September 16, 2015 

Attention:

U. S. Department of Transportation Docket Operations West Building 

Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590 

RE: Alan Hurwitz, Alan Hurwitz Videography 

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI Inspire 1 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Alan Hurwitz Videography 

58 Howes Road 

Moretown Vermont, 05660 

561-271-0934 alanhurwitz@me.com
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level Area of Interest

ATC Air Traffic Control

ATP Air Traffic Organization Aerial Vehicle 

CFR Code of Federal Regulations 

CA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command

FAA Modernization and Reform Act of 2012 (FMRA) Safety Observer

SOP Standard Operating Procedures

UAS Unmanned Aircraft Aircraft System

VFP Visual Flight Rules

VLS Visual Line of Site

VMS Visual Meteorological Conditions

VTL Vertical Takeoff and Landing 

SUMMARY 

Alan Hurwitz Videography hereafter referred to as AHV seeks 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

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

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI 

Inspire 1) pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit AHV to 

operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction 

sites, residential and commercial real estate, civil landscapes and events 

over certain areas of the United States. 
INTRODUCTION AND INTERESTS OF THE PETITIONER 

AHV has for over twenty years provided clients (which include private 

sector businesses and non-profits, along with local state and federal 

agencies) with expertise and knowledge in video and multimedia 

marketing, advertising, public relations and training using advanced 

technologies and solutions. AHV has worked on thousands of 

Iproductions over the past 20 years in all types of locations with a 

perfect client and employee safety record. In the past we have supplied 

our clients aerial video and photography using commercial aircraft. The 

objective of AHV and our Unmanned Aircraft System (DJI Inspire 1) 

aerial operations is to provide a more affordable, high-quality production 

system for a variety of governmental, commercial, public, and 

residential uses, specifically targeting 

 • Construction sites before and after 

 • Appraisals 

 • Real-estate marketing 

 • Economic development 

 • Civic landmarks 

 • Special event coverage 
 • Private and governmental training 

My staff has safely flown small RC electric quadcopters 

recreationally for approximately 2 years without incident. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1, UAS 

AHV seeks an exemption to operate DJI Inspire 1 system for 

compensation or hire within the NAS. The DJI Inspire 1 is vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The DJI Inspire 1 has a maximum gross weight of 

approximately 2935 grams while having a diagonal dimension of 

559 to 581 mm, a maximum speed of approximately 22 m/s (ATTI 

mode, no wind) and a maximum flying height of 400'. The DJI 

Inspire 1 is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. 

The DJI Inspire 1 that will be operated by AHV will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 

C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, AHV, 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 DJI Inspire 1, UAS in 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 speed, weight, size, and limited operating area 

associated with the unmanned aircraft and its operation, AHV operation 

of DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and 
therefore, will not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. 

Accordingly, AHV 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. 

AHV submits that the requested relief is proper since an equivalent level 

of safety will be ensured. AHV will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual). Furthermore, AHV will document 

and maintain all maintenance records for the DJI 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 AHV to the extent necessary to allow a Pilot in Command (PIC) 

holding a private pilot or higher level 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 DJI 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. 

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

airworthiness, because the DJI Inspire 1 UAS does not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. As such, AHV submits that they will ensure that the DJI Inspire 1 

UAS is in an airworthy condition, prior to every flight, by determining 

that the UAS are in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight. 
AHV also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a 

typical barometric altimeter onboard. However, altitude information of 

the DJI Inspire 1 UAS will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications 

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

monitoring of the flight path. This altitude information, combined with 

AHV’s operation of the DJI Inspire 1 UAS within visual line of sight, at 

or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 

Additionally, AHV seeks an exemption from the requirements of Section 

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

submits that safety will not be affected by operation of the DJI Inspire 1 

UAS during daylight hours in visual meteorological conditions (VMC) 

under visual flight rules (VFR), with enough battery power to fly for a 

total duration of approximately 23 minutes. Battery power indicators are 

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

much time is needed to return safely back to point of take off. 

In accordance with 14 C.F.R. § 11.81, AHV provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Alan Hurwitz Videography 

58 Howes Road 

Moretown Vermont, 05660 

561-271-0934 alanhurwitz@me.com

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

Exemption. 
1. AHV 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. AHV 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. AHV 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. 

