Lockheed Martin Aeronautics Company 

86 South Cobb Drive Marietta, GA 30063 

Coleen Thornton 

LOCKHEED MARTIN=* 

August 24,2015 

Reference CAP 15-052 

Aviation Safety and Airworthiness- Engineering and Technical Operations 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Subject: Lockheed Martin Aeronautics Exemption Request for Section 333 of FAA Modernization and 

Reform Act of2012 

Dear Sir or Madam, 

Lockheed Martin Aeronautics 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate 

an Unmanned Aircraft System (UAS) pursuant to Section 333 of the FAA Modernization and Reform Act 

of2012 (FMRA). This exemption will permit Lockheed Martin Aeronautics to operate a UAS for the 

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

Use And Interests Of The Petitioner 

The objective of Lockheed Martin Aeronautics' aerial video and photography operations is to provide high 

quality imaging for a variety of commercial uses. 

Background 

Lockheed Martin Aeronautics seeks an exemption to operate DJI systems within the national air space 

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

Control Station (GCS) utilizing electronic tablet or smart phone 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 45 knots. The DJI Inspire 1 UAS is equipped with four main 

rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1 that will be operated by Lockheed Martin Aeronautics 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, Lockheed Martin Aeronautics, pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircrqft Systems, hereby petitions the Administrator to commercially operate 

the DJI Inspire 1 UAS in the 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)(l), 91.409(a)(l) & (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, Lockheed Martin Aeronautics operation of the DJI Inspire I UAS meets the 

conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance 

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

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Accordingly, Lockheed Martin Aeronautics requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. 

Lockheed Martin Aeronautics submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Lockheed Martin Aeronautics will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, Lockheed Martin Aeronautics 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 Lockheed Martin Aeronautics 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, by meeting minimum flight- hour 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, aircraft, vehicles and structures. 

Lockheed Martin Aeronautics 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, Lockheed Martin Aeronautics submits that we will ensure that the U AS is in 

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

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), and that the 

aircraft are in a condition for safe flight. 

Lockheed Martin also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude 

information ofDJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) 

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

active monitoring of the flight path. This altitude information, combined with Lockheed Martin 

Aeronautics' operation of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, Lockheed Martin Aeronautics seeks an exemption from the requirements of Section 

91.151 (b), entitled Fuel requirements for flight in VFR conditions. Lockheed Martin Aeronautics submits 

that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight hours in visual 

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

total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal 

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

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

support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

Lockheed Martin Aeronautics 

Aviation Safety and Airworthiness 

86 South Cobb Drive 

Marietta, GA 30063-0579 

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B. The Specific Sections Of 14 C.F.R. From Which Lockheed Martin Aeronautics Seeks Exemption. 

B.l. Lockheed Martin Aeronautics 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 

oremployrnentif--

(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. 

B.2. Lockheed Martin Aeronautics 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. 

B.3. Lockheed Martin Aeronautics 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 ofthat aircraft, as the 

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

(!) 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; 

(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. 

B.4. Lockheed Martin Aeronautics 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. 

B.S. Lockheed Martin Aeronautics 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[.] 

B.6. Lockheed Martin Aeronautics 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)(l), states the following: 

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

rebuilding, or alteration unless--

(!) It has been approved for return to service by a person authorized under§ 43.7 of this chapter[.] 

B.7. Lockheed Martin Aeronautics Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

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

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

preceding 12 calendar months, it has had --

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(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. 

B.S. Lockheed Martin Aeronautics 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 ofthe 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. 

(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)(l) 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 Lockheed Martin Aeronautics Seeks And The Reason Lockheed Martin 

Aeronautics Seeks The Relief. 

C.l. Extent Of Relief Lockheed Martin Aermiautics Seeks And The Reason Lockheed Martin 

Aeronautics 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 61.1 13(a) and (b) state that a private pilot 

may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. 

As set forth more fully below, Lockheed Martin Aeronautics submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the UAS unless that PIC has met certain flighthour and currency requirements, demonstrating 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. 

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Further, Lockheed Martin Aeronautics submits that all flights of a Dn Inspire 1 UAS, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to Lockheed Martin Aeronautics business; 

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

C.2. Extent Of Relief Lockheed Martin Aeronautics Seeks And The Reason Lockheed Martin 

Aeronautics 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 

Lockheed Martin Aeronautics to determine that the Dn Inspire 1 UAS is in airworthy condition prior to 

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

Maintenance Log, and Dn Inspire 1 Instruction Manual). 

