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UNITED	STATES	OF	AMERICA

DEPARTMENT	OF	TRANSPORTATION

FEDERAL	AVIATION	ADMINISTRATION

WASHINGTON,	DC

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:

AEROSPECTIVE	IMAGING,	LLC

FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF

TITLE	14	OF	THE	CODE OF	FEDERAL	REGULATIONS

SECTIONS	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	AND	

91.417(a)	&	

(b)	CONCERNING	COMMERCIAL	OPERATION	OF	DJI	PHANTOM	3,	DJI	INSPIRE 1,	AND	DJI	SPREADING	WINGS	

S1000+	UNMANNED	AIRCRAFT	SYSTEMS

PURSUANT	TO	SECTION	333	OF

THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012

(PUBLIC	LAW	112-95)

Submitted	on	November	9,	2015

Aerospective	Imaging,	LLC

Attn.	Theodore	Bradford	Dickerson

3923	Reflection	Drive

Anchorage,	AK	99504

828-545-6906

aerospectiveimaging@gmail.com
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TABLE	OF	CONTENTS

GLOSSARY	OF	ABBREVIATIONS...............................................................................................................................................................5

SUMMARY........................................................................................................................................................................................................6

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER.................................................................................................................6

BACKGROUND................................................................................................................................................................................................6

BASIS	FOR	PETITION...................................................................................................................................................................................6

A.	Name	And	Address	Of	The	Petitioner ..............................................................................................................................................8

B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Aerospective	Imaging,	LLC	Seeks	Exemption....................................8

1.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	

(b) ............................................................................................................................................................................................8

2.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirements	Of	Section	91.7(a) ...............8

3.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirements	Of	Section	91.121................8

4.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirements	Of	Section	91.151(b)..........9

5.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirement	Of	Section	91.405(a) ............9

7.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirements	Of	Sections	91.409(a)(1)	

And	91.409(a)(2) ...............................................................................................................................................................9

8.	Aerospective	Imaging,	LLC	Seeks	Exemption	From	The	Requirements	Of	Sections	91.417(a)	And	

91.417(b) ............................................................................................................................................................................10

C.	The	Extent	Of	Relief	Aerospective	Imaging,	LLC	Seeks	And	The	Reason	Aerospective	Imaging,	LLC	Seeks	The	

Relief ..............................................................................................................................................................................................................11

1.	Extent	Of	Relief	Aerospective	Imaging,	LLC	Seeks	And	The	Reason	Aerospective	Imaging,	LLC	

Seeks	Relief	From	Section	61.113(a)	And	(b)........................................................................................................11

2.	Extent	Of	Relief	Aerospective	Imaging,	LLC	Seeks	And	The	Reason	Aerospective	Imaging,	LLC	

Seeks	Relief	From	Section	91.7(a) .............................................................................................................................11

3.	Extent	Of	Relief	Aerospective	Imaging,	LLC	Seeks	And	The	Reason	Aerospective	Imaging,	LLC	

Seeks	Relief	From	Section	91.121..............................................................................................................................12

4.	Extent	Of	Relief	Aerospective	Imaging,	LLC	Seeks	And	The	Reason	Aerospective	Imaging,	LLC	

Seeks	Relief	From	Section	91.151(b)........................................................................................................................12
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5.	Extent	Of	Relief	Aerospective	Imaging,	LLC	Seeks	And	The	Reason	Aerospective	Imaging,	LLC	

Seeks	Relief	From	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b)...12

D.	The	Reasons	Why	Granting	Aerospective	Imaging,	LLC	Request	Would	Be	In	The	Public	Interest;	That	Is,	How	

It	Would	Benefit	The	Public	As	A	Whole...........................................................................................................................................13

1.	The	Public	Will	Benefit	From	Decreased	Congestion	Of	The	NAS..............................................................13

2.	The	Public	Will	Benefit	From	The	Safety	And	Efficiency	Of	The	DJI	Phantom	3,	Inspire	1,	and	

Spreading	Wings	S1000+	UASs ...................................................................................................................................13

3.	Performing	Aerial	Video	and	Photography	Operations	With	The	DJI	Phantom	3,	Inspire	1,	and	

Spreading	Wings	S1000+	UASs	Will	Benefit	The	Economy...............................................................................14

4.	There	Are	No	Privacy	Issues....................................................................................................................................14

E.	The	Reasons	Why	Granting	The	Exemption	Would	Not	Adversely	Affect	Safety,	Or	How	The	Exemption	Would	

Provide	A	Level	Of	Safety	At	Least	Equal	To	That	Provided	By	The	Rule	From	Which	Aerospective	Imaging,	LLC	

Seeks	Exemption........................................................................................................................................................................................14

1.	Reasons	Why	The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UAs	Meet	The	

Conditions	Of	The	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333............................15

2.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	(b)	Would	Not	

Adversely	Affect	Safety ..................................................................................................................................................19

3.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.7(a)	Would	Not	Adversely	

Affect	Safety .......................................................................................................................................................................20

4.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.121	Would	Not	Adversely	

Affect	Safety .......................................................................................................................................................................20

5.	Reasons	Why	An	Exemption	From	The	Requirements Of	Section	91.151(b)	Would	Not	Adversely	

Affect	Safety .......................................................................................................................................................................21

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......................................21

7.	The	FAA	May	Prescribe	Any	Other	Conditions	For	Safe	Operation...........................................................22

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

Imaging,	LLC	Seeks	Exemption.............................................................................................................................................................23

A	Brief	Description	Of	The	Nature	Of	The	Exemption	Aerospective	Imaging,	LLC	Seeks:.....................23
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G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support	Aerospective	Imaging,	LLC’s	Request

..........................................................................................................................................................................................................................23

CONCLUSION................................................................................................................................................................................................24
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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	Aviation	Administration

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	Operating	Procedures

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
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SUMMARY

Aerospective	Imaging,	LLC	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	

Aerospective	Imaging,	LLC	to	operate	an	Unmanned	Aircraft	System	(UAS)	for	the	commercial	purpose	of	conducting	

aerial	imaging,	video,	and	photography	over	certain	areas	of	the	United	States.

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

Aerospective	Imaging,	LLC	primarily	provides	clients	with	photography	and	video	services	of	properties	and	buildings	

for	the	purpose	of	advertising	and	promotion.	The	objective	of	Aerospective	Imaging,	LLC	and	its	aerial	operations	is	to	

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

- Construction

- Real-estate	marketing

- Data	Gathering	and	Surveying

BACKGROUND

Unmanned	Aircraft	Systems:	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UASs

Aerospective Imaging,	LLC	seeks	an	exemption	to	operate	DJI	systems	for	compensation	or	hire	within	the	NAS.	The	DJI	

Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	are	vertical	takeoff	and	landing	(VTOL)	Unmanned	Aircraft	(UA)	

with	a	Ground	Control	Station	(GCS)	utilizing	electronic	tablet	or	smart	phone	systems.

