Transp o sur e ®

Creativ e

Mail | P.O. Box 161 . Milford . New Jersey . 08848

Studio | 643 East Broad Street . Bethlehem . Pennsylvania . 18018

PETITION FOR RELIEF OF REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS, SPECIFICALLY AS 

AUTHORIZED UNDER THE F.A.A. MODERNIZATION AND REFORM ACT OF 2012,

SECTION 333; SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS. 

Kenneth P. Volpe, DBA as Transposure, LLC 

Transposure, LLC seeks exemptions from Title 14 of the Code of Federal Regulations: 61.113(a) and (b); 

91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b), in order to 

operate a DJI Inspire 1 UAS. This exemption will allow Transposure, LLC to operate an unmanned aerial 

vehicle commercially for the purposes of conducting aerial video and still photography in the Real Estate, 

Insurance, Engineering, Construction and Filmmaking markets of New Jersey and Pennsylvania. These still 

images and videos will provide both commercial and community awareness and understanding of aerial 

imaging systems.

Transposure, LLC is a professional photography and videography imagery company producing high quality 

results for clients who require ground and aerial based imagery for Real Estate, Insurance, Engineering, 

Construction and Filmmaking purposes throughout the New Jersey and Pennsylvania markets. Mr. Kenneth 

P. Volpe is the owner of Transposure, LLC. He is also the owner of a separate structural engineering 

company. Mr. Volpe is a licensed professional engineer in New Jersey and Pennsylvania as well as other 

states. Transposure, LLC will be using a factory spec DJI Inspire 1 quad copter to commercially capture still 

and video imagery while working on private and public properties for the purpose of aerial imagery services. 

Transposure, LLC will employ both a pilot and visual observer at all times to maintain a visual line-of-sight 

between the quad copter and the pilot UAV operator. Additional safeguards will entail the posting of 

ground-based caution signs and property owner consent.

THE DJI INSPIRE 1

The DJI Inspire 1 is an electric powered quad copter weighing less than seven pounds and is operated via a 

handheld remote that features a “Return to Home” command. The Return to Home feature can be 

triggered manually and the UAV unit works off of a 2.4 GHz downlink for remote control. The video function 

works on a 5.8 GHz frequency. The camera system is comprised of a gimbal mounted 4K image sensor and 

is operated from the handheld remote control. Each of the units (UAV and handheld remote) are powered 

by separate batteries affording the DJI Inspire 1 approximately 18 minutes of flight time. The remote control 

provides real time battery reserve data with both visual and audible alarms when battery power is 

approaching the point required for a safe “return to home” flight.

BASIS FOR PETITION 

Transposure, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. SS 11.61) and the 

F.A.A. Modernization and Reformed Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to operate the DJI INSPIRE 1 UAS within the National Airspace 

System, and for an exemption from the requirements of 14 CFR SS 61.113(a) and (b), 91.7(a), 91.119, 91.121, 

91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b). 

NAME AND ADDRESS OF THE PETITIONER 

Kenneth P. Volpe, Owner

Transposure, LLC

PO Box 161

Milford, New Jersey 08848

ken@transposure.com
Transp o sur e

Creativ e

Mail | P.O. Box 161 . Milford . New Jersey . 08848

Studio | 643 East Broad Street . Bethlehem . Pennsylvania . 18018

TRANSPOSURE, LLC REQUESTS RELIEF FROM THE FOLLOWING SECTIONS OF 14 C.F.R. 

Sections 61.113, entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) and (b).

Extent of relief from 61.113 sought by Transposure, LLC:

1. (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. 

2. (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. 

Relief from section 61.113(a) and (b) is requested to allow a PIC to operate the DJI Inspire 1. The flight would 

be complemented by a visual observer who will, along with the pilot, maintain visual line of sight with the DJI 

Inspire 1 at all times. All operations will be conducted as per Transposure LLC’s business related operations. 

The DJI Inspire 1 is not able to carry passengers. 

Section 91.7, entitled Civil airworthiness subsection (a).