4. AHV 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. AHV 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. AHV 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. AHV 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 

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

accordance with part 21 of this chapter. 

8. AHV 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. 

(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 AHV Seeks And The Reason AHV Seeks The 

Relief. 

1. Extent Of Relief AHV Seeks And The Reason AHV Seeks Relief 

From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges 

and limitations: Pilot in command, is requested to the extent necessary to 

allow a PIC holding a private pilot or higher level certificate, as well as a 

current and valid airman medical certificate, and who has met certain 

flight-hour and currency requirements, to conduct the proposed UAS 

flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 

61.113(a) and (b) state that a private pilot may, for compensation or hire, 

act as PIC of an aircraft in connection with any business or employment 

if: (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation 

or hire. 

As set forth more fully below, AHV submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the 

DJI Inspire 1 UAS unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely 

operate either the DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption, including 

evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. 
Further, AHV submits that all flights of the DJI Inspire 1 UAS, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to AHV’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2. Extent Of Relief AHV Seeks And The Reason AHV 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 AHV to determine that the DJI 

Inspire 1 UAS are in airworthy condition prior to every flight by 

ensuring that the UAS is in compliance with the operating documents 

(i.e., AHV Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual). 

AHV seeks the requested relief because the DJI Inspire 1 UAS does not 

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

Subpart H. Therefore, AHV will ensure that the DJI Inspire 1 UAS are in 

airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1) prior to 

every flight, and further, determine that the aircraft are in condition for 

safe flight, as stated in the conditions and limitations below. 

3. Extent Of Relief AHV Seeks And The Reason AHV Seeks Relief 

From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required 

to allow flight operations of the DJI Inspire 1 UAS, which 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). Since the 

FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level 

(AGL), AHV seeks the requested relief because the DJI Inspire 1 UA’s 

altimeter may be set on the ground to zero feet AGL, rather than the 

local barometric pressure or field altitude, before each flight. 
Considering the limited altitude of the proposed operations, relief from 

14 CFR 91.121 is sought to the extent necessary to comply with the 

applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 UAS are equipped with a barometric pressure sensor and 

GPS equipment, which automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides the 

PIC with altitude information of the UA on the heads-up display of the 

GCS. 

4. Extent Of Relief AHV Seeks And The Reason AHV Seeks Relief 

From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in 

VFR conditions, is requested to the extent required to allow flights of the 

battery powered DJI Inspire 1 UAS during daylight hours in visual 

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

total duration of 23 minutes. AHV seeks the requested relief because 

without an exemption from Section 91.151(b), the flight time duration of 

the battery powered DJI Inspire 1 UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that AHV 

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI 

Inspire 1 UAS, the DJI Inspire 1 operating documents, and AHV’s 

proposed operating limitations, ensure that AHV will safely operate the 

battery powered DJI Inspire 1 UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with 

enough battery power to fly for a total duration of 23 minutes. 

5. Extent Of Relief AHV Seeks And The Reason AHV 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, 

AHV requests relief from these Sections because the DJI Inspire 1 UAS 
do not require airworthiness certificates. As set forth more fully below, 

the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, AHV will 

use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the AHV 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, AHV will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

D. The Reasons Why Granting AHV 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 

AHV to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, events and civic landscape 

over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of 

the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of AHV’s proposed operation of the DJI 

Inspire 1 UAS will be realized without implicating any privacy issues. 

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

The DJI Inspire 1 UAS 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 DJI Inspire 1 UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the safety of life 

and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the 

NAS, congestion around airports caused by arriving and departing 

aircraft will be reduced. The DJI Inspire 1 UAS does not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft 
conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power 

and electric motors, the DJI Inspire 1 UAS produces no air pollution, 

and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, 

while reducing the carbon footprint of aerial acquisitions, also eliminates 

noise pollution, as the UAS are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack 

of flight crew members located onboard the aircraft, the DJI Inspire 1 

UAS (weighing approximately 2935 g at their maximum gross weight 

with diagonal dimension of 559 to 581 mm, and with no fuel on board), 

has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with 

a wingspan of approximately 42 feet, a length of 34 feet, and a fuel 

capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Inspire 1 UAS Will Benefit The Economy. 
In addition to being safe and efficient, the DJI Inspire 1 UAS are also an 

economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Inspire 1 UAS will allow 

