UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _

PETITION FOR EXEMPTION OF:

HIGH ADVENTURE AIR, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 45.23, 61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a),

91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION

OF THE DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW

112-95)

Submitted on January 30, 2015

Craig Van Camp (president)

High Adventure Air,Inc

8735 mills macon hwy 

Tecumseh,MI 49286

517-605-3129

cvancamp@me.com
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TABLE OF CONTENTS

Page

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

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

INTRODUCTION AND INTERESTS OF PETITIONER..................................................4

BACKGROUND .................................................................................................................5

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

NAME AND ADDRESS OF PETITIONER.................................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HAAI, INC. SEEKS

EXEMPTION.................................................................................................................8

THE EXTENT OF RELIEF HAAI, INC. SEEKS AND THE REASON HAAI, INC.

SEEKS THE RELIEF ..................................................................................................11

THE REASONS WHY GRANTING HAAI, INC.'S REQUEST FOR EXEMPTION 

WOULD BE IN THE PUBLIC INTEREST................................................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..............................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........33

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT HAAI, INC.'S REQUEST...................................................................33

CONCLUSION.................................................................................................................33
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

RTH Return To Home

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

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
4

SUMMARY

High Adventure Air, Inc. seeks exemption from the requirements of 14 C.F.R §§ 

45.23,61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b),

to commercially operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit High Adventure 

Air, Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of

conducting aerial acquisitions , research and inspections over certain rural areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

High Adventure Air, Inc. (hereinafter referred to as “HAAI”) was founded in 1984 by

CEO Craig Van Camp, a U.S. Army veteran (ret), HAAI is a Service-Disabled Veteran-Owned

Small Business supplying aircraft and maintenance to aviation community, and focused on 

bringing aviation technological advancements of UAS into the foreground of agriculture and 

inspections. This innovative approach to data collection will ultimately enable multiple

industries to have a faster, safer, and more efficient way to do business.

HAAI offers comprehensive solutions to develop data, with precision and speed, 

concerning precision agriculture, land management, infrastructure, and architecture. HAAI is 

fully compliant with government regulations and industry protocols. HAAI firmly believes in

combining innovation, quality and safety into all of its operations, in order to best aid its clients

and the communities it serves.

As set forth in this Petition, HAAI seeks to commercially operate its DJI Inspire 1UAS

over certain rural areas of the United States for the purpose of conducting aerial acquisitions

and research, videography, gathering of agricultural data, natural resources, conservation, 
5

construction ,infrastructure management and inspections ,monitoring assessments, search and

rescue operations, and reconnaissance in support of disaster or emergency situations.

BACKGROUND

Unmanned Aircraft System: DJI Inspire 1 UAS

HAAI seeks an exemption to operate the DJI Inspire 1 UAS for compensation or hire

within the NAS. The DJI Inspire 1 UAS is comprised of a vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The DJI Inspire 

1 UA has a maximum gross weight of approximately 6.7 pounds, while having a diameter of 26

inches, and maximum speed of 49 mph (approximately 42 knots). The DJI Inspire 1 UA is 

equipped with four propellers, each being driven by a Lithium Polymer battery powered

electric motor.

BASIS FOR

PETITION

Petitioner, HAAI, Inc., by and through undersigned counsel, pursuant to the provisions of

the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform

Act of 2012, Section 333, entitled Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to operate the DJI Inspire 1 UAS in the National Airspace System

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 45.23,61.113(a) & (b),

91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
6

 In consideration of the size, weight and speed, as well as the limited area of intended operation

associated with the unmanned aircraft, HAAI’s use of the DJI Inspire 1 UAS meets the

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

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

Accordingly, HAAI requests relief from Sections 45.23,91.405(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.

HAAI submits that the requested relief is proper since an equivalent level of safety will

be ensured. HAAI will use FAA qualified technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the manufacturer’s user/safety guidelines manual. Furthermore, HAAI will document and

maintain all maintenance records for the DJI Inspire 1 UAS.

