11170, 11171,

11172 ).

4

. Reasons Why An Exemption Fr om 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

t he altitude of the Inspire 1 UA w ill be reported to air traffic control ( ATC ) in feet above ground

level ( AGL )
, and iBusiness Technologies will operate the Inspire 1 UA within visual line of
sight
, at or below 400 feet AGL. Furthermore, the altitude information of the Insp ire 1 UA will
be provided to the PIC via GPS equipment and a radio communications telemetry data link,

which downlinks from the UA to the GCS for active monitoring of the flight path and altitude

. Prior to each flight, a zero altitude initiation point is automatically establish ed by the UAS at
ground level.

T he 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 , 11166, 11167, 11170, 11171 ).

5

. Reasons Why An Exemption From The Requirements Of Section 91.151( b ) Would Not Adversely Affect S afety.
A grant of this exemption would ensure an equiv a l e nt level of safety established by 14

C.F.R. Section 91.151( b ) as a result of (1) the technical specifications of the Inspire 1 UAS ; (2)

the limitations on the proposed flight operations ; and (3) th e location of the proposed flight
operations . Accordingly, iBusiness Technologies will ensure that it will safely operate the
battery powered Inspire 1 UA during daylight hours in VFR conditions
, with enough battery29

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 (i.e., 25 percent battery

power remaining )

. Here, as in Exemption No. 11109, the technical specifications of the Inspire 1 UA S ; 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 Inspire 1 UAS provides visual and au dible warnings to

the PIC at the GCS when the UA experiences low battery voltage
, and if no action is taken in
response to the warnings, the UA will automatically retur n to i t s starting point and land. A full
description of the l ow batter y level failsafes is provided at page 1 4 of the Inspire 1 User Manual
,
attached hereto as Exhibit A.
Significantly
, previous exemptions granted by the FAA co ncerning 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, 1 0808, 10673 , 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080
, 11109
, 11110
, 11136, 11138 , 11150, 11153 , 11156, 11157, 11158, 11159, 11160, 11161 , 11166, 11167, 11170,

11171, 11172 ).30

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, iBusiness Technologies submits that the equivalent level of
safety with regard to the regulatory maintenance and alteration requirements established by

Sect ions 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b) will be met because

iBusiness Technologies will perf orm maintenance, alteration s , or preventive maintenance on the

UAS using the methods, techniques, and practices prescribed in the operat ing documents (i.e.
, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety

Guidelines, the OpenPilot Preflight Checklist
, the Intelligent Flight Battery Safety Guidelines
,
and the iBusiness SOP ) , or will utilize manuf acturer authorized support services to perform

maintenance, alteration s , or preventive maintenance on the UAS. Furthermore, iBusiness
Technologies will document and maintain all maintenance records for the Inspire 1 UAS.

Since the Inspire 1 UAS will be inspected as prescribed by t he operating documents
,
iBusiness Technologies will maintain the equivalent level of safety established by Section s
91.405(a)
, 91.409(a)(1)
, and 91.409(a)(2)

. The following operating documents are attached

hereto
, identifie d as the following Exhibits: (A) the Inspire 1 UAS User Manual ; (B) the Inspire

1 UAS Quick Start Guide ; (C) the Inspire 1 UAS Safety Guidelines ; (D) the OpenPilot Preflight

Checklist; (E) the Intelligent Flight Battery Safety Guidelines ; and (F) the iBusi ness SOP

. The
foregoing exhibits contain proprietary information and are to be held in a separate file p ursuant
to 14 C.F.R. § 11.35(b).

Likewise, the exemption sought will not adversely affect safety because iBusiness
Technologies will perform maintenan ce, alteration s or preventive maintenance on the UAS using
the methods, techniques, and practices prescribed by t he operating documents
, or will utilize31

manufacturer authorized support services to perform maintenance, alteration s , or preventive

maintena nce on the UAS.

Furthermore, the exemption sought would maintain an equivalent level o f safety
established by Sections 91.407, 91.417(a) and 91.417(b)
, because iBusiness Technologies will

document and maintain maintenance records for the Inspire 1 UAS.

In consideration of iBusiness Technologies ’ proposed operating limitations, the operating

documents , and the technical aspects of the Inspire 1 UAS, iBusiness Technologies submits that
safety will not be ad versely 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)

. T he FAA has previously granted
relief specific to UAS in circumstances similar, in all material respects, to those pres ented 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 , 1116 6, 11167, 11170,

11171, 11172 ).

7

. T he FAA May Prescribe Any Other Conditions For Safe Operation.

In acco rdance with Sec tion 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, iBusiness Technologies requests that

the FAA prescribe special conditions for the intended operation of the Inspire 1 UAS , whi ch
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), an d 91.417(a) & (b)

. Such special conditions will permit safe operation of the UA for the limited purpose of
conducting aerial acquisitions withi n the NAS for compensation or hire

. FMRA Sec tion 333 sets

forth the requirem ents 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 for32

such UAS to operate without airworthiness certification in acco rdance 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 Inspire 1 UAS
, since the airworthiness regulations of 14 C.F.R. Part
21 do not contain adequate o r 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 airworthines s 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 condit ions 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 sa fety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16

. Therefore, in accordance with FMRA Sec tion 333 and 14 C.F.R. § 21.16 , the FAA may
prescribe special conditions for iBusiness Technologies’ intended operation of the 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), 9 1 .121, 91.151( b )
, 91.405(a), 91. 407(a)(1), 91.409(a)(1) &

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

.
F. A S ummary That C an Be P ublish ed In T he Federal Register, stating: The Rules From Which iBusiness Technologies Seeks Exemption:

iBusiness Technologies, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151( b )
, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

. A Brief Description Of The Nature Of The Exemption iBusiness Technologies Seeks:
This exemption will permit iBusiness Technologies, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions

w ithin the National Airspace System (NAS)

.33

G. Any Additional Information, Views, Or Arguments Available To Support iB usiness Technologies’ Request

.
This Petition is made p ursuant 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
, iBusines s Technologies’ request for exemption may be
granted pursuant to the authority of FMRA Sec tion 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the require ments 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
, iBusiness Technologies will operate the Inspire 1 UAS

safe ly 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
, iBusiness Technologies seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FA A Modernization and Reform Act of 2012 (FMRA)
, which will
permit safe operation of the Inspire 1 UAS commercially
, without an airworthiness certificate
,
for the limited purpose of conducting aerial acquisitions within the National Airspace System

( NAS )

. By granting this Petition, the FAA Administrator will be fulfill ing the Congressional

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

of the public
, by allowing iBusiness Technologies to safely, efficiently, and eco nomically

operate the Inspire 1 UAS commercially with in the NAS

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

Modernization and Reform Act of 2012, Section 333, iBusiness Technologies respectfully

requests that the Administra tor grant this Petition for an exemption from the requirements of 1434

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 iBusiness Technologies to operate the
Inspire 1 UAS commercially for the purpose of conducting aerial acquisitions within the NAS

.
Dated: February 1 1 , 201 5 Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________ Gregory S. Winton, Esq. Jared M. Allen, Esq. 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorneys for Petitioner

cc: James H. Williams , AFS

- 80 Robert Pa ppas Dean Griffith, Esq.