United States based companies, like AHV, 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 DJI Inspire 1 UAS 

is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the DJI Inspire 1 UAS, companies such as AHV, can 

remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute 

to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Inspire 1 UAS, provides 

a stable workforce that increases consumer spending; improves local, 

state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the 

United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, AHV’s proposed operation of the DJI Inspire 1 

UAS will not implicate any privacy issues. Specifically, the DJI Inspire 

1 UAS will be operated only in compliance with operating documents 

(i.e., AHV Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 
E. The Reasons Why Granting The Exemption Would Not Adversely 

Affect Safety, Or How The Exemption Would Provide A Level Of Safety 

At Least Equal To That Provided By The Rule From Which AHV Seeks 

Exemption. 

1. Reasons Why The DJI 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, AHV’s 

operation of the DJI Inspire 1 UAS meet the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without 

airworthiness certification and sets forth requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, 

and not later than 180 days after the date of enactment of this Act, the 

Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this 

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

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

determination under subsection (a), the Secretary shall determine, at a 

minimum-- 

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

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a 

hazard to users of the national airspace system or the public or pose a 

threat to national security; and 
(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under 

this section that certain unmanned aircraft systems may operate safely in 

the national airspace system, the Secretary shall establish requirements 

for the safe operation of such aircraft systems in the national airspace 

system. 

In seeking this exemption, AHV submits that the DJI Inspire 1 UAS can 

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

demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the 

pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics. The DJI Inspire 1 UAS does not create a hazard to users 

of the NAS or the public, or otherwise pose a threat to national security 

considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth by the 

DJI Inspire 1 User 

Manual, attached hereto as Appendix A. 

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

To Remain Within A Defined Operational Area. 

The DJI Inspire 1 UAS may be operated in both manual and global 

positioning flight modes. A complete description of the flight and 

navigational modes of the DJI Inspire 1 UAS is provided at pages 11 of 

the DJI Inspire 1 User Manual attached hereto as Appendix A. 
iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation. 

When the Control Link is lost, the DJI Inspire 1 UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Inspire 1 UAS does not reacquire control link data from the GCS, the 

UAS will assume that the Control Link is lost and the will return to the 

home position (i.e., failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 

UAS are set forth at pages 12 through 14 of the DJI Inspire 1 User 

Manual, attached hereto as Appendix A. 

iv. The DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

Inspire 1 GCS and flight control software is provided at pages 23 

through 29 of the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual 

is attached hereto as Appendix A. 

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

Sight Of A Certificated Pilot in Command With A Safety Observer. 

AHV video production staff will be the only persons to act as a pilot in 

command (PIC) of the DJI Inspire 1 UAS. Additionally, a safety 

observer will assist him at all times during flight time. 

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, AHV proposes to commercially operate DJI 

Inspire 1 UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the 

following specific operating limitations. 
1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UAS 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1 

Unmanned Aircraft Systems. 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 video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 

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 unless a special request is made and approved 

by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS 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 safety observer (SO) 

is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be 

used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The SO 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 SO can perform the functions 

prescribed in the operating documents. 

8. The SO 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 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 the exemption, then 

the operator must petition for amendment to its 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 that 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 third- class 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 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). Flights for the purposes 

of training the operator’s PICs 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). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of 

operations. 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 pre- determined 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 Airman (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. 
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 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 fewer than 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. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, 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, SO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 91.119(a). 

32. 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. 

33. 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 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. 

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety. 

AHV submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to 

operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the DJI 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 AHV’s proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot 

aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the DJI Inspire 1 UAS, AHV submits that the 

additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for AHV’s 

specific proposed flight operations. 
The FAA has previously granted relief from Section 61.113(a) and (b) 

specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

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

AHV will not allow any PIC to operate the DJI Inspire 1 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Inspire 1 UAS training and currency 

requirements, that the PIC is able to safely operate the DJI 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 (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 takeoffs and landings 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 AHV’s 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 and logged, in a manner 

consistent with 14 CFR 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 takeoffs 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 experiencebuilding 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, AHV will ensure safe operations by not allowing any PIC 

to operate the DJI 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 DJI 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, AHV will ensure that the DJI 