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

privileges and limitations: Pilot in command, is requested by HAAI to the extent necessary to

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

medical certificate, and who has completed the DJI Inspire 1 UAS training and currency

requirements, to conduct the proposed UAS flight operations for compensation or hire. HAAI

submits that the conditions and limitations set forth herein will ensure the safety of the NAS, as

well as the safety of persons and property on the ground.

HAAI 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, HAAI submits that it will ensure that the DJI Inspire 1UAS

is in an airworthy condition prior to every flight, by determining that the UAS is in
7

compliance with its type design pursuant to the DJI Inspire 1 User Manual, and that the aircraft

is in a condition for safe flight.

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

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

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

Positioning System (GPS) equipment and a 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 HAAI’s operation of the DJI Inspire 1 UA within visual line of

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, HAAI seeks an exemption from the requirements of Section 91.171(b),

entitled Fuel requirements for flight in VFR conditions. HAAI submits that safety will not be

affected by operation of the DJI Inspire 1 UA during daylight hours under visual flight rules

(VFR) and visual meteorological conditions (VMC), with enough battery power to fly for a total

duration of 17 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least five minutes.

In accordance with 14 C.F.R. § 11.81, HAAI provides the following information in

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

 High Adventure Air, Inc.

8735 Mills Macon Hwy

Tecumseh, MI. 49286
8

 The point of contact for this Petition and specific contact information is as follows:

Craig Van Camp (president)

High Adventure Air,Inc

8735 mills macon hwy 

Tecumseh,MI 49286

517-605-3129 ,cvancamp@me.com

B. The Specific Sections Of 14 C.F.R. From Which HAAI Seeks

Exemption.

1. HAAI 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. HAAI 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. HAAI Seeks Exemption From The Requirements Of Section

91.121.

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

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

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

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100

nautical miles of the aircraft;
9

(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. HAAI Seeks Exemption From The Requirements Of Section

91.171(b).

Section 91.171, 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. HAAI 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. HAAI 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. HAAI 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:
10

(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. HAAI 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.

(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.
11

(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 HAAI Seeks And The Reason HAAI Seeks The 

Relief.

1. Extent of Relief HAAI Seeks And The Reason HAAI 

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 or higher

level pilot certificate, a current and valid airman medical certificate, and who has completed the

DJI Inspire 1 UAS training 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.
12

As set forth more fully below, HAAI 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

demonstrated, through the DJI Inspire 1 UAS training and currency requirements, that the PIC is 

able to safely operate the DJI Inspire 1 UAS in a manner consistent with 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, HAAI submits that all flights of the DJI Inspire 1 UAS conducted by the PIC

pursuant to the grant of this Petition - (1) will be incidental to HAAI’s business; and

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

2. Extent of Relief HAAI Seeks And The Reason HAAI 

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 HAAI to determine that the DJI Inspire 1 UAS is in an airworthy condition

prior to every flight by ensuring that the UAS is in compliance with the DJI Inspire 1 User

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

HAAI 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, prior to

every flight, HAAI will ensure that the DJI Inspire 1 UAS is in an airworthy condition based 

upon a visual inspection, in order to determine that the UA and its components are in compliance 

with its type design and operating documents (i.e., the DJI Inspire 1 User Manual, GCS User

Manual, and DJI Inspire 1 System safety guideline Manual), and that the aircraft can be operated

safely pursuant to the conditions and limitations stated herein.
13

3. Extent of Relief HAAI Seeks And The Reason HAAI 

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 GCS. HAAI seeks the requested relief because the DJI Inspire 1

UA does not utilize a typical barometric altimeter onboard that may be set as contemplated by

Section 91.121. As more fully set forth below, an equivalent level of safety will be maintained

since the DJI Inspire 1 UA is 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 HAAI Seeks And The Reason HAAI 

Seeks Relief From Section 91.171(b).

