UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: RICHARD GLASS OF 

BLUE CRAB MEDIA, INC. 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 INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA

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

Submitted on November 18, 2015

Richard Glass

Blue Crab Media, INC

1226 Mt Pleasant Drive

Annapolis, MD 21409

410-320-6584

bluecrabmedia@gmail.com
TABLE OF CONTENTS

Page

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

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

INTRODUCTION AND INTERESTSOF PETITIONER................................................................... 4

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

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

NAME AND ADDRESS OF PETITIONER......................................................................................... 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BLUE CRAB MEDIA, INC.

SEEKS EXEMPTION............................................................................................................................ 7

THE EXTENT OF RELIEF BLUE CRAB MEDIA INC. SEEKS AND THE

REASON BLUE CRAB MEDIA, INC. SEEKSTHE RELIEF......................................................... 10

THE REASONS WHY GRANTING BLUE CRAB MEDIA, INC.’S REQUEST

WOULD BE IN THE PUBLIC INTEREST........................................................................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULDNOT

ADVERSELY AFFECT SAFETY.......................................................................................................15

SUMMARY THAT CAN BE PUBLISHED IN THEFEDERAL REGISTER................................. 27

ANY ADDITIONAL INFORMATION, VIEWS, ORARGUMENTS

AVAILABLE TO SUPPORT BLUE CRAB MEDIA,INC’S REQUEST .........................................28

CONCLUSION....................................................................................................................................28

APPENDICES..................................................................................................................................... 30
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal AviationAdministration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System 

LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard OperatingProcedures 

UA Unmanned Aircraft

UAS Unmanned Aircraft System 

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing
SUMMARY

Richard Glass 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 Blue Crab Media, Inc. 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 UnitedStates.

INTRODUCTION AND INTERESTS OF THEPETITIONER

Blue Crab Media, Inc. provides its clients with the highest quality digital content for use in 

their commercial, personal, and non-profit multimedia projects. Blue crab Media, Inc. has 

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

leader in providing a quality product. Blue Crab Media, Inc. has over 3 years recreational/hobby 

experience in all aspects of aerial video and photography. The objective of Blue Crab Media, Inc. 

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

• Aerial event filming

• Film production

• Aerial location scouting and safetyinspection

• Mapping 

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

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1UAV

Blue Crab Media, Inc. seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Inspire 1 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 Inspire 1 has a maximum gross weight of approximately 6 pounds 5
Ounces, while having a length of 19 inches width of 18 inches, height of 8 inches, and a 

maximum speed of approximately 42 knots. The DJI Inspire 1 UAS is equipped with four main 

rotors; Driven by Lithium Polymer battery powered electric motors.

BASIS FOR PETITION

Petitioner, Blue Crab Media, Inc., 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, Blue Crab Media, Inc.’s operation of the 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, Blue Crab Media, Inc. 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.

Blue Crab Media, Inc. submits that the requested relief is proper since an equivalent

level of safety will be ensured. Blue Crab Media, Inc. will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs using 

the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Blue Crab Media, Inc. 

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 Blue Crab Media, Inc. 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.

Blue Crab Media, Inc. 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, Blue Crab Media, Inc. submits that it

will ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight, by 

determining that the UASs 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.

Blue Crab Media, Inc. also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1 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 Blue Crab Media, Inc.’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, Blue Crab Media, Inc. seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Blue Crab Media, Inc. 

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

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

battery power to fly for a total duration of approximately 13.5 minutes to the first point of 

intended landing.

In accordance with 14 C.F.R. § 11.81, Blue Crab Media, Inc. provides the following 

information in support of its petition for exemption:

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

Richard Glass,

1226 Mt Pleasant Drive

Annapolis, md 21409

410-320-6584 

bluecrabmedia@gmail.com
A. The Specific Sections Of 14 C.F.R. From Which Blue Crab Media, Inc. Seeks Exemption.