The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	have a	maximum	gross	weight including	imaging	equipment	

of	24.25	lbs,	maximum	diameter	of	41.14”,	and	maximum	speed	of	approximately	40mph.		

BASIS	FOR	PETITION

Petitioner,	Aerospective	Imaging,	LLC	pursuant	to	the	provisions	of	the	Federal	Aviation	Regulations	(14	C.F.R.	§	11.61)	

and	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	Section	333,	Special	Rules	for	Certain	Unmanned	Aircraft	

Systems,	hereby	petitions	the	Administrator	to	commercially	operate	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+ UASs	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,	Aerospective	Imaging,	LLC	operation of	a	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ 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.
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Accordingly,	Aerospective Imaging,	LLC	requests	relief	from	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	

and	91.417(a)	&	(b),	as	these	sections	set	forth	requirements	for	maintenance	that	only	apply	to	aircraft	with	an	

airworthiness	certificate.

Aerospective	Imaging,	LLC	submits	that	the	requested	relief	is	proper	since	an	equivalent	level	of	safety	will	be	ensured.	

Aerospective	Imaging,	LLC	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	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ Instruction	

Manual).	Furthermore,	Aerospective	Imaging,	LLC	will	document	and	maintain	all	maintenance	records	for	the	DJI	

Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs.

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

command,	is	requested	by	Aerospective	Imaging,	LLC	to	the	extent	necessary	to	allow	a	Pilot	in	Command	(PIC)	holding	

a	sport 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	Phantom	3,	Inspire	1,	and	

Spreading	Wings	S1000+ UASs	in	a	manner	consistent	with	this	exemption,	including	evasive	and	emergency	

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

Aerospective	Imaging,	LLC	seeks	relief	from	Section	91.7(a),	entitled	Civil	aircraft	airworthiness,	because	the	DJI	

Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	do	not	require	an	airworthiness	certificate	in	accordance	with	

14	C.F.R.	Part	21,	Subpart	H.	As	such,	Aerospective	Imaging,	LLC	submits	that	it will	ensure	that	the	DJI Phantom	3,	

Inspire	1,	and	Spreading	Wings	S1000+	UASs	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	Instruction	Manuals),	

and	that	the	aircraft	are	in a	condition	for	safe	flight.		Aerospective	Imaging,	LLC will	utilize	the	preflight	instructions	

provided	by	DJI	to	ensure	airworthiness	checks	prior	to	each	flight.

Aerospective	Imaging,	LLC	also	seeks	an	exemption	from	the	requirements	of	Section	91.121,	entitled	Altimeter	Settings,	

as	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UAs	will	not	have	a	typical	barometric	altimeter	onboard.	

However,	altitude	information	of	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UAs	will	be	provided	to	the	

PIC	via	Global	Positioning	System	(GPS)	equipment	and	radio	communications	telemetry	data	link,	which	downlinks	

from	the	UA	to	the	GCS	for	active	monitoring	of	the	flight	path.	This	altitude	information,	combined	with	Aerospective	

Imaging,	LLC’s	operation	of	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UAs	within	visual	line	of	sight,	at	

or	below	500	feet	AGL,	will	ensure	a	level	of	safety equivalent	to	Section	91.121.

Additionally,	Aerospective	Imaging,	LLC	seeks	an	exemption	from	the	requirements	of	Section	91.151(b),	entitled	Fuel	

requirements	for	flight	in	VFR	conditions.	Aerospective	Imaging,	LLC	submits	that	safety	will	not	be	affected	by	operation	

of	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UAs	during	daylight	hours	in	visual	meteorological	

conditions	(VMC)	under	visual	flight	rules	(VFR),	with	enough	battery	power	to	fly	for	a	total	duration	of	approximately	

18.5	minutes	to	the	first	point	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	

minutes.

In	accordance	with	14	C.F.R.	§	11.81,	Aerospective	Imaging,	LLC	provides	the	following	information	in	support	of	its	

petition	for	exemption:
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A.	NAME	AND	ADDRESS	OF	THE PETITIONER

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

Aerospective	Imaging,	LLC

ATTN:	Theodore	Dickerson

3923	Reflection	Dr

Anchorage,	AK	99504

828-545-6906

aerospectiveimaging@gmail.com

B.	THE	SPECIFIC	SECTIONS	OF	14	C.F.R.	FROM	WHICH	AEROSPECTIVE	IMAGING,	LLC	

SEEKS	EXEMPTION

1.	AEROSPECTIVE	IMAGING,	LLC	SEEKS	EXEMPTION	FROM	THE	REQUIREMENTS	OF	SECTION	

61.113(A)	AND	(B)

Section	61.113,	entitled	Private	pilot	privileges	and	limitations:	Pilot	in	command,	subsections	(a)	and	(b)	

prescribe	the	following,	in	relevant	part:

(a) No	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	(PIC)	of	an	aircraft	

that	is	carrying	passengers	or	property	for	compensation	or	hire;	nor	may	that	person,	for	

compensation	or	hire,	act	as	PIC	of	an	aircraft.

(b) A	private	pilot	may,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft	in	connection	with	any	

business	or	employment	if—

(i) The	flight	is	only	incidental	to	that	business	or	employment;	and

(ii) The	aircraft	does	not	carry	passengers	or	property	for	compensation	or	hire.

2.	AEROSPECTIVE	IMAGING,	LLC	SEEKS	EXEMPTION	FROM	THE	REQUIREMENTS	OF	SECTION	

91.7(A)

Section	91.7,	entitled	Civil	aircraft	airworthiness,	subsection	(a),	states	the	following:

(a) No person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	condition.

3.	AEROSPECTIVE	IMAGING,	LLC	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--

(i) Below	18,000	feet	MSL,	to--
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(1) The	current	reported	altimeter	setting	of	a	station	along	the	route	and	within	100	nautical	

miles	of	the	aircraft;

(2) 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

(3) In	the	case	of	an aircraft	not	equipped	with	a	radio,	the	elevation	of	the	departure	airport	

or	an	appropriate	altimeter	setting	available	before	departure.

4.	AEROSPECTIVE	IMAGING,	LLC	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.	AEROSPECTIVE	IMAGING,	LLC	SEEKS	EXEMPTION	FROM	THE	REQUIREMENT	OF	SECTION	

91.405(A)

Section	91.405,	entitled	Maintenance	required,	subsection	(a),	states	the	following:	Each	owner	or	operator	of	

an	aircraft—

(a) Shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	

required	inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	

repaired	as	prescribed	in	part	43	of	this	chapter[.]