Relief from Section 91.171(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS

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

(VFR), for a total duration of 17 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least five minutes. HAAI seeks the requested relief

because without an exemption from Section 91.171(b), the flight time duration of the battery

powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial acquisition and

research flight operations that HAAI proposes to conduct pursuant to this Petition.
14

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS,

the DJI Inspire 1 User Manual, and HAAI’s proposed operating limitations, ensure that HAAI

will safely operate the battery powered DJI Inspire 1 UA during daylight hours under VFR, with 

enough battery power to fly for a total duration of 17 minutes to the first point of intended

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

5. Extent Of Relief HAAI Seeks And The Reason HAAI 

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, HAAI requests relief from these Sections

because the DJI Inspire 1 UAS does not require an airworthiness certificate. As set forth more

fully below, the DJI Inspire 1 UAS meets the conditions of Section 333 of the FMRA for

operation without an airworthiness certificate. Accordingly, HAAI will use FAA qualified 

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

the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. 

Furthermore, HAAI will document and maintain all maintenance records for the DJI Inspire 1

UAS.

D. The Reasons Why Granting HAAI’s Request For Exemption

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 HAAI to safely,

efficiently, and economically perform aerial acquisitions and research over rural areas of the

United States, commercially, in support of government entities, agriculture, scientific studies,

wildlife monitoring, forestry operations, and the electric, oil and gas industries. Additionally, use

of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide
15

significant benefits to the economy. Notably, the benefits of HAAI’s proposed operation of the

DJI Inspire 1 UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial

Acquisition And Research Performed.

HAAI submits this Petition to commercially operate the DJI Inspire 1 UAS and perform

aerial acquisition and research throughout rural areas of the United States, in support of

government entities, agriculture, infrastructure management assessments, search and rescue

operations, and reconnaissance operations during emergency situations. The DJI Inspire 1 UAS

will provide safe, efficient, and economical aerial acquisition and research to further each of

these fields, all of which are critical to the well being of the general public.

The specific operations that HAAI will perform with the DJI Inspire 1 UAS demonstrate

how the requested exemption will directly benefit the above-referenced industries and the

general public as a whole.

Agriculture

In the field of agriculture, HAAI’s operation of the DJI Inspire 1 UAS will be used to 

assess and increase crop yields, and allows for less use of pesticides and herbicides.

Specifically, HAAI’s ability to use the DJI Inspire 1 UAS to perform photos of fields, crops, and

known land tracts. This ability to during all seasons, will provide invaluable data for land and

soil management, which is costly using conventional manned aircraft. The capability of the 

DJI Inspire 1 UAS to utilize the high definition video camera packages, high definition

photography packages, will allow for detailed analysis and recording,

necessary to determine land erosion, perform flood mapping, and provide critical information

for land management.
16

2. The Public Will Benefit From Decreased Congestion Of

The NAS.

The DJI Inspire 1 UA is battery powered and serves as a safe, efficient, and economical

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

the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the 

use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce 

noise and air pollution, as well as increase the safety of life and property in the air and on the

ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. The DJI 

Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial survey 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.
17

3. 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 survey flight operations. By using battery power and electric

motors, the DJI Inspire 1 UAS produces no air pollution, and is the most viable environmentally

conscious alternative to the cabin class, six cylinder internal combustion twin engine aircraft that

are typically utilized for aerial acquisitions, 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 reduces noise pollution, as the UA is propelled by battery powered electric 

motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life

and property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the 

lack of flightcrew members located onboard the aircraft, the DJI Inspire 1 UA (weighing

approximately 6.7 pounds at its maximum gross weight with a diameter of 26 inches, 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 aerial acquisitions (weighing 

approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a

fuel capacity of 180 gallons).
18

4. Performing Aerial Acquisition Operations With The

DJI Inspire 1 UAS Will Benefit The Economy.

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

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the DJI 

Inspire 1 UAS will allow United States based companies, like HAAI, 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 the DJI Inspire 1 UAS, companies such as HAAI 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.

