Omar Herrera (Proposed Dba: iDroneVision) SECTION 333 EXEMPTION PETITION 

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Omar Herrera 

(Proposed dba: iDroneVision) 

21 Kristi Lane 

Woodbury, NY 11797 

June 5, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 

14 CFR Part 21 subpart H, 14 CFR 45.23 (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 91.103, 

14 CFR 91.109, 14 CFR 91.119 (c), 14 CFR 91.121, 14 CFR 91.203 (a) and (b), 14 CFR 91.405 (a), 

14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) 

Dear Sir or Madam, 

I, Omar Herrera (proposed dba: “ iDroneVision ”), write this letter pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R.11, 

and request that I, Omar Herrera, a Licensed Real Estate Broker for over 12 years and 

owner/operator of a small unmanned aircraft system (“UAS”), be exempt from the Federal 

Aviation Regulations (“FARs”) listed below and be granted exemption to operate an 

unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal 

Aviation Administration (“FAA”). 

The Exemption Request would be for a DJI Inspire 1, Model T 600 UAS that I own, with 

intent to commercially offer for compensation low cost aerial photography and 

videography to other real estate brokers / agents within the NAS. In the public interest 

this will enhance their listings offered for sale in today’s competitive market without the 

high cost of using manned aircraft for aerial photography and videography. The use of 

UAS’s in the real estate industry provides both buyers and sellers a higher level of service 

for marketing and advertising appealing to more buyers, resulting in fewer days on the 

market sales. Home sales also increase the economy as a whole. I will be able to provide 

a high level of service without the use of high cost fuel, emissions, and loud manned 

aircraft noise and in less time. Considering size, weight, speed, and the DJI Inspire 1 

UAS will poses much less of a safety concern for the general public when compared to 

larger costly manned aircraft. 
Omar Herrera (Proposed Dba: iDroneVision) SECTION 333 EXEMPTION PETITION 

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I, Omar Herrera, am experienced in building and flying remote controlled hobby 

helicopters for recreational purposes for over 22 years without any accidents. I currently 

have over 55 hours of remote control flying including additional DJI Pilot training for the

DJI Inspire 1 UAS. I’m also an insured member of the AMA (Academy of Model 

Aeronautics). Safety is my number one priority, therefore pre-flight inspections and post 

flight inspections are always performed as recommended by the manufacturer owner’s 

manual and documented in a flight log. 

The DJI Inspire 1 UAS has a maximum gross weight of 6 pounds 7.5 ounces, a length 

of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. All photography and video of real estate will be taken at levels of 

approx. 200ft above ground level (AGL), at a speed less than 17 knots, and with a 

maximum flight time of 13.5 minutes allowing additional remaining return to home position 

flight time. The DJI Inspire 1 UAS meets the definition of "small unmanned aircraft" found 

in section 331 "The Reform Act". The DJI Inspire 1 UAS is battery powered there are no 

combustible fuels are onboard. Maximum flight time for the DJI Inspire 1 UAS is approx., 

18 minutes with a TB47, 4500mAh, 22.2 V LiPo 6S battery and approx., 22 minutes TB48, 

57mAh, 22.8 V LiPo 6S battery. For safe a return, all flights are terminated with 25% 

battery life remaining. Given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized I find this exception to be reasonable with an 

equivalent, level of safety to be reached by the Pilot in Command (PIC).

I, Omar Herrera therefore, as Petitioner, 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 Regulations from 

14 CFR Part 21 subpart H,14 CFR 45.23 (b),14 CFR 91.7 (a),14 CFR 91.9 (b) (2),14 CFR 

91.103, 14 CFR 91.109, 14 CFR 91.119 (c), 14 CFR 91.121, 

14 CFR 91.203 (a) and (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 

14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b). 