Transposure LLC requests to be allowed to determine the airworthiness of the DJI Inspire 1. 

Section 91.119 entitled Minimum Safe Altitudes, General. 

Relief from 91.119 is requested to allow operations of the DJI Inspire 1 at altitudes not exceeding 400 feet 

AGL, over private property and/or at a distance at or greater than five nautical miles from the nearest 

airport as depicted on current aeronautical charts.

Transposure, LLC also wishes to be granted exemptions to operate at an altitude not more than 50 feet AGL 

or below tree level between one and five nautical miles from the nearest airport as depicted on current 

aeronautical charts. 

Section 91.121, entitled Altimeter Settings.

Extent of relief that Transposure, LLC seeks from 91.121(a):

Altimeter Settings 

Extent of relief from 91.121 is requested because the DJI Inspire 1 utilizes an Electronic GPS with a barometric 

sensor.

Section 91.151 entitled Fuel requirements for flight in VFR conditions.

Extent of relief that Transposure, LLC seeks in regard to section 91.151(a), Fuel Requirements for Flight in VFR 

Conditions:

Relief from 91.151(b), is requested to the extent that allows Transposure, LLC to operate the DJI Inspire 1 up 

to a point that there is enough power to fly at normal cruising speed to the landing point and land the 

vehicle with 25% battery power remaining. (Note: A visual low battery indicator on the operating console for 

the DJI Inspire 1 is supplemented by an audible spoken alarm warning the pilot of a low battery condition.)
Transp o sur e

Creativ e

Mail | P.O. Box 161 . Milford . New Jersey . 08848

Studio | 643 East Broad Street . Bethlehem . Pennsylvania . 18018

Section 91.405, entitled Maintenance required.

Section 91.407 (a) (1), entitled Operation after maintenance, preventative maintenance, rebuilding, or 

alteration. 

Section 91.409 entitled Inspections. 

Section 91.417 entitled Maintenance Records.

Extent of relief that Transposure, LLC seeks in regards to sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and 

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

These are all associated with an airworthiness certificate. There are currently no airworthiness certificates for 

small UAVs. 

BENEFITS GAINED VIA RELIEF FOR TRANSPOSURE, LLC from the above stated Federal Regulations: 

A. Use of the small UAV will allow for more accurate and timely aerial imagery, mapping, and surveying of 

contracted imagery tasks.

B. Use of the small UAV will allow for a more economical solution for contracted imagery tasks since the 

cost to operate a small UAV is a fraction of the cost of operating a full size aircraft for aerial imagery. 

C. Use of the small UAV will reduce the risk to life and property as compared to the manned aerial imagery 

alternative.

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE REQUESTED EXEMPTIONS: 

A. Standard operating procedures prior to launch will include a comprehensive preflight checklist of the 

vehicle and a ground level visual inspection of area to be surveyed. 

B. Flight operations will be conducted by a two-man crew consisting of the PIC and the Visual Observer. All 

operations will be conducted with a clear visual line of sight (VLOS) between the team and the UAV at 

all times. 

C. Transposure, LLC will only operate the UAV over private or public property with the consent of the 

property owner or the governing body and will maintain a safe distance from any structures, people or 

vehicles. 

This petition is being made pursuant to the FAA Modernization and Reform Act of 2012, Section 333, which 

directs the Secretary of Transportation to determine if any UAS may safely operate in the National Airspace. 

Transposure, LLC will operate all aircraft granted for use by the exemption as directed by the DJI Inspire 1 

operating manual provided by the manufacturer. 

IN CONCLUSION 

As set forth previously Transposure, LLC seeks an exemption pursuant to 14 CFR: 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012, which will permit safe operation of the DJI Inspire 1 UAS 

commercially for the purposes stated herein. The Administrator will be assisting small business by granting this 

petition. 

Respectfully submitted by Transposure LLC. 

Kenneth P. Volpe, P.E.

PO Box 161

Milford, New Jersey 08848

ken@transposure.com