5. There Are No Privacy Issues.

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

decades, HAAI’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy

issues. Specifically, the DJI Inspire 1 UAS will be operated only in rural areas, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude
19

requirements of 14 C.F.R. § 91.119. Most significantly, the DJI Inspire 1 UA will not be

operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly

involved in the operation.

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 HAAI Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UAS Meets The

Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited geographical areas associated with

the unmanned aircraft and its proposed flight operations, HAAI’s operation of the DJI Inspire 1

UAS 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).
20

(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, HAAI submits that the DJI Inspire 1 UAS can operate safely

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

DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The DJI Inspire 1 UAS

Demonstrate Its Safe Characteristics.

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

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

capability.

i. Technical Specifications Of The DJI Inspire 1 UAS.

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

User and safety Manual, attached hereto as attachment A. Attachment A contains proprietary

information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1.

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 either the semi- autonomous or fullyautonomous flight modes. In its basic configuration, the DJI Inspire 1 UAS autonomous flight

mode features include a GPS Position and Altitude Hold, and a Return To Home (RTH)

function. While utilizing the GPS Position and Altitude Hold feature, the UA will automatically

1 Attachments to this Petition contain proprietary information, and in accordance with 14 C.F.R.

§ 11.35(b), are not to be included in the Federal Docket Management System (FDMS).
21

hold its position, altitude and heading. The RTH function commands a direct route to the

original point of launch, where the UA will perform an autonomous landing.

A complete description of the GPS Position and Hold function of the DJI Inspire 1 UAS

is provided in the DJI Inspire 1 User Manual, attached hereto as Attachment A. Attachment A 

contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 

11.35(b).

iii. The DJI Inspire 1 UAS Is Designed For

Automatic Return To Home Or Auto-Land In The 

Event Of Loss Of The Control Link Or 

Navigation.

According to the manufacturer of the DJI Inspire 1 UAS, in the unlikely event of a low 

battery condition or loss of the control link, the UA will automatically land or return to the point 

of launch. An altitude threshold can also be programmed, so that the UA will not exceed a

preset altitude.

Through the GCS, the PIC may select whether the UA will return to the point of launch

or automatically land in the unlikely event of the loss of the control link. If the automatic

landing feature is selected, the UA will begin a slow, safe, automatic descent to landing if the

control link is lost. Through feedback via on-board inertia sensors, the UA motors are turned off

and the rotors stop spinning, when the UA touches down upon landing.

Upon a loss of the control link, if the return to point of launch is selected, the UA will

begin to return to the point of launch, in a direct line. Once the UA returns to the point of

launch, it will hover to begin the manual landing process, or, if the control link has not been

reestablished, the UA will automatically land. If the control link is reestablished during a loss of

control link situation, the PIC may begin to manually control the UA.
22

Additionally, the PIC will receive visual alerts at the GCS in the event of degradation of

the GPS signal or control link. If less than six GPS satellites are within range of the DJI Inspire 

1 UAS, the PIC will receive a visual “Low GPS Warning”, which will also disable the GPS

Position and Hold feature, as well as the RTH feature.

Likewise, the DJI Inspire 1 UAS will provide a visual warning to the PIC at the GCS if the

control link is lost, while the UA enters failsafe mode and either begins to return to the point of 

launch, or automatically lands, depending upon the PIC’s previous settings. Once the control

link is reestablished, the PIC will be notified through visual alerts at the GCS.

A description of the fail-safe systems of the DJI Inspire 1 UAS is attached hereto as

Attachment A. Attachment A contains proprietary information and is to be held in a separate

file pursuant to 14 C.F.R. § 11.35(b).

iv. The DJI Inspire 1 GCS And Its Operation.

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

GCS and flight control software is provided in the DJI Inspire 1 GCS User Manual. A copy of

the DJI Inspire 1 GCS User Manual, which contains proprietary information, is attached hereto

as Attachment A, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

b. Flight Operations Of The DJI Inspire 1 UAS Are 

Limited To The Line Of Sight Of A Certificated

Pilot in Command With

A Safety Observer.

