September 4, 2015

Exemption No. 12766

Regulatory Docket No. FAA−2015−2579

Mr. Jeffrey Nichols

Owner

adPharos, LLC

3350 Riverwood Parkway Suite 1900

Atlanta, GA 30339

Dear Mr. Nichols:

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) on 

behalf of adPharos, LLC (hereinafter petitioner or operator) for an exemption. The petitioner

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

photography, search and rescue, and increase public knowledge.

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

the regulations that the petitioner seeks an exemption.

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

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

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

Airworthiness Certification

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

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

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

operating area associated with the aircraft and its operation, the Secretary of Transportation 
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has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

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

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

requirements of part 36, is not necessary.

The Basis for Our Decision

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

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

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

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

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

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

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

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

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

by this exemption is in the public interest.

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

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

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

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

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

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

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

delegated to me by the Administrator, adPharos, LLC is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

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

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

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

Conditions and Limitations

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

 

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

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

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

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

grounds for the immediate suspension or rescission of this exemption.

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

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 
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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.

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 
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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.

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

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

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

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

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

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

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

official upon request.

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

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

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

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

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

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

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

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

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

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

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

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

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

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

must include at least the following:

a. Dates and times for all flights;

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

under this grant of exemption;

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

the UAS;

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

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

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

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

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

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

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

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

exemption holder’s MPTOM.

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

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

parts 45, 47, 61, and 91.

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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SUMMARY

adPharos, 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

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

conducting aerial video and photography for construction sites before and after, real estate 

photography, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

adPharos provides its clients with the high quality digital content for use in their commercial, 

personal, and non-profit multimedia projects. adPharos has recreational/hobby experience in all 

aspects of aerial video and photography. The objective of adPharos aerial video and photography 

operations is to provide high quality imaging for a variety of, commercial, public, and residential 

uses, specifically targeting

• Real Estate Videography and Photography

• Construction sites before and after

• Search and Rescue operations

• Increase public knowledge of UAS and promote safe UAS operations

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UASs

adPharos seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with

a Ground Control Station (GCS) utilizing electronic tablet or smartphone systems. The DJI 

Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 

17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI 

Inspire 1UA is equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors. The DJI Inspire 1 UA that will be operated by adPharos, LLC will be registered 

in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, 

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking.

BASIS FOR PETITION

Petitioner, adPharos, 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
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Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

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

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

unmanned aircraft and its operation, adPharos operation of DJI Inspire 1 UAS meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, adPharos 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. adPharos submits that the requested relief is 

proper since an equivalent level of safety will be ensured. adPharos 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 

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

and limitations: Pilot in command, is requested by adPharos to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman 

medical certificate, and who has demonstrated, that the PIC is able to safely operate the DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

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

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

Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, adPharos will ensure that the DJI Inspire 1 UAS is in airworthy condition, 

prior to every flight, by determining that the UAS is in compliance with the operating documents 

and that the aircraft is in a condition for safe flight.

adPharos also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Inspire 1 UA will be provided to the PIC via 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 adPharos

operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121.

Additionally, adPharos seeks an exemption from the requirements of Section

91.151(b) entitled Fuel requirements for flight in VFR conditions. adPharos submits that safety 

will not be affected by operation of DJI Inspire 1 UA during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to 

fly for a total duration of approximately 16 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4 minutes.

In accordance with 14 C.F.R. § 11.81, adPharos 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:

adPharos, LLC

3350 Riverwood Parkway Suite 1900

Atlanta, GA 30339

404-439-1029

jnichols@adPharos.com

B. The Specific Sections Of 14 C.F.R. from Which adPharos Seeks Exemption.

1. adPharos Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as PIC of an aircraft.

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

with any business or employment if—

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

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

2. adPharos 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. adPharos Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

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

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available before 

departure.

4. adPharos 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. adPharos 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. adPharos 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—

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

chapter [.]

7. adPharos 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:
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(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. adPharos Seeks Exemption from the Requirements of Sections 91.417(a) and

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.
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(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

C. The Extent Of Relief adPharos Seeks And The Reason adPharos Seeks The Relief.

1. Extent Of Relief adPharos Seeks and the Reason adPharos Seeks Relief From

Section 61.113(a) And (b)

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical certificate, 

and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire. This relief is requested since the 

limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for 

compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire.
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As set forth more fully below, adPharos submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that 

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

able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures.

Further, adPharos submits that all flights of the DJI Inspire 1 UASs, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to adPharos business; and 

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

2. Extent Of Relief adPharos Seeks And The Reason adPharos 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 adPharos to determine that the DJI Inspire 1 UASs are in airworthy 

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

operating documents.

adPharos seeks the requested relief because the DJI Inspire 1 UAS does not require an 

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

adPharos will ensure that the DJI Inspire 1 UAS is in airworthy condition based upon its 

compliance with the operating documents prior to every flight, and further, determine that 

the aircraft are in condition for safe flight, as stated in the conditions and limitations 

below.

3. Extent Of Relief adPharos Seeks And The Reason adPharos Seeks Relief From

Section 91.121

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

operations of the DJI Inspire 1 UAS, which utilizes 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),

adPharos seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set 

on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before 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 DJI Inspire 1 UA is equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting will 
8

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 adPharos Seeks and the Reason adPharos 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 Inspire 1 UA

during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), for a total duration of 16 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4 minutes. adPharos seeks 

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

duration of the battery powered DJI Inspire 1 UAs will severely constrain the practicality 

of any aerial video or still photo flight operations that adPharos proposes to conduct 

pursuant to this Petition.