6.	AEROSPECTIVE	IMAGING,	LLC	SEEKS	EXEMPTION	FROM	THE	REQUIREMENTS	OF	SECTION	

91.407(A)(1)

Section	91.407,	entitled	Operation	after	maintenance,	preventive	maintenance,	rebuilding,	or	alteration,	

subsection	(a)(1),	states	the	following:

(a) No	person	may	operate	any	aircraft	that	has	undergone	maintenance,	preventive	maintenance,	

rebuilding,	or	alteration	unless--

(i) It	has	been	approved	for	return	to	service	by	a	person	authorized	under	§	43.7	of	this	

chapter[.]

7.	AEROSPECTIVE	IMAGING,	LLC	SEEKS	EXEMPTION	FROM	THE	REQUIREMENTS	OF	SECTIONS	

91.409(A)(1)	AND	91.409(A)(2)

Section	91.409,	entitled	Inspections,	subsection	(a),	states	the	following:

(a) Except	as	provided	in	paragraph	(c)	of	this	section,	no	person	may	operate	an	aircraft	unless,	

within	the	preceding	12	calendar	months, it	has	had	--
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(i) 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

(ii) An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	part	21	of	

this	chapter.

8.	AEROSPECTIVE	IMAGING,	LLC	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:

(i) 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--

(1) A	description	(or	reference	to	data	acceptable	to	the	Administrator)	of	the	work	

performed;	and

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

(3) The	signature,	and	certificate	number	of	the	person	approving	the	aircraft	for	return	to	

service.

(ii) Records	containing	the	following	information:

(1) The	total	time	in	service	of	the	airframe,	each	engine,	each	propeller,	and	each	rotor.

(2) The	current	status	of	life-limited	parts	of	each	airframe,	engine,	propeller,	rotor,	and	

appliance.

(3) The	time	since	last	overhaul	of	all	items	installed	on	the	aircraft	which	are	required	to	be	

overhauled	on	a	specified	time	basis.

(4) The	current	inspection	status	of	the	aircraft,	including	the	time	since	the	last	inspection	

required	by	the	inspection	program	under	which	the	aircraft	and	its	appliances	are	

maintained.

(5) 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.

(6) 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:

(i) 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.

(ii) 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.

(iii) A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§	43.11	of	this	chapter	shall	

be	retained	until	the	defects	are	repaired	and	the	aircraft	is approved	for	return	to	service
11

C.	THE	EXTENT	OF	RELIEF AEROSPECTIVE	IMAGING,	LLC	SEEKS	AND	THE	REASON	

AEROSPECTIVE	IMAGING,	LLC	SEEKS	THE	RELIEF

1.	EXTENT	OF	RELIEF	AEROSPECTIVE	IMAGING,	LLC	SEEKS	AND	THE	REASON	AEROSPECTIVE	

IMAGING,	LLC	SEEKS	RELIEF	FROM	SECTION	61.113(A)	AND	(B)

Relief	from	Section	61.113(a)	and	(b)	entitled	Private	pilot	privileges	and	limitations:	Pilot	in	command,	is	requested	to	

the	extent	necessary	to	allow	a	PIC	holding	a	sport 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,	Aerospective	Imaging,	LLC	submits	that	an	equivalent	level	of	safety	will	be	maintained	

because	no	PIC	will	be	allowed	to	operate	the	DJI	Phantom	3,	Inspire	1,	or	Spreading	Wings	S1000+ UASs unless	that	

PIC	has	met	certain	flight-hour	and	currency	requirements,	demonstrating	that	the	PIC	is	able	to	safely	operate the	DJI	

UASs 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,	Aerospective	Imaging,	LLC	submits	that	all	flights	of	the		DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+ UASs,	conducted	by	the	PIC	pursuant	to	the	grant	of	this	Petition:	(1)	will	be	incidental	to	Aerospective	Imaging,	

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

2.	EXTENT	OF	RELIEF	AEROSPECTIVE	IMAGING,	LLC	SEEKS	AND	THE	REASON	AEROSPECTIVE	

IMAGING,	LLC	SEEKS	RELIEF	FROM	SECTION	91.7(A)

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

Imaging,	LLC	to	determine	that	the		DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	are	in	airworthy	

condition	prior	to	every	flight	by	ensuring	that	the	UAS	is	in	compliance	with	the	operating	documents	(i.e.,	the	

Aerospective	Imaging,	LLC	Aerial	Operations	Manual,	Monthly	Maintenance	Log	and	DJI	Instruction	Manuals).

Aerospective Imaging,	LLC	seeks	the	requested	relief	because	the	DJI Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+ UASs	do	not	require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	Therefore,	

Aerospective	Imaging,	LLC	will	ensure	that	the		DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	are	in	

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

Instruction	Manuals)	prior	to	every	flight,	and	further,	determine	that	the	aircraft	are	in	condition	for	safe	flight,	as	

stated	in	the	conditions	and	limitations	below.
12

3.	EXTENT	OF	RELIEF	AEROSPECTIVE	IMAGING,	LLC	SEEKS	AND	THE	REASON	AEROSPECTIVE	

IMAGING,	LLC	SEEKS	RELIEF	FROM	SECTION	91.121

Relief	from	Section	91.121,	entitled	Altimeter	settings,	may	be	required	to	allow	flight	operations	of	the	DJI	Phantom	3,	

Inspire	1,	and	Spreading	Wings	S1000+ UASs,	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),	Aerospective	Imaging,	LLC	seeks	the	requested	relief	because	the	DJI	

Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UA’s	altimeter	may	be	set	on	the	ground	to	zero	feet	AGL,	rather	

than	the	local	barometric	pressure	or	field	altitude,	before	each	flight.

Considering	the	limited	altitude	of	the	proposed	operations,	relief	from	14	CFR	91.121	is	sought	to	the	extent	necessary	

to	comply	with	the	applicable	conditions	and	limitations	stated	below.	As	more	fully	set	forth	herein,	an	equivalent	level	

of	safety	will	be	maintained	since	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ 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	AEROSPECTIVE	IMAGING,	LLC	SEEKS	AND	THE	REASON	AEROSPECTIVE	

IMAGING,	LLC	SEEKS	RELIEF	FROM	SECTION	91.151(B)

Relief	from	Section	91.151(b)	entitled	Fuel	requirements	for	flight	in	VFR	conditions,	is	requested	to	the	extent	required	

to	allow	flights	of	the	battery	powered	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UAs	during	daylight	

hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight	rules (VFR),	for	a	total	duration	of	18.5	minutes	to	

the	first	point	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	minutes.	

Aerospective	Imaging,	LLC	seeks	the	requested	relief	because	without	an	exemption	from	Section	91.151(b),	the	flight	

time	duration	of	the	battery	powered		DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UAs	will	severely	

constrain	the	practicality	of	any	aerial	imaging,	video, or	still	photo	flight	operations	that	Aerospective	Imaging,	LLC	

proposes	to	conduct	pursuant	to	this	Petition.