14 CFR Part 21 subpart H

In consideration of the speed, weight, size, and limited operating area associated 

with the UAS and its operation, the DJI Inspire 1 UAS meets the conditions of FMRA 

Section 333 and therefore, I request exemption of an airworthiness certificate in 

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

14 CFR 45.23 (b) 

The DJI Inspire 1 UAS does not have a cockpit, cabin, or pilot station on which to market 

certain words or phrases due its dimensions. However, in compliance with FAA 

regulations, the UAS’s fuselage will be marked with lettering and/or “N” numbers as large 

as possible to identify the aircraft as required by the FAA ruling to preserve the equivalent 

level of safety and compliance. 
Omar Herrera (Proposed Dba: iDroneVision) SECTION 333 EXEMPTION PETITION 

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14 CFR 91.7 (a) 

The DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. Accordingly, I, Omar Herrera will submit and ensure that 

the DJI Inspire 1 UAS is always in airworthy condition, prior to every flight, by determining 

that the UAS is compliance with the operating documents for the DJI Inspire 1 UAS, and 

pre-flight and maintenance logs for the aircraft’s safe flight conditions.

14 CFR 91.9 (b) (2) 

Due to the dimension and configuration the DJI Inspire 1 UAS, the UAS does not have 

the means of to carry a flight manual on board. I, Omar Herrera, consequently request 

exempt from 14 CFR 91.9 (b) (2) because the flight manuals, are maintained within my 

reach at all times on the ground, both in print format and electronic “pdf “ format with 

immediate access should it be necessary.

14 CFR 91.103 

The DJI Inspire 1 UAS does not have an FAA approved flight manual. However, I request 

exemption 14 CFR 91.103 because procedures for weather check, GPS satellites, flight 

battery levels, landing and take-off measurements, compass calibrations and other flight 

telemetry are found in the DJI Pilot App and provide an equivalent level of pre-flight 

protocols. 

14 CFR 91.109 

The DJI Inspire 1 UAS does not have fully functional dual controls since it is remotely 

piloted via radio communications from the aircraft to a hand held transmitter. Since the 

DJI Inspire 1 UAS does not carry a pilot or passengers the comparable level of safety 

and control is retained by the Pilot in Command (PIC).

14 CFR 91.119 (c) 

In compliance with 14CFR 91.119, I, Omar Herrera as Pilot in Command (PIC), fly only 

within visual line-of-sight (VLOS) or the VLOS of a visual observer (VO) when required. 

The UAS remains at least 500 feet from other people in order to not pose an unwarranted 

hazard to persons and property. All flights are conducted during daylight-only hours 

(sunrise to sunset). Flights are never conducted from a moving vehicle. No flights are 

ever conducted within 5 miles of an airport. No flights are ever over 400 feet above ground 

level (AGL). No flights are ever less than 3 miles visibility from the home point.

14 CFR 91.121 

The DJI Inspire 1 UAS does not have a typical barometric altimeter onboard. However, 

altitude information is provided via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which is downlinked from the DJI Inspire 1 UAS to 

the PIC’s remote control screen actively monitoring the flight path. This altitude 

information, combined with other flight telemetry and flying the DJI Inspire 1 UAS only 

within visual line of sight, and below 400 feet AGL, will ensure an equivalent level of 

safety. In addition should communications be lost at any point, the DJI Inspire 1 UAS will 

automatically return to the home position (failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown. 

 
Omar Herrera (Proposed Dba: iDroneVision) SECTION 333 EXEMPTION PETITION 

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14 CFR 91.203 (a) and (b) 

Given the similarities of, 14 CFR 91.9 (b) (2) Due to the dimension and configuration the 

DJI Inspire 1 UAS, the UAS does not have the means of to carry a flight manual on board. 

An equivalent level of safety is maintained within my reach at all times on the ground by 

having the flight manuals in print format and electronic “pdf” format with immediate access 

should it be necessary.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) 

Furthermore, I, Omar Herrera request relief from Sections 91.405(a),91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

I, Omar Herrera, submit that the requested relief is appropriate since an equivalent level 

of safety will be ensured by performing preventive maintenance on the DJI Inspire 1 UAS 

using the methods, techniques, and practices prescribed in the operating documents for 

the DJI Inspire 1. Furthermore, I document and maintain all flights and maintenance 

records for the DJI Inspire 1 UAS and will made available for inspection by the FAA at 

any time upon request. 

In consideration of the FAA grating me the above Section 333 Exemption Petition, I thank 

the FAA in advance for the efforts to stablish proper regulations and protocols for the use 

of UAS’s within the national airspace. I further standby to support and cooperate with the 

FAA with any request regarding the public safety. 

Thank you. 

Sincerely, 

Omar Herrera 

Attachments: DJI Maintenance Manual, DJI Safety Guidelines, Flight/Maintenance Log Sheet