5. Extent Of Relief adPharos Seeks And The Reason adPharos 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, adPharos requests relief from these

Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set 

forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 

for operation without an airworthiness certificate. Accordingly, adPharos will use trained

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

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

Furthermore, adPharos will document and maintain all maintenance records for the DJI 

Inspire 1 UASs.

D. The Reasons Why Granting adPharos 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 adPharos too safely, 

efficiently, and economically perform aerial video and photography for real estate, special 

events, and landscape over certain areas of the United States. Additionally, use of the DJI Inspire 

1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to

the economy. Notably, the benefits of adPharos proposed operation of the DJI Inspire 1 UAS

will be realized without implicating any privacy issues.

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

The DJI Inspire 1 UA are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an 
9

exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life 

and property in the air and on the ground. Furthermore, by reducing the number of 

manned aircraft operating in the NAS, congestion around airports caused by arriving and 

departing aircraft will be reduced. The DJI Inspire 1 UA does not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

2. The Public Will Benefit from the Safety and Efficiency Of The

DJI Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, DJI Inspire 1 UAS produce no air pollution, and is the 

most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI 

Inspire 1 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates 

noise pollution, as the UA is propelled by battery powered electric motors, rather than an 

internal combustion engine. By using DJI Inspire 1 UAS to perform aerial acquisitions, 

the substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Inspire 1 UA (weighing 6 pounds 7.5 ounces respectively, at 

maximum gross weight with length of 17.3 inches respectively, width of 17.7 inches 

respectively, and with no fuel on board), has less physical potential for collateral damage 

to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons).

3. Performing Aerial Video and Photography Operations With The

DJI Inspire 1 UASs Will Benefit the Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of DJI Inspire 1 UAS will allow United States based companies, like adPharos, 

to remain competitive and contribute to growth of the U.S. economy. Specifically, with 

the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies 

must adopt new and alternative technology in order to remain competitive. Operating the 

battery powered DJI Inspire 1 UAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. By operating 
10

the DJI Inspire 1 UAS, companies such as adPharos, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, 

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

performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and 

federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, adPharos, LLC proposed operation of the DJI Inspire 1 UASs will not implicate 

any privacy issues. Specifically, the DJI Inspire 1 UASs will be operated only in 

compliance with operating documents which requires property owner involvement 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 adPharos Seeks Exemption.

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

and Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, adPharos operation of the DJI Inspire 1 UAS meet 

the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, 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. 

In seeking this exemption, adPharos submits that the DJI Inspire 1 UAS can operate 

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

characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) 

the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics.

The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, 

and operational capability.
11

i. Technical Specifications Of The DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS are set forth by the 

DJI Inspire 1 user manual, attached hereto as Exhibit A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area.

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

autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI Inspire 1 UAS is provided at pages 12-16 

and 45-50 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit A.

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation.

When the Control Link is lost, the DJI Inspire 1UA will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 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 

Inspire 1 at pages 13 through 15 of the DJI Inspire 1 User Manuals, 

attached hereto as Exhibit A.

iv. DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI 

Inspire 1 GCS and flight control software is provided at pages 40 through 

47 of the DJI Inspire 1 User Manual. DJI Inspire 1 User Manuals are 

attached hereto as Exhibit A.

b. Flight Operations of DJI Inspire 1 UAS Are Limited to the Line Of Sight 

of A Certificated Pilot in Command with A Safety Observer.

adPharos will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1

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

c. Flights of DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, adPharos proposes to commercially operate DJI Inspire 

1 UAS for the special purpose of conducting aerial video and photography over 
12

certain areas of United States, pursuant to the following specific operating 

limitations:

1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned 

Aircraft System. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant.

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

for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 50 knots.

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

level (AGL), as indicated by the procedures specified in the operating documents 

unless a special request is made and approved by ATC. All altitudes reported to 

ATC must be in feet AGL.

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

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents.

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

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments.

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

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 
13

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 private pilot certificate and at least a current 

third- class medical certificate.
14

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

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

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

distance from nonparticipants in accordance with 14 C.F.R. §91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. The 

letter of agreement with the airport management must be made available to the 

Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

forecast weather conditions) there is enough power to fly at normal cruising speed 

to the intended landing point and land the UA with 25% battery power remaining.

25. 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.
15

26. 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.

27. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

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

vehicle.

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and;

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

present an undue hazard to those persons per § 91.119(a). 32. All operations shall 

be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be 

conducted.

30. 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. 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, adPharos requests that the 
16

FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification in accordance 

with any requirements that must be established for the safe operation of the UAS in the 

NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 

21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel 

or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, 

states the following: If the FAA finds that the airworthiness regulations of this subchapter 

do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or 

propeller because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. The 

special conditions are issued in accordance with Part 11 of this chapter and contain such 

safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. 

§ 21.16. 

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

prescribe special conditions for adPharos intended operation of the DJI Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

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

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

From Which adPharos Seeks Exemption:

adPharos 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 adPharos Seeks:

This exemption will permit adPharos to commercially operate an Unmanned Aircraft

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

areas of the United States.
17

G. Any Additional Information, Views, or Arguments Available To Support adPharos

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, adPharos 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, adPharos will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard 

to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, adPharos seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United 

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing adPharos to safely, efficiently, and economically operate the DJI 

Inspire 1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, adPharos 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 adPharos to operate the DJI Inspire 1 UAS commercially 

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

States.

Dated: 6/11/15

adPharos, LLC

_________________________

Jeffrey Nichols

adPharos, LLC, Owner

3350 Riverwood Parkway Suite 1900

Atlanta, GA 30339

404-439-1029

Appendices:

A - DJI Inspire 1 Manufacturer’s User Manual
18

DJI Inspire 1 Manual web address

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf