September 3, 2015

Exemption No. 12753

Regulatory Docket No. FAA−2015−2541

Mr. Robert W. Biggs 

Phoenix Drone Pros

601 East Pinto Court

Gilbert, AZ 85296

Dear Mr. Biggs:

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 June 11, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial photography, videography, surveying, inspections, search and rescue 

operations, and UAS training1.

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.

 

1 The petitioner requested authority to conduct UAS training. At this time, the FAA is unable to authorize UAS 

operations for training until a further assessment is completed. When the FAA completes its review, we will 

proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted 

to train its own pilot in commands and visual observers in accordance with condition no. 14 and the other 

conditions and limitations in this exemption.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. 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 finds that the requested 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 collection2. 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, Mr. Robert W. Biggs 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 

 

2 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.
3

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, Mr. Robert W. Biggs is hereafter referred to as the operator.

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 1 when 

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 
4

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 

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.
5

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 

(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.
6

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.

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.
7

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.

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.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation

June 11, 2015

Robert W. Biggs

DBA Phoenix Drone Pros

601 E. Pinto Ct.

Gilbert, AZ 85296

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR

91.7(a); 14 CFR

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR

91.151(a); 14 CFR 91.203

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

91.417(a) and (b) 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 CFR Part 11, Robert W. Biggs, DBA “Phoenix Drone Pros,” operator of 

Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided 

such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

Thank you in advance for your consideration.

Robert W. Biggs, DBA

Phoenix Drone Pros
The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable 

than conventional aircraft running on combustible fuel, operates at lower altitudes with no people 

on board and will thereby reduce current risk levels, enhance safety and diminish the likelihood 

of death or serious bodily injury. With a small payload and maximum flight time of only 20

minutes, this offers little or no risk to national security. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and

sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television,

public events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including

but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations

to increase awareness and improve safety for current and future UAS operations within the 

NAS.

As described fully below, the requested exemption would permit the operation of designated 

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase 

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for

the safe operation of such aircraft systems in the national airspace system.” 

The name and address of the applicant is:

Robert W. Biggs, DBA Phoenix Drone Pros

Phone: (480) 330-1778

Email: PhoenixDronePros@gmail.com

Address: 601 e. Pinto Ct., Gilbert, Arizona 85296
Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)
Robert W. Biggs, DBA Phoenix Drone Pros, will operate one or more of the following

model UAS:

1. DJI T600 INSPIRE 1

The DJI T600 Inspire One manufactured by DJI innovations, is lightweight 4 electric 

motor/rotor, battery operated quadcopter with a 6.5lb gross weight that takes off and lands 

vertically. The Inspire one has a length of 17.3 inches, width of 17.7 inches, height of 11.8 

inches, and a maximum speed of approximately 42 knots. Its avionics suite contains an onboard flight computer with GPS navigation and an Inertial Measurement Unit (IMU) based 

attitude stability system. Also included is a barometric altimeter sensor, compass unit 

ultrasonic altimeter and vision positioning camera. An on-board processor receives signals for 

flight and payload control from a ground-based transmitter/controller/ground station device. 

An on-board telemetry system delivers flight data from the flight computer to the downlink 

radio transmitter to provide the Pilot in Command (PIC) with information such as altitude 

AGL, horizontal and vertical speed, compass direction of flight, bearing and distance to the 

controlling station, current waypoint, battery status, current flight mode, GPS health status, 

datalink status, and GPS position. This data is displayed to the PIC via the Ground Control 

Station (GCS) application running on one or more computer devices such as a smart phone, 

tablet or PC. 

THE GROUND CONTROL STATION/CONTROLLER: 

The DJI UAS products CCAS intends to operate under this exemption use a series of 

components to comprise the Ground Control Station (GCS). The first and primary component 

of the ground segment is a handheld pilot controller and an optional handheld payload 

controller. The pilot controller provides a user interface for flight attitude and altitude 

commands augmented by the UA’s onboard IMU and GPS aided stabilization system. The 

controller also has options for manipulating the flight mode, payload gimbal, camera functions, 

and landing gear if equipped. The Datalink segment is comprised of an uplink transmitter 

command/control link using a frequency range of 2.4GHz to 2.48GHz frequency range with a 

power output of approximately 125mW. The uplink sends flight and payload commands to the 

UA’s autopilot which then processes the commands along with sensor inputs to manipulate the 

motor speed controllers and provide the desired response. The downlink transmitter on the UA 

operates on a 5.728GHz to 5.85GHz and an output power of approximately 25mW. The 

downlink transmitter provides live video from the on-board camera plus all the UA flight data 

described above. Downlink data and video is received by the pilot controller and optional 

payload controller which is then displayed to the PIC and optional PO via an application on a 

handheld device such as a smart phone, tablet or PC. The GCS application also provides a 

heads up display of pertinent flight data and UA status reports along with a moving map 

display. Both the uplink and downlink transmitters have been tested and comply with part 15 

of the FCC rules for a class B digital device.

DOCUMENTATION

The following documents are attached and provided to support this petition. 

• DJI T600 Inspire 1 - Manual Version 1.0

• Preflight Checklist 
Given the small size of the UAS in scope and the controlled environment provided, the 

proposed operations will adhere to the Reform Act’s safety requirements. The approval of

this application presents no national security issues. Regarding the level of safety

surrounding the proposed operations and the public benefit, reduction in environmental

impacts, including but not limited to reduced emissions and noise, the grant of the

requested exemption is in the public interest. Accordingly, the applicant graciously requests

that the FAA grant the requested exemption.

OPERATIONAL PARAMETERS

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

aircraft. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the

Flight Operations Manual (FOM) include:

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with

battery and camera.

