U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

September 1O, 2015 

Petitioner 

Ariel Saint Hilaire

903 Lake Lily Dr. #A111

Maitland, Florida 32751

407-300-4316

www.Flashismyname.com 

Ariel Saint Hilaire will be providing clients with high quality imaging for a variety of 

commercial, public, and residential uses. He is a 8 year experienced Aerial 

Photographer/Videographer with hours of flying experience and is seeking an 

exemption from these specific requirements of Title 14 C.F.R.: 

1. 91.119(b) and (c) 

2. 91.121 

3. 91.151(a) 

4. 91.405(a) 

5. 91.407(a)(1) 

6. 91.409(a)(1) and (2) 

7. 91.417(a) and (b) 
Definitions 

1. AGL Above Ground Level 

2. ATC Air Traffic Control 

3. COA Certificate of Authorization 

4. FAA Federal Aviation Administration 

5. FAR Federal Aviation Regulation 

6. GPS Global Positioning System 

7. NAS National Airspace System 

8. PIC Pilot in Command 

9. UA Unmanned Aircraft 

10.sUAS Small Unmanned Aerial System 

11.VFR Visual Flight Rules 

12.VLOS Visual Line of Site 

Summary 

In the instance of granting exemption, Ariel Saint Hilaire will be operating the sUAS in order to 

fulfill contracted obligations, such as: aerial photography and videography for real estate 

agents, appraisers, property managers, general contractors; solar panel installation 

technicians; agriculturists; law enforcement; utility inspections (only where safe flight is 

attainable); chambers of commerce and associated businesses; wildlife conservation 

organizations; public departments; all other institution requiring filmography (safe flight 

permitting) 
Aircraft

DJI Inspire 1 

A. Weight (Including Battery and Propellers) 6.47 lbs 

B. Diagonal Size (Including Propellers) 22.87 in 

C. Max Ascent Speed 11.2 mph 

D. Max Descent Speed 9 mph 

E. Max Flight Time ~ 18 minutes 

F. Remote Controller Operating Frequency 

2.400 GHz 2.483 

GHz 

5.725 GHz 5.825 

GHz 

G. AutoTakeoff 

Rises to a preset 

height and 

will hover in place until directed 

where to go 

H. AutoReturn 

Home Remembers the exact spot it 

took off from to enable a tap of a 

button to return back home 

I. Low Battery Failsafe If the flight battery is run running 

low or the Inspire 1 loses 

connection with the remote it will 

automatically return back home 
Specific Sections of C.F.R From Which Ariel Saint Hilaire Seeks Exemption

1. Section 91.119 Minimum Safe Altitudes

Section 91.119 states persons may operate a helicopter at less than the minimums prescribed 

in paragraph (b) or (c) of this section, provided each person operating the helicopter complies 

with any routes or altitudes specifically prescribed for helicopters by the FAA. The sUAS 

meets this criteria as a helicopter and requests the ability to operate at altitudes up to 400’ 

AGL. Only in accordance with pre obtained consent will the sUAS operate while also 

maintaining an altitude less than 400’ AGL. For comparison with traditional aircraft and 

rotorcraft the sUAS weighs less than 10lbs, while also preventing potential risks associated 

with flammable fuel. Lastly the 400’ AGL ceiling limits any ability for the sUAS to interfere with 

conventional aircraft operating at or above 500’ AGL. 

2. Section 91.121 Altimeter Settings 

Section 91.121 states 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 below 18,000 feet MSL, to the current reported altimeter setting of a station along 

the route and within 100 nautical miles of the aircraft. 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. The sUAS will reference its altitude based on GPS and will be restricted to 

a 400’ AGL ceiling. The PIC will also verify GPS elevation from multiple ground based sources 

prior to takeoff. 

3. Section 91.151 Fuel Requirements for Flight in VFR conditions

Section 91.151 states 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. The sUAS battery powered operational flight time is not able to incorporate a 20 

minute reserve window following successful first point of intended landing due to current 

battery capacity limitations. In order to provide adequate reserve power for return landing the 

sUAS will abide by a 12 minute flight time or 25% of remaining battery power, whichever 

happens first. 

4. Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b) 

These sections only apply to aircraft with an airworthiness certificate, Ariel Saint Hilaire 

requests exemption from these sections because the DJI inspire 1 does not require 

airworthiness certificates. This sUAS is in accordance with FMRA Section 333 for operation, 

absent an airworthiness certificate. In order to insure proper maintenance the operations 

manual will be cited for necessary corrective measures. In addition, the PIC is the person 

most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition, 

and any sUAS conducted maintenance will be documented for the life of the aircrafts. 
Public Interest 

• Real estate agents will be able to set their listings apart with a unique perspective 

only available from sUAS photographic equipment, therefore increasing the prospect 

of meeting or exceeding the asking price. 

• Property managers and contractors will have the ability to survey their property for 

anomalies while preventing human endangerment due? ?to hazardous conditions. 

• Solar panel technicians can safely inspect potential installation locations without 

putting themselves in high elevation and sloping circumstances. 

• Agriculturists will have the ability to survey their land in a more timely manner and 

better document the condition of their property. 

• Marketing firms and other businesses would use unique aerial photography and 

panographic video to promote marketing campaigns and increase revenue. 

• Search and rescue entities could utilize the sUAS to help quickly aid in finding the 

location of person(s) while providing a better vantage point in closer quarters. 

• Public Safety 

• The DJI Inspire 1 will reduce air and noise pollution do to the aircraft being powered 

by a battery and brushless electric motors. 

• This small aircraft create less potential for harm, should an emergency situation 

occur, thanks to their size and weight. 

• Furthermore the lack of combustible fuel also significantly decreases their chances 

of producing harm. 
Conclusion 

Based on the criteria provided under the FMRA Section 333, Ariel Saint Hilaire requests that 

the FAA grants him exemption from 14 C.F.R Sections 91.119(b) and (c), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) in order to conduct 

contracted commercial sUAS operations using the DJI Inspire 1 for a wide range of industries 

and applications. 

Kind Regards,

Ariel Saint Hilaire