1. Blue Crab Media, Inc. 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. Blue Crab Media, Inc. 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. Blue Crab Media, Inc. 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 theaircraft;
(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 within 100 nautical miles of the aircraft; this section, the current 

reported altimeter setting of an appropriate available station; or departure 

airport or an appropriate altimeter setting available before departure.

4. Blue Crab Media, Inc. 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. Blue Crab Media, Inc. 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 anaircraft—

(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. Blue Crab Media, Inc. 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 alterationunless--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]
7. Blue Crab Media, Inc. 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. Blue Crab Media, Inc. 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

(ii) The date of completion of the work performed;and

(iii) The signature, and certificate number of the person approving the the 

work performed; and aircraft for return to service.

(2) Records containing the followinginformation:

(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 aremaintained.

(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 toservice.

B. The Extent Of Relief Blue Crab Media, Inc. Seeks And The Reason Blue Crab Media,

Inc. Seeks The Relief.

1. Extent Of Relief Blue Crab Media, Inc. Seeks And The Reason Blue Crab Media,

Inc. 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, Blue Crab Media, Inc. 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, Blue Crab Media, Inc. 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 Inspire 1, Inc. business;

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

2. Extent Of Relief Blue Crab Media, Inc. Seeks And The Reason Blue Crab Media,

Inc. Seeks Relief From Section91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Blue Crab Media, Inc. 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 DJI Inspire 1 Specifications, Inspire 1 User Manual, Inspire 1 (i.e., the Blue Crab 

Media, Inc. Quick Start, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines and Blue 

crab Media Pre-Flight check list)

Blue Crab Media, Inc. seeks the requested relief because the DJI Inspire 1 UAS do not 

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

Inspire 1, Inc. will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its 

compliance with the operating documents (i.e., DJI Inspire 1 Specifications, Inspire 1 User 

Manual, Inspire 1 Quick Start, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines and 

Blue crab Media Pre-Flight check list) 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 Blue Crab Media, Inc. Seeks And The Reason Blue Crab Media,

Inc. Seeks Relief From Section91.121.

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

operations of the DJI Inspire 1 UAS, 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), Blue Crab Media, Inc. 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 eachflight.

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 Blue Crab Media, Inc. Seeks And The Reason Blue Crab Media,

Inc. Seeks Relief From Section91.151(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 13minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5 minutes. Inspire 1, Inc. seeks the requested relief because 

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

DJI Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight 

operations that Blue Crab Media, Inc. 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 Blue Crab Media, Inc.’s proposed operating 

limitations, ensure that Blue Crab Media, Inc. 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 13 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes.
5. Extent Of Relief Blue Crab Media, Inc. Seeks And The Reason Blue Crab Media, Inc. 

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, Blue Crab Media, Inc. requests relief from

these Sections because the DJI Inspire1 UAS does 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, Blue Crab Media, Inc. 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 Blue Crab Media, Inc. DJI Inspire 1 Specifications, Inspire 1 User Manual, 

Inspire 1 Quick Start, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines and Blue crab 

Media Pre-Flight check list). Furthermore, Blue Crab Media, Inc. will document and maintain all 

maintenance records for the DJI Inspire 1UAS.

C. The Reasons Why Granting Blue Crab Media, Inc.’s 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 Blue Crab Media, 

Inc. 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 Inspire 1 UAS will decrease congestion of the NAS, reduce 

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

Media, Inc.’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 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 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 UA 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 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 Inspire 1 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 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 UA (weighing 

approximately 6 pounds 7.5 ounces respectively, at it’s maximum gross weight with lengths of 17

inches and 17.3 inches respectively, 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 is 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 Blue Crab Media, Inc. 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 mannedaircraft.

By operating the DJI Inspire 1 UAS, companies such as Blue crab Media, Inc., 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 andabroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Blue Crab Media, Inc. 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., the Blue Crab Media, Inc. DJI Inspire 1 Specifications, Inspire 1 User 

Manual, Inspire 1 Quick Start, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines and 

Blue crab Media Pre-Flight check list)

D. 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 Blue Crab Media, Inc. Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section333.