2. The UAS, depending on the model in operation, will have a maximum operating speed

of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual

Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS

model in operation, but will not exceed 30 minutes. Flights will be terminated at 25%

battery power reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level

(AGL) and not more than 200 feet above an elevated platform from which filming is

planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual

Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have

logged a minimum of 20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’

production activities.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a 5-mile radius of the

geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled

airport.

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.
13. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO)

no more than 72 hours but no less than 48 hours from planned operation.

14. The operator will obtain verbal/written consent of all persons involved with the

planned operation and ensure that only consenting persons will be allowed within 100 feet

of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent

level of safety determination, as U.S. Department of Transportation required under the

FOM. With the advanced permission of the FSDO, operations at closer range may be

approved.

15. The PIC and VO will have been trained in operation of UAS and receive up-todate information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all times.

17. Written and/or verbal permission and permits will be obtained from territorial, state,

county or city jurisdictions, including law enforcement, fire or other appropriate

governmental agencies as appropriate to flight operations.

18. If the UAS loses communications with the remote controller or loses GPS signal, the

UAS will have the capability to return to a pre-determined location within a designated

location and land autonomously.

19. The UAS will have the capability to abort a flight in case of emergencies

with an automated “Return Home and Land” function.

20. The UAS will have the capability to abort a flight in case of unpredicted

obstacles, weather, or emergencies such as low battery.
PREFLIGHT CHECKLIST

PRE-FLIGHT CHECKLIST

DJI INSPIRE 1

UAV Number: N-229DP

DEPARTURE

 Batteries fully charged

 Tablet

 Cables

 Safety Vest

 Micro SD Card - Clear

 Laptop

 GoPro

PRE-FLIGHT

 Notify owner and residents

 Check weather, wind < 15mph

 Put on safety vest, signage

 Power ON Hot Spot

 Power ON tablet, connect to Tx

 Power ON Transmitter

 Set antennae

 Power ON Drone

 Exit Travel Mode

 Power OFF Drone

 Insert micro SD card in camera

 Install correct camera lens filter

 Install Camera

 Install propellers, prop locks

 Power ON Drone

 Check flight status on tablet

 Check battery status on tablet

 Clear map

 Set camera mode - 4k or 1080, MP4

 Perform calibration

 Place drone in clear take off area

 TAKE-OFF: Hover, test controls

POST-FLIGHT

 LAND

 Remove propellers, prop locks

 Remove Camera

 Remove micro SD card

 Enter Travel Mode

 Power OFF Drone

 Power OFF Transmitter

 Reset antennae

 Power OFF tablet

 Power OFF HotSpot

 Remove safety vest, signage
SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN 

EXEMPTION 

A. 14 C.F.R. §§ 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command. 

These regulations limit private pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers and be operated within limited areas and altitudes, the proposed 

operations can achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to 

operate this small UAS. 

B. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness 

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 21, 

Subpart H, the airworthy condition of the UAS will be the responsibility of the PIC in accordance 

with 14 C.F.R. § 91.7(b). 

C. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas 

This regulation establishes safe altitudes for operation of civil aircraft over areas other than 

congested areas. PDP requests relief from this section with respect to persons involved in the 

operation as well as vehicles and structures. The UAS will not be operated above 400 feet altitude. 

It will be operated in a defined area where people and buildings will not be exposed to operations 

without their pre-obtained consent. 

D. 14 C.F.R. § 91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference 

to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter 

setting available before departure.” As the UAS does not have a barometric altimeter, an exemption 

is requested. The UAS Flight Controller utilizes GPS equipment aided by a static pressure sensor to 

determine and maintain altitude. The aircraft altitude above the takeoff point is provided in the 

video downlink telemetry information and provides sufficient information for the PIC to maintain 

altitudes at or below the 400 foot (122 meter) limitations. April 6, 2015 Page 6 

E. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions 

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane 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 cursing speed – (1) During the day to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 

Given that the UAS aircraft only fly for a maximum of 30 minutes and typically carry about 15 

minutes of batter power, an exemption is requested. The UAS operations are always conducted 

within a few minutes of the takeoff and landing point and within a restricted area. BEAP believes 

that terminating the flight with 25% remaining battery power provides an equivalent amount of 

safety that is intended by section 191.151(a). 

F. 14 C.F.R. § 91.405(a) Maintenance Required; 14 C.F.R. § 91.407(a)(1) Operation after 

maintenance, preventative maintenance, rebuilding or alteration; 14 C.F.R. §§ 91.409(a)(1) and (2) 

Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance Records 
These regulations require that an aircraft operator or owner “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...,” 

and others shall inspect or maintain the aircraft in compliance with part 43. 

Given that the sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the Petitioner. Maintenance will be accomplished by the operator 

pursuant to the Owner’s Manuals. An equivalent level of safety will be achieved because these 

small UAS are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in 

working order prior to initial flight, perform required maintenance and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. The FAA issued exemption to these regulations in Exemption No. 11062.

Additional Information.

The applicant, Robert W. Biggs, believes this exemption request and associated safety

considerations adequately satisfy criteria provided in Section 333 of the Reform Act of

2012, providing sufficient justification for the granting of commercial operations

of the applicant’s UAS.

The applicant, Robert W. Biggs, requests your respective approval of this Section 333

exemption petition request.

Thank you for your interest and attention in this matter. Please notify Robert W. Biggs of

your actions, and or approvals. Thank You for your interest in this request. Sincerely,

Robert W. Biggs

DBA Phoenix Drone Pros

PhoenixDronePros@gmail.com

601 E. Pinto Ct.

Gilbert, Arizona 85296