HAAI will only utilize certificated pilots who possess a valid and current 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.
23

c. Flights Of The DJI Inspire 1 UAS Will Be

Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, HAAI proposes to commercially operate the DJI Inspire 1

UAS for the special purpose of conducting aerial acquisitions over rural areas of United States,

pursuant to the following specific operating limitations:

1) Operations authorized by this grant of exemption are limited to the following aircraft

described in the operator’s manual which is a quad rotor aircraft weighing less than 6.7

pounds: 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) The UA may not be flown at an indicated airspeed exceeding 30 knots.

3) 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 operator’s manual. All altitudes

reported to ATC must be in feet AGL.

4) 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.

5) All operations must utilize a visual observer (VO). 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. The PIC must be designated

before the flight and cannot transfer his or her designation for the duration of the flight.

6) The operator’s manual and this grant of exemption must be maintained 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 operator’s

manual, the conditions and limitations herein take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operator’s manual.

The operator may update or revise its operator’s manual. 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. 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 amendment to their exemption. The FAA’s UAS Integration

Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the

operator’s manual.

7) Prior to each flight the PIC must inspect the UAS to ensure 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
24

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.

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 in accordance with the operator’s manual. The PIC who conducts the

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

requirements and procedures for a functional test flight and aircraft record entry must be

added to the operator’s manual.

9) The preflight inspection must account for all discrepancies, i.e. inoperable

components, items, or equipment, not covered in the relevant preflight inspection sections

of the operator’s manual.

10) The operator must follow the manufacturer’s UAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements, with particular attention to

flight critical components that may not be addressed in the manufacturer’s manuals.

11) HAAI must carry out their maintenance, inspections, and record keeping

requirements in accordance with the operator’s manual. Maintenance, inspection, and

alterations must be noted in the aircraft logbook, including total flight hours, description

of work accomplished, and the signature of the authorized UAS technician or PIC

returning the UAS to service.

12) Each UAS operated under this exemption must comply with all manufacturer System

and Safety Bulletins.

13) HAAI maintenance personnel must make a record entry in the UAS logbook or

equivalent document of the corrective action taken against discrepancies discovered

between inspections.

14) The PIC must possess at least a private pilot certificate and a third-class airman

medical certificate. The PIC must also meet the flight review requirements specified in 14

C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

15) The operator may not permit any PIC to operate unless that PIC has demonstrated,

through the training and currency requirements set forth in the operator’s manual, that the

PIC is able 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 people, vessels, vehicles and structures.
25

16) 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). Flights

under special visual flight rules (SVFR) are not authorized.

17) The UA may not operate within 5 nautical miles of the airport reference point as

denoted on a current FAA-published aeronautical chart.

20) 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.

21) 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 and land, or be

recovered in accordance with the operator’s manual.

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator’s manual.

23) The PIC is prohibited from beginning a UAS flight unless (considering wind and

forecast weather conditions and assuming normal cruising speed) there is enough power

to fly to the first point of intended landing prior to utilizing battery reserve power.

24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to request issuance of a Notice to

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

the operation.

25) 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.

26) The documents required pursuant to 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 aircraft 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 other manned aviation

operations and activities at all times.
26

28) The UA may not be operated over congested or densely populated areas. These areas

include but are not limited to the yellow areas depicted on World Aeronautical Charts

(WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC).

However, aeronautical charts may not reflect pertinent local information. Ultimately, it

is the PIC’s responsibility to maintain the minimum safe altitudes required by § 91.119.

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

persons (persons other than the PIC or VO), vessels, vehicles, and structures 

unless:

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

from 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 land

owner/controller has granted permission and the PIC has made a safety

assessment of the risk of operating closer to those objects and;

c. operations near the PIC or VO do not present an undue hazard to the PIC or

VO, per § 91.119(a).

30) 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 prior to the beginning

of every flight.

