August 5, 2015

Exemption No. 12343

Regulatory Docket No. FAA–2015–1227

Mr. Dino S. Tassara

Multicopter Maui LLC

P.O. BOX 11964

Lahaina, HI 96761

Dear Mr. Tassara:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 31, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Multicopter Maui LLC (hereinafter petitioner or operator) for an exemption. The

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial video 

and photography of construction sites, real estate, special events, film sets, and landscape.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 
2

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Multicopter Maui LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Multicopter Maui LLC is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported 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 or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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 duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

or amendment to this 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 an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

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

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

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

 FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Multicopter Maui 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 DJI 

QUADCOPTER UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012

 (PUBLIC LAW 112-95) 

___________________________________________________________________________

Submitted on April 17, 2015

Dino S Tassara

Multicopter Maui LLC

PO BOX 11964 Lahaina, Hawaii 96761

Tel: (808) 214-7791 

Email: multicoptermaui@gmail.com 
TABLE OF CONTENTS 

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

SUMMARY.............................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER.......................................4 

BACKGROUND.......................................................................................4 

BASIS FOR PETITION...............................................................................5 

NAME AND ADDRESS OF PETITIONER...............................................7 

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MULTICOPTER

 MAUI LLC SEEKS EXEMPTION........................................................8 

EXTENT OF RELIEF MULTICOPTER MAUI LLC SEEKS AND 

 THE REASON MULTICOPTER MAUI LLC SEEKS THE RELIEF.................11 

REASONS WHY GRANTING MULTICOPTER MAUI LLC’S REQUEST

 WOULD BE IN THE PUBLIC INTEREST...............................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

 ADVERSELY AFFECT SAFETY..........................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

 AVAILABLE TO SUPPORT NARRATE STUDIOS LLC’S REQUEST.............34 

CONCLUSION........................................................................................35 
GLOSSARY OF ABBREVIATIONS

AGL

AOI

ATC

ATO

AV

CFR

COA

FAA

FAR

GCS

GPS

LOL

NAS 

NOTAM

PIC

Section 333

SO

SOP

UA

UAS

VFR

VLOS

VMC

VTOL 

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization

Aerial Vehicle 

Code of Federal Regulations

Certificate of Authorization

Federal Aviation Administration

Federal Aviation Regulation

Ground Control Station 

Global Positioning System

Loss of Link

National Airspace System

Notice to Airman 

Pilot In Command

FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landing 
SUMMARY 

Dino S. Tassara 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 Multicopter Maui LLC to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial 

video and photography of construction sites, real estate, special events, film sets, and landscape 

over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Multicopter Maui LLC provides its clients with the highest quality digital content for use in 

their commercial, personal, and non-profit multimedia projects. Multicopter Maui LLC has 

established itself as a technological innovator in multimedia and is recognized as a leader in 

providing high quality product and services. Multicopter Maui LLC has over 20 years 

recreational/hobby experience in all aspects of aerial video and photography. The objective of 

Multicopter Maui LLC aerial video and photography operations is to provide high quality 

imaging for a variety of commercial, public, and residential uses, specifically targeting: 

• Aerial event photography

• Real Estate Marketing

• Aerial event filming 

• Film production 

• Aerial location scouting and safety inspection 

• Increase public knowledge of UAS and promote safe UAS operations. 
BACKGROUND 

Unmanned Aircraft Systems: DJI Quadcopter UAS

Multicopter Maui LLC seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Quadcopter UAS is a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smart phone systems. The DJI Quadcopter UAS has a maximum gross weight 

of approximately 3 pounds and a maximum speed of approximately 29 knots. The DJI 

Quadcopter UA is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 

The DJI Quadcopter UAS UA that will be operated by Multicopter Maui LLC 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, Multicopter Maui LLC, 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 Quadcopter UA 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, Multicopter Maui LLC operation of DJI Quadcopter UA 

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, Multicopter Maui LLC 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. 

Multicopter Maui LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Multicopter Maui LLC 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 Quadcopter Instruction Manual). Furthermore, Multicopter Maui LLC will 

document and maintain all maintenance records for the DJI Quadcopter UA. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by Multicopter Maui LLC 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 

Quadcopter UA in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Multicopter Maui LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Quadcopter UA do not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Multicopter Maui LLC submits that it will ensure that 

the DJI Quadcopter UA are in an airworthy condition, prior to every flight, by determining that 

the UA are in compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Quadcopter Instruction Manual), and that the aircraft are in a condition for safe flight. 

Multicopter Maui LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Quadcopter UA will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Quadcopter UA 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 Multicopter Maui LLC’s operation of the DJI 

Quadcopter UA within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 
Additionally, Multicopter Maui LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Multicopter Maui LLC 

submits that safety will not be affected by operation of the DJI Quadcopter 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 approximately 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. 

In accordance with 14 C.F.R. § 11.81, Multicopter Maui LLC 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: 

Dino Tassara

Multicopter Maui LLC

PO BOX 11964 Lahaina, Hawaii 96761

Tel: (808) 214-7791

Email: multicoptermaui@gmail.com 

B. The Specific Sections Of 14 C.F.R. From Which Multicopter Maui LLC Seeks 

Exemption. 1. Multicopter Maui LLC 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. Multicopter Maui LLC 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. Multicopter Maui LLC 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. Multicopter Maui LLC 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. Multicopter Maui LLC 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. Multicopter Maui LLC 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. Multicopter Maui LLC 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. Multicopter Maui LLC 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 Multicopter Maui LLC Seeks And The Reason Multicopter Maui 

LLC Seeks The Relief. 

1. Extent Of Relief Multicopter Maui LLC Seeks And The Reason Multicopter Maui LLC 

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, Multicopter Maui LLC submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Quadcopter UA unless 

that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate either the DJI Quadcopter UA 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, Multicopter Maui LLC submits that all flights of the DJI Quadcopter UA, conducted 

by the PIC pursuant to the grant of this Petition: (1) will be incidental to Multicopter Maui LLC 

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

2. Extent Of Relief Multicopter Maui LLC Seeks And The Multicopter Maui LLC 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 Multicopter Maui LLC to determine that the DJI Quadcopter UA are in 

airworthy condition prior to every flight by ensuring that the UA is in compliance with the 

operating documents (i.e., the Multicopter Maui LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Quadcopter Instruction Manual). 

Multicopter Maui LLC seeks the requested relief because the DJI Quadcopter UA do not 

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

Multicopter Maui LLC will ensure that the DJI Quadcopter UA are in airworthy condition 

based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Quadcopter Instruction Manual) 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 Multicopter Maui LLC Seeks And The Reason Multicopter Maui LLC 

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Quadcopter UA, which utilize 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), Multicopter Maui LLC seeks the requested relief because the DJI 

Quadcopter 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 Quadcopter UA 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 Multicopter Maui LLC Seeks And The Multicopter Maui LLC 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 Quadcopter 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. Multicopter Maui LLC seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered DJI Quadcopter UA will severely constrain the practicality of any aerial 

video or still photo flight operations that Multicopter Maui LLC proposes to conduct pursuant 

to this Petition. 

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

Quadcopter UA operating documents, and Multicopter Maui LLC’s proposed operating 

limitations, ensure that Multicopter Maui LLC will safely operate the battery powered DJI 

Quadcopter 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 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. 

5. Extent Of Relief Multicopter Maui LLC Seeks And The Reason Multicopter Maui LLC 

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, Narrate Studios LLC requests relief from these 

Sections because the DJI Quadcopter UA does not require airworthiness certificates. As set 

forth more fully below, the DJI Quadcopter UA meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Multicopter Maui LLC will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the UAS operating documents 

(i.e., the Multicopter Maui LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Quadcopter UA Instruction Manual).
D. The Reasons Why Granting Multicopter Maui LLC 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 Multicopter Maui LLC 

to safely, efficiently, and economically perform aerial video and photography of special events, 

film sets, and landscape over certain areas of the United States. 

Additionally, use of the DJI Quadcopter UA will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Multicopter 

Maui LLC’s proposed operation of the DJI Quadcopter US will be realized without implicating 

any privacy issues. 

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

The DJI Quadcopter UA are battery powered and serve 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 Quadcopter UA 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 Quadcopter 

UA do 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 Quadcopter UA. 

Conducting aerial acquisitions with the DJI Quadcopter UA, 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 Quadcopter UA produce 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 Quadcopter UA, 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 Quadcopter UA 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 Quadcopter UA (weighing 

approximately 2 pounds 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 Quadcopter UA 

Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Quadcopter UA is also an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI 

Quadcopter UA will allow United States based companies, like Multicopter Maui LLC, 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 

Quadcopter UA 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 Quadcopter UA, companies such as Multicopter Maui LLC, 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 Quadcopter UA, 

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, 

Multicopter Maui LLC proposed operation of the DJI Quadcopter UA will not implicate any 

privacy issues. Specifically, the DJI Quadcopter UA will be operated only in compliance with 

operating documents (i.e., the Multicopter Maui LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Quadcopter UA 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 Multicopter Maui LLC Seeks Exemption. 

1. Reasons Why The DJI Quadcopter UA Meet 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, Multicopter Maui LLC operation of the DJI Quadcopter 

UA 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, Multicopter Maui LLC submits that the DJI Quadcopter UA can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Quadcopter UA; (b) the pilot certification requirement; and (c) the 

specific operating limitations. 

a. The Specifications Of The DJI Quadcopter UA Demonstrate Its Safe Characteristics. 

The DJI Quadcopter UA 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 Quadcopter UA. 

The technical specifications of the DJI Quadcopter UA is set forth by the DJI Quadcopter UA 

Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Quadcopter UA Autonomous Flight And Navigation Modes Enable The UAS 

To Remain Within A Defined Operational Area. 

The DJI Quadcopter UA may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI Quadcopter UA is 

provided at pages 25-35 of the DJI Quadcopter User Manual, attached hereto as Exhibit B. 

iii. The DJI Quadcopter UA 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 Quadcopter UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Quadcopter UA does not reacquire control link 

data from the GCS, the UA will assume that the Control Link is lost and the UA 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 Quadcopter UA are set forth at 

pages 27 through 29 of the DJI Quadcopter User Manual, attached here to as B. 
iv. The DJI Quadcopter GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Quadcopter GCS and 

flight control software is provided at pages 32 through 43 of the DJI Quadcopter User Manual. 

DJI Quadcopter User Manual is attached hereto as Exhibit B. 

b. Flight Operations Of DJI Quadcopter UAS Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Multicopter Maui LLC will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Quadcopter UA. 

Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of DJI Quadcopter UA Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, proposes to commercially operate DJI Quadcopter UA 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 UASs weighing less than 55 pounds maximum 

gross weight: DJI Quadcopter Unmanned Aircraft. 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 UAS must be operated at an altitude of no more than 500 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.

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 UASs 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 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 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 (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 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. 

Multicopter Maui LLC 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 

Quadcopter UA unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Quadcopter UA in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Multicopter Maui LLC 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 Quadcopter UA, Multicopter Maui LLC submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Multicopter Maui LLC 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). 

Multicopter Maui LLC will not allow any PIC to operate the DJI Quadcopter UA unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Quadcopter 

UA training and currency requirements, that the PIC is able to safely operate the DJI 

Quadcopter UA 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 Multicopter Maui LLC 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, Multicopter Maui LLC will ensure safe operations by not allowing any PIC to 

operate the DJI Quadcopter UA unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Quadcopter UA 

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, Multicopter Maui LLC will ensure that the DJI Quadcopter UA 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 Quadcopter UAS will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UAS to 
the GCS for active monitoring of the flight path and altitude. This altitude information, 

combined with Multicopter Maui LLC’s operation of the DJI Quadcopter UA 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 UASs 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 Quadcopter UA; (2) 

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

operations. Accordingly, Multicopter Maui LLC will ensure that it will safely operate the 

battery powered DJI Quadcopter UA during daylight hours in VFR conditions, 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. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Quadcopter UA; 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 Quadcopter UA 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 Quadcopter UA 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, Multicopter Maui LLC 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 

Multicopter Maui LLC 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., the Multicopter Maui LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Quadcopter Instruction Manual). Furthermore, Multicopter Maui 

LLC will document and maintain all maintenance records for the DJI Quadcopter UA. 

Since the DJI Quadcopter UA will be inspected as prescribed by the operating documents, 

Multicopter Maui LLC 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 Quadcopter User Manuals are 

attached hereto as Exhibit B; a copy of the DJI Quadcopter UAS Maintenance LOG is attached 

hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Multicopter Maui LLC 

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 Quadcopter UA 

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 Multicopter Maui LLC proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Quadcopter UA, Multicopter Maui LLC 

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, Multicopter Maui LLC requests that the 

FAA prescribe special conditions for the intended operation of the DJI Quadcopter UA, 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 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 Quadcopter 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 Quadcopter 

UA, 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 Multicopter Maui LLC Seeks Exemption: 

Multicopter Maui 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 Multicopter Maui LLC Seeks: 

This exemption will permit Multicopter Maui LLC to commercially operate an Unmanned 

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

areas of the United States. 

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

Maui LLC 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, Multicopter Maui LLC 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, Multicopter Maui LLC will operate the DJI Quadcopter UASs 

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, Multicopter Maui LLC 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 Quadcopter 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 Multicopter Maui LLC to safely, efficiently, 

and economically operate the DJI Quadcopter UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Multicopter Maui LLC 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 Quadcopter UA 

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States. 

Dated: March 31, 2015 

Respectfully submitted, Dino Tassara

Dino Tassara

Multicopter Maui LLC

PO BOX 11964 Lahaina, Hawaii 96761

Tel: (808) 214-7791

Email: multicoptermaui@gmail.com