UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

iBUSINESS TECHNOLOGIES, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

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

Submitted on February 11, 2015

GREGORY S. WINTON, ESQ.

JARED M. ALLEN, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorneys for Petitioner
2

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH iBUSINESS

TECHNOLOGIES, LLC SEEKS EXEMPTION ..........................................................8

THE EXTENT OF RELIEF iBUSINESS TECHNOLOGIES, LLC SEEKS AND 

THE REASON iBUSINESS TECHNOLOGIES, LLC SEEKS THE RELIEF ..........11

THE REASONS WHY GRANTING iBUSINESS TECHNOLOGIES, LLC'S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ............................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........32

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT iBUSINESS TECHNOLOGIES, LLC'S REQUEST..........................33

CONCLUSION.................................................................................................................33
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

PIC Pilot In 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 Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing 
4

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 exemption will permit iBusiness

Technologies, LLC to operate an Unmanned Aircraft System (UAS) for the commercial 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 mobile 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 Inspire 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) Unmanned Aircraft (UA) and a 

transportable Ground Control Station (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 driven by a Lithium Polymer battery 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, Aircraft 
5

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

Modernization and Reform Act of 2012 (FMRA) Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

Inspire 1 UAS within the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

In consideration of the size, weight, speed, and limited operating area associated with 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. Part 21, Subpart H. 

Accordingly, 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. 

iBusiness Technologies submits that the requested relief is proper since an equivalent 

level of safety will be ensured. iBusiness Technologies will perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 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 iBusiness SOP), or will utilize manufacturer authorized 
6

support services to perform maintenance, alterations, 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 Command (PIC) holding a 

private pilot certificate, as well as an airman medical certificate, and who has demonstrated, 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 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. Part 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 

determining 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), 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 the altitude reporting equipment of the Inspire 1 UAS 

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

altitude, before each flight. The altitude information of the Inspire 1 UA is provided to the PIC

via a barometric pressure sensor, Global Positioning System (GPS) equipment, and a radio 
7

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. A level of safety equivalent to 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.

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 after 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 And Address Of The Petitioner.

The name and address of the Petitioner is:

iBusiness Technologies, LLC

Box 364

Wynnewood, PA 19096-0364

The point of contact for this Petition 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

Email: Greg@aviationlawexperts.com
8

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

Exemption.

1. iBusiness Technologies 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. iBusiness 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 condition.

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 altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(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 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. iBusiness Technologies 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. iBusiness Technologies 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. iBusiness Technologies Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

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

unless, within 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
10

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

with part 21 of this chapter.

8. iBusiness Technologies 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.

(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.
11

(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 iBusiness Technologies Seeks And The Reason iBusiness

Technologies Seeks The Relief.

1. Extent Of 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) entitled 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 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, iBusiness 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, demonstrating that the PIC is 
12

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

as set forth herein, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.

Further, 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 compensation or hire.

2. Extent Of Relief iBusiness Technologies Seeks And The Reason iBusiness

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

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

upon its compliance with the operating documents prior to every flight, and further, determine 

that the aircraft is in a condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of 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 the Inspire 1 UA’s altitude reporting equipment may be 

set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before
13

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 the 

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 the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, a level of safety equivalent to 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 Of Relief iBusiness Technologies Seeks And The Reason iBusiness

Technologies 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 Inspire 1 UA during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery power remaining). 

iBusiness Technologies seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered Inspire 1 UA will severely constrain 

the practicality of any aerial acquisition and research flight operations that iBusiness

Technologies proposes 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 iBusiness 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 rules 
14

(VFR), with enough battery power to fly, for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes

(i.e., 25 percent battery power remaining).

5. Extent Of Relief iBusiness Technologies Seeks And The Reason iBusiness

Technologies 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, iBusiness Technologies requests relief from 

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

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

operation without an airworthiness certificate. Accordingly, iBusiness Technologies will

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices 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 iBusiness 

SOP ), or will utilize manufacturer authorized support services to perform maintenance, 

alterations, or preventive maintenance on the UAS. Furthermore, iBusiness Technologies will 

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.

Granting the present Petition will further the public interest by allowing iBusiness

Technologies to safely, efficiently, and economically perform aerial acquisitions within the NAS, 

commercially, in support of the real estate industry, 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 iBusiness 
15

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

privacy issues.