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

the unmanned aircraft and its operation, Blue Crab Media, Inc. 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, SubpartH.

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, Blue Crab Media, Inc. 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 is set forth by the DJI Inspire 1

Specifications and Data Sheet, attached hereto as Exhibit A.
ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined OperationalArea.

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

Exhibit C.

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 UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Inspire 1 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 Inspire 1 UAS are set forth at

pages 12 through 17 of the DJI Inspire 1 User Manual, attached hereto as B.

iv. The DJI Inspire 1 GCS And ItsOperation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and

flight control software is provided at pages 14 through 16 of the DJI Inspire 1 User 

Manual. DJI Inspire 1 User Manual is attached hereto as Exhibit C.

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer.

Blue Crab Media, Inc. 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 Inspire 1 UAS. Additionally, a 

safety observer will assist all pilots during flight time.

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

Limitations.

In seeking this exemption, 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 UASs weighing less than 55 pounds
maximum gross weight: DJI Inspire 1 Unmanned Aircraft System. Proposed operations

of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video andphotography.

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 aircraftrecords.

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 aircraftrecords.

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 thirdclass medical certificate.

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

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

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 operatingdocuments.

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

accordance with the operatingdocuments.

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 alltimes.

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 structuresunless:

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 immediatelyand/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 AffectSafety.

Blue Crab Media, Inc. 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.

Blue Crab Media, Inc. 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, Blue Crab Media, Inc. submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Blue Crab Media, Inc. 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).

Blue Crab Media, Inc. 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 Blue Crab Media, Inc. proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating asfollows:

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 

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

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

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

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.
Accordingly, Blue Crab Media, Inc. 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, Blue Crab Media, Inc. 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 limitationsherein.

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 UA will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

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

Crab Media, Inc.’s operation of the DJI Inspire 1 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 Inspire 1 UAs; 

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

operations. Accordingly, Blue Crab Media, Inc. will ensure that it will safely operate the battery 

powered DJI Inspire 1 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 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, Blue Crab Media, Inc. 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 

Blue Crab Media, Inc. 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 DJI Inspire 1 Specifications, Inspire 1 User Manual, Inspire 1 (i.e., the 

Blue Crab Media, Inc. Quick Start, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines 

and Blue crab Media Pre-Flight check list) Furthermore, Blue Crab Media, Inc. 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, Blue Crab Media, Inc. 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 Exhibit B; a copy of the DJI Inspire 1 UAS Safety Manual Exhibit E.

Likewise, the exemption sought will not adversely affect safety because Blue Crab 

Media, Inc. 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 maintenancelog.

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 Blue Crab Media, Inc. proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, Blue Crab Media, Inc. 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, Blue Crab Media, Inc. 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 theNAS.

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 Blue Crab Media, Inc.’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).

E. A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which Blue Crab Media, Inc. SeeksExemption:
Blue Crab Media, Inc. 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 Blue Crab Media, Inc. Seeks: 

This exemption will permit Blue Crab Media, Inc. to commercially operate an

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

photography over certain areas of the UnitedStates.

F. Any Additional Information, Views, Or Arguments Available To Support Blue 

Crab Media Inc.’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, Blue Crab Media, Inc.’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, Blue Crab Media, Inc. will operate the DJI Inspire 1 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, Blue Crab Media, Inc. 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 Blue Crab Media, Inc. 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, Blue Crab Media, Inc. 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 Blue Crab Media, Inc. 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: November 30th, 2015

Respectfully submitted, 

Richard Glass

Richard Glass Blue 

Crab Media, Inc 

1226 Mt Pleasant Dr 

Annapolis, Md 21409

Tel: (410)-320-6584

Email: 

bluecrabmedia@gmail.com
Appendices:

A – DJI Inspire 1 Specifications DataSheet 

B – DJI Inspire 1 User Manual

C – DJI Inspire 1 Quick Start Guide

D- DJI Inspire 1 Maintenance Manual

E- DJI Inspire 1 Safety Guidelines

F- Blue Crab Media Operating Procedure & Pre Flight Checklist