31)Safe Mobile Operation Of The DJI Inspirer 1 UAS.

The DJI Inspire 1 UAS may be safely operated by a Pilot-in-Command (PIC) and safety

observer co-located with a GCS on a mobile vehicle or watercraft, in order to efficiently perform

aerial acquisition operations of large areas. additional limitations and requirements apply to 

mobile operations of the DJI Inspire 1 UAS, including the following:

The driver/operator of the mobile vehicle must be licensed and fully understand his/her

role in the operation.

The mobile vehicle is a custom built 3 seat vehicle with a dedicated driver, observer, 

PIC. The PIC seat is elevated on the vehicle for better line of sight with no obstructions

of the UAS and is equipped with internal communications for all three positions

Equipment and personnel positioning within the vehicle is predetermined upon by the

team. Each team member must use appropriate safety restraint equipment, and such

equipment should not interfere with safe flight.

The PIC must have ready communication with the driver/operator of the mobile vehicle,
27

as well as the safety observer. If 3 way communications is lost the operation will be 

terminated.

GCS software must be configured for constant updating of GCS position on the map

overlay, and the PIC must be kept aware of mobile vehicle position. The GCS must be

mounted or fixed to the mobile vehicle to ensure that no excess movement will shift the

GCS during operations.

The route of the mobile vehicle must be determined prior to operation. The PIC must

ensure that no part of the route will obscure the safety observer’s view or cause any

physical obstacles or obstructions to any member of the flight team.

The Area of Interest (AOI) must be large enough to warrant mobile operations, and the

UA cannot be allowed to exit the AOI under any circumstance. The only change to the

standard operating procedures (SOP’s) with mobile operations must be an update of the

LOL (Loss of Link) site. Mobile operations are only permitted if suitable LOL sites

within 500 ft. of the PIC at all times. The entire AOI must also meet the “sterile

environment” of a static site of operation, otherwise mobile operations are prohibited.

 32)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.
28

2. Reasons Why An Exemption From The Requirements Of

Section 61.113(a) And (b) Would Not Adversely Affect 

Safety.

HAAI submits that the equivalent level of safety established by Section 61.113(a) and

(b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless 

that PIC has demonstrated, through the DJI Inspire 1 UAS training and currency requirements,

that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

Considering HAAI’s proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary

to safely operate the DJI Inspire 1 UAS, HAAI submits that the additional manned airmanship

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

necessary for HAAI’s specific proposed flight operations.

Additionally, 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).

As in Exemption No. 11109, HAAI will not allow any PIC to operate the DJI Inspire 1

UAS unless that PIC has demonstrated through the DJI Inspire 1 UAS training and currency

requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.
29

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, HAAI will ensure that the DJI Inspire 1 UAS is in an airworthy condition

based upon the aircraft’s conformity to its type design, including compliance with its operating

documents (i.e., the DJI Inspire 1 User Manual and the DJI Inspire 1 System User/safety Manual,

and that the UAS is in a condition for safe flight, as stated in the conditions and limitations

contained herein.

Notably, the similar DJI Phantom 2 UAS was the subject of a previous Grant of

Exemption from Section 91.7(a) (Exemption No. 11153). 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).

4. Reasons Why An Exemption From The Requirements Of

Section 91.121 Would Not Adversely Affect Safety.

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

the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS

equipment and a radio communications telemetry data link, which downlinks from the UAS to 

the GCS for active monitoring of the flight path and altitude. This altitude information,

combined with HAAI’s operation of the DJI Inspire 1 UAS within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude

information will be generated by GPS equipment installed onboard the aircraft. Prior to each

flight, a zero altitude initiation point is automatically established by the UAS.

The FAA has previously granted relief from Section 91.121 specific to UAS, in
30

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).

5. Reasons Why An Exemption From The Requirements

Of Section 91.171(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 91.171(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS;

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

operations. Accordingly, HAAI will ensure that it will safely operate the battery powered DJI 

Inspire 1 UA during daylight hours in VMC conditions, under VFR, with enough battery power 

to fly for a total duration of 17 minutes to the first point of intended landing and, assuming

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

Similar to the FAA’s Grant of Exemption No. 11109, HAAI hereby submits that the

technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight

operations; and the location of the proposed operations, will ensure an equivalent level of safety

established by 14 C.F.R. Section 91.171(b). Furthermore, an equivalent level of safety will be

ensured as the DJI Inspire 1 UAS provides visual warnings to the PIC at the GCS when the UA 

battery power is low.

Significantly, previous exemptions granted by the FAA concerning Section 91.171

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 91.171, including Exemption Nos. 2689, 5745, and

10650. Moreover, the FAA has previously granted relief from Section 91.171 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,
31

11136, 11138).

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, HAAI submits that an 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 HAAI will use

FAA qualified technicians to perform maintenance, alterations, or preventive maintenance on 

the UAS using the methods, techniques, and practices prescribed in the manufacturer’s

user/safety manual. Furthermore, HAAI will document and maintain all maintenance records

for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the manufacturer’s

user/safety manual, HAAI will maintain the equivalent level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). The DJI Inspire 1 System user/safety Manual sets

forth suggested requirements for the UA, including preflight inspections, as well as scheduled

maintenance after every 50 flight hours.

Likewise, the exemption sought will not adversely affect safety because HAAI will use

FAA qualified technicians to perform maintenance, alterations or preventive maintenance on the

UAS using the methods, techniques, and practices prescribed by the manufacturer’s user/safety 

manual. The DJI Inspire 1 System user/saftey Manual procedures for inspection, firmware 

upgrades, motor testing, and motor replacement.

A complete description of the DJI Inspire 1 UAS maintenance requirements is set forth

in the DJI Inspire 1System usre/safety Manual, attached hereto as Attatchment A contains

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).
32

Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI 

Inspire 1 UAS will be performed by FAA qualified technicians, which will document and

maintain maintenance records for the UAS.

Significantly, previous exemptions granted by the FAA concerning the DJI Inspire 1UAS

and 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 HAAI’s proposed operating limitations, the DJI Inspire 1 User

Manual, and the technical aspects of the DJI Inspire 1 UAS, HAAI 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).

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, HAAI requests that the FAA

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

such safety standards that the Administrator finds necessary to establish a level of safety

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

91.7 (a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
33

Such special conditions will permit HAAI’s safe operation of the UA for the limited purpose of

conducting aerial acquisitions over certain rural 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 HAAI’s intended operation of the DJI Inspire 1 UAS, which 

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

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a)

& (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).
34

F. A Summary That Can Be Published In The Federal

Register, stating: The Rules From Which HAAI 

Seeks Exemption:

HAAI, Inc. seeks exemption from the requirements of 14 C.F.R Sections 45.23 

61.113(a)&(b), 91.7(a), 91.121, 91.171(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 HAAI Seeks:

This exemption will permit HAAI, Inc. to commercially operate an Unmanned Aircraft

System (UAS) for the purpose of conducting aerial acquisitions , research and inspections 

over certain rural areas of the United States.

G. Any Additional Information, Views, Or Arguments

Available To Support HAAI’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, HAAI’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, HAAI 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, HAAI 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 acquisitions over certain rural areas of the United States
35

for compensation or hire. 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 HAAI to safely, efficiently, and economically

operate the DJI Inspire 1 UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, HAAI respectfully requests that the

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

45.23, 61.113(a) & (b), 91.7(a), 91.121, 91.171(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and

91.417(a) & (b), and permit HAAI to operate the DJI Inspire 1 UAS commercially for the 

purpose of conducting aerial acquisitions , research and inspections over certain rural areas of

the United States.

Dated: January 30, 2015

Respectfully submitted,

Craig Van Camp (president)

High Adventure Air,Inc

8735 mills macon hwy 

Tecumseh,MI 49286

517-605-3129

cvancamp@me.com
36