Significantly,	as	set	forth	below,	the	technical	specifications	of	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+	UASs,	the	DJI	operating	documents,	and	Aerospective	Imaging,	LLC’s	proposed	operating	limitations,	ensure	

that	Aerospective	Imaging,	LLC	will	safely	operate	the	battery	powered	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+ 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	18.5	minutes	to	the	first	point	of	intended	landing	and,	assuming	

normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	minutes.

5.	EXTENT	OF	RELIEF	AEROSPECTIVE	IMAGING,	LLC	SEEKS	AND	THE	REASON	AEROSPECTIVE	

IMAGING,	LLC	SEEKS	RELIEF	FROM	SECTIONS	91.405(A),	91.407(A)(1),	91.409(A)(1)	&	

(A)(2),	AND	91.417(A)	&	(B)

Since	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	only	apply	to	aircraft	with	an	

airworthiness	certificate,	Aerospective	Imaging,	LLC	requests	relief	from	these	Sections	because	the		DJI	Phantom	3,	

Inspire	1,	and	Spreading	Wings	S10000+ UASs	do	not	require	airworthiness	certificates.	As	set	forth	more	fully	below,	
13

the	DJI	Phantom	3,	Inspire	1,	Spreading	Wings	S10000+ UASs	meet	the	conditions	of	FMRA	Section	333	for	operation	

without	an	airworthiness	certificate.	Accordingly,	Aerospective	Imaging,	LLC	will	use	trained	technicians	to	perform	

maintenance,	alterations,	or	preventive	maintenance	on	the	UASs	using	the	methods,	techniques,	and	practices	

prescribed	in	the	UAS	operating	documents	(i.e.,	the	Aerospective	Imaging,	LLC	Aerial	Operations	Manual,	Monthly	

Maintenance	Log	and	DJI	Instruction	Manuals).	Furthermore,	Aerospective	Imaging,	LLC will	document	and	maintain	all	

maintenance	records	for	the		DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs.

D.	THE	REASONS	WHY	GRANTING	AEROSPECTIVE	IMAGING,	LLC	REQUEST	WOULD	BE	IN	

THE	PUBLIC	INTEREST; THAT	IS,	HOW	IT	WOULD	BENEFIT	THE	PUBLIC AS	A	WHOLE

Granting	the	present	Petition	will	further	the	public	interest	by	allowing	Aerospective	Imaging,	LLC	to	safely,	efficiently,	

and	economically	perform	aerial imaging, video, and	photography	over	certain	areas	of	the	United	States.

Additionally,	use	of	the	DJI Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	will	decrease	congestion	of	the	

NAS,	reduce	pollution,	and	provide	significant	benefits	to	the	economy.	Notably,	the	benefits	of	Aerospective	Imaging,	

LLC’s	proposed	operation	of	the		DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	will	be	realized	without	

implicating	any	privacy	issues.

1.	THE	PUBLIC	WILL	BENEFIT	FROM	DECREASED	CONGESTION	OF	THE	NAS

The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UAs	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	these DJI	UASs 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	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UAs	do	not	

require	an	airport	to	takeoff	or	land.	Likewise,	a	reduction	of	manned	aircraft	conducting	aerial	imaging,	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	PHANTOM 3,	

INSPIRE	1,	AND	SPREADING	WINGS	S1000+ UASS

Conducting	aerial	acquisitions	with	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs,	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	UASs	

produce	no	air	pollution,	and	are the	most	viable	environmentally	conscious	alternative	to	the	cabin	class,	six	cylinder	

internal	combustion	engine	aircraft	that	are	typically	utilized	for	aerial	imaging,	video, and	photography,	while	burning	

approximately	20-30	gallons	per	hour	of	leaded	aviation	fuel.	The	DJI	Phantom 3,	Inspire	1,	and	Spreading	Wings	

S1000+ UAs,	while	reducing	the	carbon	footprint	of	aerial	acquisitions,	also	eliminates	noise	pollution,	as	the	UAs	are	

propelled	by	battery	powered	electric	motors,	rather	than	an	internal	combustion	engine.
14

By	using	the DJI	Phantom	3,	Inspire1,	and	Spreading	Wings	S1000+ UASs	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	UAs	(weighing	a	maximum	of	24.25lbs,	diameter a	maximum	of	41.14”,	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	PHANTOM	3,	

INSPIRE	1,	AND	SPREADING	WINGS	S1000+ UASS	WILL	BENEFIT	THE	ECONOMY

In	addition	to	being	safe	and	efficient,	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	are	also	an	

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

will	allow	United	States	based	companies,	like	Aerospective	Imaging,	LLC,	to	remain	competitive	and	contribute	to	

growth	of	the	U.S.	economy.	Specifically,	with	the	rising	cost	of	aviation	fuel	and	the	Environmental	Protection	Agency	

(“EPA”)	regulatory	actions	phasing	out	leaded	aviation	fuels,	U.S.	owned	and	operated	companies	must	adopt	new	and	

alternative	technology	in	order	to	remain	competitive.	Operating	the	battery	powered	DJI	UASs	is	one	such	technology	

that	not	only	allows	companies	greater	operational	flexibility	compared	to	manned	aircraft,	but	provides	such	flexibility	

without	the	high	operational	cost	of	a	traditional	manned	aircraft.

By	operating	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs,	companies	such	as	Aerospective	

Imaging,	LLC,	can	remain	competitive	and	profitable,	and	therefore,	provide	greater	job	stability	to	employees	and	

contractors,	which	will	ultimately	contribute	to	growth	of	the	U.S.	economy.	Improved	financial	performance	of	U.S.	

companies,	through	commercial	use	of	the	DJI	UASs,	provides	a	stable	workforce	that	increases	consumer	spending;	

improves	local,	state,	and	federal	tax	revenues;	and	allows	companies	to	invest	in	research	and	development	in	order	to	

remain	competitive	both	in	the	United	States	and	abroad.

4.	THERE	ARE	NO	PRIVACY	ISSUES

Similar	to	the	manned	aerial	acquisition	flight	operations	that	have	been	conducted	for	many	years,	Aerospective	

Imaging,	LLC’s	proposed	operation	of	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	will	not	

implicate	any	privacy	issues.	Specifically,	the	DJI UASs	will	be	operated	only	in	compliance	with	operating	documents	

(i.e.,	the	Aerospective	Imaging,	LLC	Aerial	Operations	Manual,	Monthly	Maintenance	Log	and	DJI	Instruction	Manuals)	

which	requires	property	owner	involvement	and	permission	to	videotape/photograph	as	well	as	local	law	enforcement	

notification,	and	in	accordance	with	the	Federal	Aviation	Regulations,	including	the	minimum	altitude	requirements	of	

14	C.F.R.	§	91.119.

E.	THE	REASONS	WHY	GRANTING	THE	EXEMPTION	WOULD	NOT	ADVERSELY	AFFECT	

SAFETY,	OR	HOW	THE	EXEMPTION	WOULD	PROVIDE	A	LEVEL	OF	SAFETY AT	LEAST	

EQUAL	TO	THAT	PROVIDED	BY	THE	RULE	FROM	WHICH	AEROSPECTIVE	IMAGING,	LLC	

SEEKS	EXEMPTION
15

1.	REASONS	WHY	THE	DJI	PHANTOM	3,	INSPIRE	1,	AND	SPREADING	WINGS	S1000+ UAS	MEET	

THE	CONDITIONS	OF	THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012	(FMRA)	SECTION	

333

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

operation,	Aerospective	Imaging,	LLC’s	operation	of	the	DJI	UASs	meets the	conditions	of	FMRA	Section	333,	and	will	

not	require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.

Section	333	provides	authority	for	a	UAS	to	operate	without	airworthiness	certification	and	sets	forth	requirements	for	

considering	whether	a	UAS	will	create	a	hazard	to	users	of	the	NAS	or the	public,	or	otherwise	pose	a	threat	to	national	

security.	Specifically,	FMRA	Section	333	states	the	following,	in	part:

a) In	General.--Notwithstanding	any	other	requirement	of	this	subtitle,	and	not	later	than	180	days	after	the	date	of	

enactment	of	this Act,	the	Secretary	of	Transportation	shall	determine	if	certain	unmanned	aircraft	systems	may	

operate	safely	in	the	national	airspace	system	before	completion	of	the	plan	and	rulemaking	required	by	section	

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

b) Assessment	of	Unmanned	Aircraft	Systems.--In	making	the	determination	under	subsection	(a),	the	Secretary	shall	

determine,	at	a	minimum—

1. which	types	of	unmanned	aircraft	systems,	if	any,	as	a	result	of	their	size,	weight,	speed,	operational	

capability,	proximity	to	airports	and	populated	areas,	and	operation	within	visual	line	of	sight	do	not	create	a	

hazard	to	users	of	the	national	airspace	system	or	the	public	or	pose	a	threat	to	national	security;	and

2. whether	a	certificate	of	waiver,	certificate	of	authorization,	or	airworthiness	certification	under	section	44704	

of	title	49,	United	States	Code,	is	required	for	the	operation	of	unmanned	aircraft	systems	identified	under	

paragraph	(1).

c) Requirements	for	Safe	Operation.--If	the	Secretary	determines	under	this	section	that	certain	unmanned	aircraft	

systems	may	operate	safely	in	the	national	airspace	system,	the	Secretary	shall	establish	requirements	for	the	safe	

operation	of	such	aircraft	systems	in	the	national	airspace	system.

In	seeking	this	exemption,	Aerospective	Imaging,	LLC	submits	that	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+ UASs	can	operate	safely	in	the	NAS	pursuant	to	FMRA	Section	333,	as	demonstrated	by:	(a) the	characteristics	

of	the	DJI UASs; (b) the	pilot	certification	requirement;	and	(c)	the	specific	operating	limitations.

a) The	Specifications	Of	The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	Demonstrate	Its	

Safe	Characteristics.

 The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	do	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	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs.

 The	technical	specifications	of	the	DJI Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UASs	are	

set	forth	by	the	DJI User	Manuals.

ii. The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	Autonomous	Flight	And	Navigation	

Modes	Enable	The UASs	To	Remain	Within	A	Defined	Operational	Area.

 The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	may	be	operated	in	both	manual	

and	fully	autonomous	flight	modes.	A	complete	description	of	the	flight	and	navigational	modes	of	

the	DJI	UASs	is	provided	in	the DJI	User	Manuals.
16

iii. The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	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	UAs	will	remain	stationary,	in	flight,	for	3	seconds	or	more.	If,	

after	3	seconds,	the	DJI	UAs	do	not	reacquire	control	link	data	from	the	GCS,	the	UAs	will	assume	

that	the	Control	Link	is	lost	and	the	UAs	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	UASs	is provided	in	the	DJI User	

Manuals.

iv. The	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ GCS	And	Its	Operation.

 A	complete	description	of	the	operation	and	specifications	of	the	DJI	UASs	GCS	and	flight	control	

software	is	provided	in	the DJI	User	Manuals.

b) Flight	Operations	Of	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	Are	Limited	To	The	

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

Aerospective	Imaging,	LLC	works	with	several	pilot	contractors	to	act	as	a	pilot	in	command	(PIC)	of	the	DJI UASs.	

Additionally,	a	safety	observer	will	assist in	flights.

c) Flights	Of	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	Will	Be	Conducted	Pursuant	To	

Specific	Operating	Limitations.

In	seeking	this	exemption,	Aerospective	Imaging,	LLC	proposes	to	commercially	operate	DJI	Inspire	and	Phantom	3	

UASs	for	the	special	purpose	of	conducting	aerial	imaging,	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	Phantom	3,	

Inspire	1,	and	Spreading	Wings	S1000+ Unmanned	Aircraft	Systems.	Proposed	operations	of	any	other	aircraft	

will	require	a	new	petition	or	a	petition	to	amend	this	grant.

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

imaging, video, and	photography.

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

4. The	UA	must	be	operated	at	an	altitude	of	no	more	than	500	feet	above	ground	level	(AGL),	as	indicated	by	the	

procedures	specified	in	the	operating	documents	unless	a	special	request	is	made	and	approved	by	ATC.	All	

altitudes	reported	to	ATC	must	be	in	feet	AGL.

5. The	UAs	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all	times.	This	requires	the	PIC	to	be	

able	to	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAAissued	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.
17

8. The	SO	must	not	perform	any	other	duties	beyond	assisting	the	PIC	with	seeing	and	avoiding	other	air	traffic	

and	other	ground	based	obstacles/	obstructions	and	is	not	permitted	to	operate	the	camera	or	other	

instruments.

9. The	operating	documents	and	the	grant	of	exemption	must	be	accessible	during	UAS	operations	and	made	

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

contained	in	the	grant	of	exemption	and	the	procedures	outlined	in	the	operating	documents,	the	conditions	

and	limitations	contained	in	the	grant	of	exemption	take	precedence	and	must	be	followed.	Otherwise,	the	

operator	must	follow	the	procedures	as	outlined	in	its	operating	documents.	The	operator	may	update	or	

revise	its	operating	documents.	It	is	the	operator’s	responsibility	to	track	such	revisions	and	present	updated	

and	revised	documents	to	the	Administrator	upon	request.	The	operator	must	also	present	updated	and	

revised	documents	if	it	petitions	for	extension	or	amendment	to	the	grant	of	exemption.	If	the	operator	

determines	that	any	update	or	revision	would	affect	the	basis	upon	which	the	FAA	granted	the	exemption,	then	

the	operator	must	petition	for	amendment	to	its	grant	of	exemption.	The	FAA’s	UAS	Integration	Office	(AFS-80)	

may	be	contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents.