1. The Public Will Benefit From The Aerial Acquisitions 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-referenced industries 

and the public. In the real estate industry, aerial imagery 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, scientific 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 aircraft 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, and 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 Inspire 
16

1 UA does not require an airport to takeoff or land. Likewise, a reduction 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 From 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 traditional 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 

reduces 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 with 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 18 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 (weighing 

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 being 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 adopt 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 without 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 federal 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 conducted for 

decades, iBusiness Technologies’ proposed operation of the Inspire 1 UAS will not implicate any 

privacy issues. Specifically, the Inspire 1 UAS will be operated pursuant to the specific 

conditions and limitations set forth herein, and in accordance with the Federal Aviation 
18

Regulations, including 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 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, iBusiness Technologies’ operation of the Inspire 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 forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1).
19

(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, iBusiness Technologies submits that the Inspire 1 UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 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) And 

Policies.”

a. The Specifications Of The Inspire 1 UAS 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. Technical 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 pursuant to 14 C.F.R. § 11.35(b)1.

ii. The Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational 

Area.

The Inspire 1 UAS may be operated in both manual and autonomous flight modes. A 

complete description of autonomous flight modes is provided at pages 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. § 11.35(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 Designed 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 

pages 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 system software, known as the DJI Pilot App. A

complete description of the operation and specifications of the Inspire 1 remote controller is 

provided at pages 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 43 of the Inspire 1 

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

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

is set forth at page 58 of the Inspire 1 UAS User 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 in Command With 

A Safety Observer.

iBusiness Technologies will only utilize certificated pilots who possess a current and

valid FAA issued airman medical certificate 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. Flights Of The Inspire 1 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations.

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 pounds 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 operating 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 lenses, 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 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

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

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

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

in the grant of exemption take precedence and must be followed. Otherwise, the operator 
22

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

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

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

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

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

update or revision would affect the basis upon which the FAA granted 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 operating 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 necessary 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 must 

make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

15. Each 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 discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 
23

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). 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 the 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 

training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC 

must operate the UA with appropriate distance from nonparticipants in accordance with 

14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s management is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

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

accordance with the operating documents.

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

accordance with the operating documents. 

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

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

landing point and land the UA with 25% battery power remaining. 

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

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airmen 

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

large as practicable. 

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

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

other appropriate government oversight agency requirements. 

28. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. 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 debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and; 

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 conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

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 to 
25

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

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

NTSB Web site: www.ntsb.gov. 

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. 

The “Standard Operating Procedures And Policies,” which contain proprietary 

information, are 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 Affect 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 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.

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 not 
26

correlate to the airmanship skills necessary for iBusiness Technologies’ 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, 11170, 11171, 11172).

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

PIC has demonstrated, by meeting minimum flight-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 distances from people, vessels, 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 pilot 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 

landings 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 Technologies’ 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 that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 
27

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 pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

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 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, iBusiness Technologies will ensure safe operations by not allowing any PIC 

to operate the Inspire 1 UAS unless that PIC has demonstrated, 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 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, iBusiness Technologies will ensure that the Inspire 1 UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the proposed 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 
28

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

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 

11172).

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 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. Furthermore, the altitude information of the Inspire 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 established by the UAS at 

ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171).

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 Inspire 1 UAS; (2)

the limitations on the proposed flight operations; and (3) the 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 battery 
29

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 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 Inspire 1 UAS provides visual and audible 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 return to its starting point and land. A full 

description of the low battery level failsafes is provided at page 14 of the Inspire 1 User Manual, 

attached hereto as Exhibit A.

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, 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 

Sections 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 perform maintenance, alterations, or preventive maintenance on the 

UAS using the methods, techniques, and practices 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 iBusiness SOP ), or will utilize manufacturer authorized support services to perform 

maintenance, alterations, 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 the operating documents, 

iBusiness Technologies will maintain the equivalent level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating documents are attached 

hereto, identified 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 iBusiness SOP. The 

foregoing exhibits contain proprietary information and are to be held in a separate file pursuant 

to 14 C.F.R. § 11.35(b).

Likewise, the exemption sought will not adversely affect safety because iBusiness

Technologies will perform maintenance, alterations or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed by the operating documents, or will utilize 
31

manufacturer authorized support services to perform maintenance, alterations, or preventive 

maintenance on the UAS. 

Furthermore, the exemption sought would maintain an equivalent level of 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 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, 11166, 11167, 11170, 

11171, 11172).

 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, iBusiness Technologies requests that 

the FAA prescribe special conditions for the 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 §§ 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 UA for the limited purpose of 

conducting aerial acquisitions within the NAS 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 
32

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 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 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), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

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

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which 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

within the National Airspace System (NAS).
33

G. Any Additional Information, Views, Or Arguments Available To Support iBusiness 

Technologies’ 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, iBusiness Technologies’ 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, iBusiness Technologies will operate the 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, iBusiness Technologies 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 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 fulfilling 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 economically

operate the 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, iBusiness Technologies respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14 
34

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 11, 2015

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 Pappas

Dean Griffith, Esq.