Inspire 1 UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions 

and limitations herein. 
Additionally, the FAA has previously granted relief from Section 91.7(a) 

specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 

91.121 Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be 

maintained because the altitude information of the DJI Inspire 1 UAS 

will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to 

the GCS for active monitoring of the flight path and altitude. This 

altitude information, combined with AHV’s operation of the DJI Inspire 

1 UAS within visual line of sight, at or below 500 feet AGL, will ensure 

a level of safety equivalent to Section 91.121. The altitude information 

will be generated by GPS equipment installed onboard the aircraft. Prior 

to each flight, a zero altitude initiation point is automatically established 

by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to 

UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical 

specifications of the DJI Inspire 1 UAS; (2) the limitations on the 

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

operations. Accordingly, AHV will ensure that it will safely operate the 

battery powered DJI Inspire 1 UAS during daylight hours in VFR 
conditions, with enough battery power to fly for a total duration of 23 

minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI 

Inspire 1 UAS; the limitations on the proposed flight operations; and the 

location of the proposed operations, will ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety 

will be ensured as the DJI Inspire 1 UAS provide audible and visual 

warnings to the PIC at the GCS when the UAS experiences low battery 

voltage, the first warning occurring at approximately 33% remaining 

battery power, and again at approximately 10% remaining battery power. 

At the critically low battery level, the DJI Inspire 1 UAS will descend 

and land automatically. 

Significantly, previous exemptions granted by the FAA concerning 

Section 91.151 establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less 

than the minimums prescribed in Section 91.151, including Exemption 

Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in 

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

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) 

Would Not Adversely Affect Safety. 

In seeking this exemption, AHV 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 AHV will use 

trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., AHV Aerial Operations 
Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction 

Manual). Furthermore, AHV will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

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

operating documents, AHV will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A 

copy of the DJI Inspire 1 User Manuals are attached hereto as Appendix 

A and B; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached 

hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because 

AHV will use trained technicians to perform maintenance, alterations or 

preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level 

of safety established by Sections 91.407, 91.417(a) and 91.417(b), 

because all maintenance of the DJI Inspire 1 UAS will be performed by 

trained technicians. Maintenance will be documented and maintained 

utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. 

In consideration of AHV’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, AHV 

submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)

(2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to UAS in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 
7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, 

AHV requests that the FAA prescribe special conditions for the intended 

operation of the DJI Inspire 1 UAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

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

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

conditions will permit safe operation of the UAS for the limited purpose 

of conducting aerial video and photography over certain areas of the 

United States for compensation or hire. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 

14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features 

of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do 

not contain adequate or appropriate safety standards for an aircraft, 

aircraft engine, or propeller because of a novel or unusual design feature 

of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller 

as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16. 
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 

21.16, the FAA may prescribe special conditions for Leading Edge’s 

intended operation of the DJI Inspire 1 UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R Sections 

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

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

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

The Rules From Which AHV Seeks Exemption: 

AHV 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 AHV Seeks: 

This exemption will permit AHV to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To 

Support AHV’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform 

Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to 

determine if certain UAS may operate safely in the NAS. As such, 

AHV’s request for exemption may be granted pursuant to the authority 

of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification. 
As discussed in detail above, AHV will operate the DJI Inspire 1 UAS 

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

public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, AHV seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA), which will permit safe operation of the DJI Inspire 1 

UAS commercially, without an airworthiness certificate, for the limited 

purpose of conducting aerial video and photography over certain areas 

of the United States. By granting this Petition, the FAA Administrator 

will be fulfilling the Congressional mandate of the FAA Modernization 

and Reform Act of 2012, while also advancing the interests of the 

public, by allowing AHV to safely, efficiently, and economically operate 

the DJI Inspire 1 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and 

the FAA Modernization and Reform Act of 2012, Section 333, AHV 

respectfully requests that the Administrator grant this Petition for an 

exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 

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

(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Inspire 1 UAS commercially for the purpose of conducting aerial video 

and photography over certain areas of the United States. 

Dated: September 16, 2015 Respectfully submitted, 

Alan Hurwitz Videography 

58 Howes Road 

Moretown Vermont, 05660 

561-271-0934 alanhurwitz@me.com
Appendices:

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

26

http://download.dji-innovations.com/downloads/inspire_1/fr/

Inspire_1_Quick_Start_Guide_v1.4_fr.pdf