10. Prior	to	each	flight	the	PIC	must	inspect	the	UAS	to	ensure	that	it	is	in	a	condition	for	safe	flight.	If	the	

inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the	aircraft	is	prohibited	from	

operating	until	the	necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a	condition	for	

safe	flight.	The	Ground	Control	Station	must	be	included	in	the	preflight	inspection.	All	maintenance	and	

alterations	must	be	properly	documented	in	the	aircraft	records.

11. Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	operation	or flight	characteristics,	

e.g.	replacement	of	a	flight	critical	component,	must	undergo	a	functional	test	flight.	The	PIC	who	conducts	the	

functional	test	flight	must	make	an	entry	in	the	aircraft	records.

12. The	pre-flight	inspection	must	account	for	all	potential	discrepancies,	e.g.	inoperable	components,	items,	or	

equipment,	not	already	covered	in	the	relevant	sections	of	the	operating	documents.

13. The	operator	must	follow	the	UAS	manufacturer’s	aircraft/component,	maintenance,	overhaul,	replacement,	

inspection,	and	life	limit	requirements.

14. The	operator	must	carry	out	its	maintenance,	inspections,	and	record	keeping	requirements,	in	accordance	

with	the	operating	documents.	Maintenance,	inspection,	alterations,	and	status	of	replacement/overhaul	

component	parts	must	be	noted	in	the	aircraft	records,	including	total	time	in	service,	description	of	work	

accomplished,	and	the	signature	of	the	authorized	person	returning	the	UAS	to	service.

15. Each	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	sport pilot	certificate	and	at	least	a	current	third- class	medical	certificate.

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

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

under	the	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	from	

persons,	vessels,	vehicles	and	structures.	PIC	qualification	flight	hours	must	be	logged	in	a	manner	consistent	

with	14	C.F.R.	§	61.51(b).	Flights	for	the	purposes	of	training	the	operator’s	PICs	are	permitted	under	the	terms	

of	the	exemption.	However,	training	operations	may	only	be	conducted	during	dedicated	training	sessions.	

During	training,	proficiency,	and	experience-building	flights,	all	persons	not	essential	for flight	operations	are	

considered	nonparticipants,	and	the	PIC	must	operate	the	UA	with	appropriate	distance	from	nonparticipants	

in	accordance	with	14	C.F.R.	§	91.119.
18

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	FAApublished	aeronautical	chart	unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained,	and	the	

operation	is	conducted	in	accordance	with	a	NOTAM	as	required	by	the	operator’s	COA.	The	letter	of	agreement	

with	the	airport	management	must	be	made	available	to	the	Administrator	upon	request.

21. The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	horizontally	from	a	cloud	or	when	

visibility	is	less	than	3	statute	miles	from	the	PIC.

22. If	the	UA	loses	communications	or	loses	its	GPS	signal,	it	must	return	to	a	pre- determined	location	within	the	

planned	operating	area	and	land	or	be	recovered	in	accordance	with	the	operating	documents.

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

operating	documents.

24. The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast	weather	conditions)	there	

is	enough	power	to	fly	at	normal	cruising	speed	to	the	intended	landing	point	and	land	the	UA	with	25%	

battery	power	remaining.

25. The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate	of	Waiver	or	Authorization	(COA)	

prior	to	conducting	any	operations	under	the	grant	of	exemption.	This	COA	will	also	require	the	operator	to	

request	a	Notice	to	Airman	(NOTAM)	not	more	than	72	hours	in	advance,	but	not	less	than	48	hours	prior	to	

the	operation.	All	operations	shall	be	conducted	in	accordance	with	airspace	requirements	in	the	ATO	issued	

COA	including	class	of	airspace,	altitude	level	and	potential	transponder	requirements.

26. All	aircraft	operated	in	accordance	with	the	exemption	must	be	identified	by	serial	number,	registered	in	

accordance	with	14	C.F.R.	part	47,	and	have	identification	(N- Number)	markings	in	accordance	with	14	C.F.R.	

part	45,	Subpart	C.	Markings	must	be	as	large	as	practicable.

27. Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	and	control	of the	UA	must	

comply	with	the	Federal	Communications	Commission	(FCC)	or	other	appropriate	government	oversight	

agency	requirements.

28. The	documents	required	fewer	than	14	C.F.R.	91.9	and	91.203	must	be	available	to	the	PIC	at	the	Ground	

Control	Station	of	the	UAS	any	time	the	UAS	is	operating.	These	documents	must	be	made	available	to	the	

Administrator	or	any	law	enforcement	official	upon	request.

29. The	UA	must	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation	operations	and	activities	at	all	

times.

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

31. Flight	operations	must	be	conducted	at	least	500	feet	from	all	nonparticipating	persons	(persons	other	than	the	

PIC,	SO,	operator	trainees	or	essential	persons),	vessels,	vehicles, and	structures	unless:

a. Barriers	or	structures	are	present	that	sufficiently	protect	nonparticipating	persons	from	the	UA	

and/or	debris	in	the	event	of	an accident.	The	operator	must	ensure	that	nonparticipating	persons	

remain	under	such	protection.	If	a	situation	arises	where	nonparticipating	persons	leave	such	

protection	and	are	within	500	feet	of	the	UA,	flight	operations	must	cease	immediately	and/or;

b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the	owner/controller	of	such	

vessels,	vehicles	or	structures	has	granted	permission	and	the	PIC	has	made	a	safety	assessment	of	the	

risk	of	operating	closer	to	those	objects	and	determined	that	it	does	not	present	an	undue	hazard,	and;
19

c. Operations	nearer	to	the	PIC,	SO,	operator	trainees	or	essential	persons	do	not	present	an	undue	

hazard	to	those	persons	per	§	91.119(a).

32. All	operations	shall	be	conducted	over	private	or	controlled-access	property	with	permission	from	the	land	

owner/controller	or	authorized	representative.	Permission	from	land	owner/controller	or	authorized	

representative	will	be	obtained	for	each	flight	to	be	conducted.

33. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	boundaries	of	the	operational	

area	as	defined	by	the	applicable	COA	must be	reported	to	the	FAA's	UAS	Integration	Office	(AFS-80)	within	24	

hours.	Accidents	must	be	reported	to	the	National	Transportation	Safety	Board	(NTSB)	per	instructions	

contained	on	the	NTSB	Web	site:	www.ntsb.gov.

2.	REASONS	WHY	AN	EXEMPTION	FROM	THE	REQUIREMENTS	OF	SECTION 61.113(A)	AND	(B)	

WOULD	NOT	ADVERSELY	AFFECT	SAFETY

Aerospective	Imaging,	LLC	submits	that	the	equivalent	level	of	safety	established	by	Section	61.113(a)	and	(b)	will	be	

maintained	because	no	PIC	will	be	allowed	to	operate	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	

unless	that	PIC	has	demonstrated,	by	meeting	minimum	flight-hour	and	currency	requirements,	that	the	PIC	is	able	to	

safely	operate	the	DJI	UAS	in	a	manner	consistent	with	the	exemption,	including	evasive	and	emergency	maneuvers	and	

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

Considering	Aerospective	Imaging,	LLC’s	proposed	area	of	operations,	and	the	operating	limitations	set	forth-above;	the	

parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to	those	of	commercial	pilot	requirements	(See	

Exemption	No.	11062);	and	the	airmanship	skills	necessary	to	safely	operate	the	DJI	Phantom	3,	Inspire	1,	and	

Spreading	Wings	S1000+ UAS,	Aerospective	Imaging,	LLC	submits	that	the	additional	manned	airmanship	experience	of	

a	commercially	certificated	pilot	would	not	correlate	to	the	airmanship	skills	necessary	for	Aerospective	Imaging,	LLC’s	

specific	proposed	flight	operations.

The	FAA	has	previously	granted	relief	from Section	61.113(a)	and	(b)	specific	to	UAS,	in	circumstances	similar,	in	all	

material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	

11109,	11110,	11112,	11136,	11138,	11150,	11153,	11156,	11158,	11159,	11160,	11161).

Aerospective	Imaging,	LLC	will	not	allow	any	PIC	to	operate	the	DJI	Phantom	3,	Inspire	1,	or	Spreading	Wings	S1000+

UAS	unless	that	PIC	has	demonstrated,	by	meeting	minimum	flight-hour	requirements	or	DJI	UAS	training	and	currency	

requirements,	that	the	PIC	is	able	to	safely	operate	the	DJI	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	Aerospective	Imaging,	LLC’s	proposed	

operations.	The	Administrator	has	held	that	prior	documented	flight	experience	that	was	obtained	in	compliance	with	

applicable	regulations	would	ensure	safe	operations,	stating	as	follows:
20

In	Exemption	No.	11062,	the	FAA	required	that	prior	to	conducting	operations	for	the	purpose	of	motion	

picture	filming	(or	similar	operations),	the	PIC	must	have	accumulated	and	logged,	in	a	manner	consistent	with	

14	CFR	61.51(b),	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	including	at	least	10	hours	logged	as	a	UAS	

pilot	with	a	multi-rotor	UAS.	Prior	to	operations	under	Exemption	No.	11062,	the	PIC	must	also	have	

accumulated	and	logged	a	minimum	of	5	hours	as	a	UAS	pilot	operating	the	same	make	and	model	of	UAS	to	be	

used	for	operations	under	the	exemption.	For	clarification,	the	FAA	considers	these	minimum	hour	

requirements	to	be	inclusive	rather	than	additive;	i.e.	5	hours	make	and	model	time	may	be included	in	the	10	

hours	of	multi-rotor	time	and	the	10	hours	may	be	included	in	the	total	25	hours	of	UAS	rotorcraft	time.	In	

addition	to	the	hour	requirements,	the	PIC	must	accomplish	3	takeoffs	and	landings	in	the	preceding	90	days	

(for	currency	purposes).	The	FAA	finds	that	at	a	minimum,	the	flight-hour	requirements	in	Exemption	No.	

11062	are	appropriate	to	practice	and	build	proficiency	in	the	skills	necessary	to	safely	conduct	the	petitioner’s	

proposed	operations.	The	FAA	also	finds	that	prior	documented	flight	experience	that	was	obtained	in	

compliance	with	applicable	regulations	would	satisfy	this	requirement.	Training,	proficiency,	and	experiencebuilding	flights	can	also	be	conducted	under	the	grant	of	exemption	to	accomplish	the	required	flight	time.	

During	training,	proficiency,	and	experience-building	flights	the	PIC	is	required	to	operate	the	UA	with	

appropriate	distances	in	accordance	with	14	C.F.R	91.119.

Exemption	No.	11138	at	page	15.

Accordingly,	Aerospective	Imaging,	LLC	will	ensure	safe	operations	by	not	allowing	any	PIC to	operate	the	DJI	Phantom	

3,	Inspire	1,	or	Spreading	Wings	S1000+ UAS	unless	that	PIC	has	demonstrated,	by	meeting	minimum	flight-hour	and	

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

Aerospective	Imaging,	LLC	will	ensure	that	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UAS	are in	an	

airworthy	condition	based	upon	the	UAS’s	compliance	with	its	operating	documents	and	as	stated	in	the	conditions	and	

limitations	herein.

Additionally,	the	FAA	has	previously	granted	relief	from	Section	91.7(a)	specific	to	UAS,	in	circumstances	similar,	in	all	

material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	

11109,	11110,	11112,	11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161).

4.	REASONS	WHY	AN	EXEMPTION	FROM	THE	REQUIREMENTS	OF	SECTION	91.121	WOULD

NOT	ADVERSELY	AFFECT SAFETY

The	equivalent	level	of	safety	established	by	Section	91.121	will	be	maintained	because	the	altitude	information	of	the	

DJI	Phantom	3.	Inspire	1,	and	Spreading	Wings	S1000+ UAs	will	be	provided	to	the	PIC	via	GPS	equipment	and	a	radio	

communications	telemetry	data	link,	which	downlinks	from	the	UA	to	the	GCS	for	active	monitoring	of	the	flight	path	

and	altitude.	This	altitude	information,	combined	with	Aerospective	Imaging,	LLC’s	operation	of	the	DJI UAs	within	

visual	line	of	sight,	at	or	below	500	feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121.	The	altitude	
21

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	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+	UASs;	(2)	the	

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

Aerospective	Imaging,	LLC	will	ensure	that	it	will	safely	operate	the	battery	powered	DJI	UAs	during	daylight	hours	in	

VFR	conditions,	with	enough	battery	power	to	fly	for	a	total	duration	of	18.5	minutes	to	the	first	point	of	intended	

landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	minutes.

Here,	the	technical	specifications	of	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs;	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 UASs	provide	audible and	

visual	warnings	to	the	PIC	at	the	GCS	when	the	UAs	experiences	low	battery	voltage,	the	first	warning	occurring	at	

approximately	30%	remaining	battery	power,	and	again	at	approximately	10%	remaining	battery	power.	At	the	

critically	low	battery	level,	the	UASs	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,	Aerospective	Imaging,	LLC	submits	that	the	equivalent	level	of	safety	with	regard	to	the	

regulatory	maintenance	and	alteration	requirements	established	by	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	

(a)(2),	and	91.417(a)	&	(b)	will	be	met	because	Aerospective	Imaging,	LLC	will	use	trained	technicians	to	perform	

maintenance,	alterations,	or	preventive	maintenance	on	the	UASs	using	the	methods,	techniques,	and	practices	

prescribed	in	the	operating	documents	(i.e.,	the	Aerospective	Imaging,	LLC	Aerial	Operations	Manual,	Monthly	

Maintenance	Log	and	DJI	Instruction	Manual)s.	Furthermore,	Aerospective	Imaging,	LLC	will	document	and	maintain	all	

maintenance	records	for	the	DJI	UASs.
22

Since	the	DJI	UASs	will	be	inspected	as	prescribed	by	the	operating	documents,	Aerospective	Imaging,	LLC	will	maintain	

the	equivalent	level	of	safety	established	by	Sections	91.405(a),	91.409(a)(1),	and	91.409(a)(2).	

Likewise,	the	exemption	sought	will	not	adversely	affect	safety	because	Aerospective	Imaging,	LLC	will	use	trained	

technicians	to	perform	maintenance,	alterations	or	preventive	maintenance	on	the	UAS	using	the	methods,	techniques,	

and	practices	prescribed	by	the	operating	documents.

Furthermore,	the	exemption	sought	would	maintain	an	equivalent	level	of	safety	established	by	Sections	91.407,	

91.417(a)	and	91.417(b),	because	all	maintenance	of	the	DJI	UASs	will	be	performed	by	trained	technicians.	

Maintenance	will	be	documented	and	maintained	utilizing	the	monthly	maintenance	log.

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	

(a)(2),	and	91.417(a)	&	(b)	establish	that	safety	is	not	adversely	affected	when	the	technical	characteristics	and	

operating	limitations	of	the	UAS	are	considered.

In	consideration	of	Aerospective	Imaging,	LLC’s	proposed	operating	limitations,	the	operating	documents,	and	the	

technical	aspects	of	the	DJI	UASs,	Aerospective	Imaging,	LLC	submits	that	safety	will	not	be	adversely	affected	by	

granting	exemption	from	14	C.F.R.	Sections	91.405(a),	91.407(a)(1)	and	(a)(2),	91.409(a)(2),	and	91.417(a)	and	(b).	

The	FAA	has	previously	granted	relief	specific	to	UAS	in	circumstances	similar,	in	all	material	respects,	to	those	

presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	11112,	

11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161).

7.	THE	FAA	MAY	PRESCRIBE	ANY	OTHER	CONDITIONS	FOR	SAFE	OPERATION

In	accordance	with	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	and	14	C.F.R.	§	21.16	entitled	

Special	Conditions,	Aerospective	Imaging,	LLC	requests	that	the	FAA	prescribe	special	conditions	for	the	intended	

operation	of	the	DJI	UASs,	which	contain	such	safety	standards	that	the	Administrator	finds	necessary	to	establish	a	

level	of	safety	equivalent	to	that	established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14	C.F.R	§§	61.113(a)	&	(b),	91.7	(a),	

91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	Such	special	conditions	will	

permit	safe	operation	of	the	UAs	for	the	limited	purpose	of	conducting	aerial	video	and	photography	over	certain	areas	

of	the	United	States	for	compensation	or	hire.	FMRA	Section	333	sets	forth	the	requirements	for	considering	whether	a	

UAS	will	create	a	hazard	to	users	of	the	NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security;	and	further,	

provides	the	authority	for	such	UAS	to	operate	without	airworthiness	certification	in	accordance	with	any	requirements	

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

Likewise,	the	Administrator	may	prescribe	special	conditions	pursuant	to	14	C.F.R. §	21.16,	for	operation	of	the	DJI	

UASs,	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.
23

See	14	C.F.R.	§	21.16.

Therefore,	in	accordance	with	FMRA	Section	333	and	14	C.F.R.	§	21.16,	the	FAA	may	prescribe	special	conditions	for	

Leading	Edge’s	intended	operation	of	the	DJI	UASs,	which	contain	such	safety	standards	that	the	Administrator	finds	

necessary	to	establish	a	level	of	safety	equivalent	to	that	established	by	14	C.F.R.

Part	21,	Subpart	H,	and	14	C.F.R	Sections	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	

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

F.	A	SUMMARY	THAT	CAN	BE	PUBLISHED	IN	THE	FEDERAL	REGISTER,	STATING:	THE	

RULES	FROM	WHICH	AEROSPECTIVE	IMAGING,	LLC	SEEKS	EXEMPTION

AEROSPECTIVE	IMAGING,	LLC	seeks	exemption	from	the	requirements	of	14	C.F.R	Sections	61.113(a)&(b),	91.7(a),	

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

A	BRIEF	DESCRIPTION	OF	THE NATURE	OF	THE	EXEMPTION	AEROSPECTIVE	IMAGING,	LLC	

SEEKS:

This	exemption	will	permit	AEROSPECTIVE	IMAGING,	LLC	to	commercially	operate	an	Unmanned	Aircraft	System	

(UAS)	for	the	purpose	of	conducting	aerial imaging, video, and	photography	over	certain	areas of	the	United	States.

G.	ANY	ADDITIONAL	INFORMATION,	VIEWS,	OR	ARGUMENTS	AVAILABLE	TO SUPPORT	

AEROSPECTIVE	IMAGING,	LLC’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,	Aerospective	Imaging,	LLC’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,	Aerospective	Imaging,	LLC	will	operate	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	

S1000+ 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.
24

CONCLUSION

As	set	forth	herein,	Aerospective	Imaging,	LLC	seeks	an	exemption	pursuant	to	14	C.F.R.	§	11.61	and	Section	333	of	the	

FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	which	will	permit	safe	operation	of	the	DJI	Phantom	3,	Inspire	1,	

and	Spreading	Wings	S1000+ UASs	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	Aerospective	Imaging,	LLC	to	safely,	efficiently,	and	economically	

operate	the	DJI	Phantom	3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	commercially	within	the	NAS.

WHEREFORE,	in	accordance	with	the	Federal	Aviation	Regulations	and	the	FAA	Modernization	and	Reform	Act	of	2012,	

Section	333,	Aerospective	Imaging,	LLC	respectfully	requests	that	the	Administrator	grant	this	Petition	for	an	

exemption	from	the	requirements	of	14	C.F.R	Sections	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	

91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	and	permit	Aerospective	Imaging	to	operate	the	DJI	Phantom	

3,	Inspire	1,	and	Spreading	Wings	S1000+ UASs	commercially	for	the	purpose	of	conducting	aerial imaging, video, and	

photography	over	certain	areas	of	the	United	States.

Respectfully	submitted	on	November	9,	2015

Aerospective	Imaging,	LLC

Attn.	Daniel	Powers and	Theodore	Dickerson

3923	Reflection	Drive

Anchorage,	AK	99504

828-545-6906

aerospectiveimaging@gmail.com