Lockheed Martin Aeronautics seeks the requested relief because the Dn Inspire 1 UAS does not require an 

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

Aeronautics will ensure that the Dn Inspire 1 UAS is in an airworthy condition based upon its compliance 

with the operating documents (i.e., Monthly Maintenance Log, and Dn Inspire 1 Instruction Manual) prior 

to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below. 

C.3. Extent Of Relief Lockheed Martin Aeronautics Seeks And The Reason Lockheed Martin 

Aeronautics Seeks Relief From Section 91.121. 

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

Dn Inspire 1 UA, which utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UAS 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), Lockheed Martin Aeronautics seeks the requested 

relief because Dn 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 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. 

C.4. Extent Of Relief Lockheed Martin Aeronautics Seeks And The Reason Lockheed Martin 

Aeronautics 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 I UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to 

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

minutes. Lockheed Martin Aeronautics seeks the requested relief because without an exemption from 

Section 91.151 (b), the flight time duration of the battery powered DJI Inspire 1 UA will severely constrain 

the practicality of any aerial video or still photo flight operations that Lockheed Martin Aeronautics 

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications and operating documents ofthe DJI Inspire I, 

and Lockheed Martin Aeronautics' proposed operating limitations, ensure that Lockheed Martin 

Aeronautics will safely operate the battery powered DJI Inspire I 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 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. 

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C.S. Extent Of Relief Lockheed Martin Aeronautics Seeks And The Reason Lockheed Martin 

Aeronautics Seeks Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (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, Lockheed Martin Aeronautics requests relief from these Sections because 

DJI Inspire 1 UAS does not require airworthiness certificates. As set forth more fully below, the DJI Inspire 

1 UAS meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Lockheed Martin Aeronautics will use trained technicians to perform maintenance, 

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

in UAS operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 User Manual). 

Furthermore, Lockheed Martin Aeronautics will document and maintain all maintenance records for the 

DJI Inspire 1 UAS. 

D. The Reasons Why Granting Lockheed Martin Aeronautics 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 Lockheed Martin Aeronautics to 

safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, 

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 Lockheed Martin Aeronautics' proposed operation of the DJI Inspire 1 UAS will 

be realized without implicating any privacy issues. 

D.l. The Public Will Benefit From Decreased Congestion Of The NAS. 

DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the 

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

needed to perform aerial video and photography, 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 oflife 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 UAs do 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. 

D.2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS. 

Conducting aerial video and photography 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 produces 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 ofleaded aviation fuel. The DJI 

Inspire 1 UA, while reducing the carbon footprint of aerial video and photography, also eliminates noise 

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

engine. 

By using a DJI Inspire 1 UAS to perform aerial video and photography, 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 approximately 2 pounds 11 ounces 

and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 

6 
inches respectively, widths of 16 inches and 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 of34 feet, and a fuel capacity of 180 gallons). 

D.3. Performing Aerial Video and Photography 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 similar aerial operations. As such, operation of a DJI Inspire 1 UAS will allow 

United States based companies, like Lockheed Martin Aeronautics, 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. 

D.4. There Are No Privacy Issues. 

Similar to the manned aerial video and photography flight operations that have been conducted for decades, 

Lockheed Martin Aeronautics' 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 compliance with operating documents 

(i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

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

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which Lockheed Martin Aeronautics Seeks Exemption. 

E.l. Reasons Why DJI Inspire 1 UAS Meet The Conditions Of The FAA Modernization and Reform 

Act of2012 (FMRA) Section 333. 

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

aircraft (UA) and its operation, Lockheed Martin Aeronautics' operation of a DJI Inspire 1 UAS meets the 

conditions ofFMRA 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.--ln 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). 

7 
(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, Lockheed Martin Aeronautics submits that the DJI Inspire I UAS can operate 

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

Inspire I 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 I 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 I UAS are set forth by DJI Inspire I Specifications 

(Appendix A). 

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

Remain Within A Defined Operational Area. 

The DJI Inspire I 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 I UAS is provided at 

pages 12-16 and 45-50 of the DJI Inspire I User Manual, attached hereto as Appendix B. 

iii. DJI Inspire 1 UAS Is 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 I UA will remain stationary in flight, for 3 seconds 

or more. If after 3 seconds, the UAS does not reacquire control link data from the GCS, the UAS 

will assume that the Control Link is lost and the UA 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 UAS are set forth at through pages 13 

through 15 of the DJI Inspire 1 User Manual. 

iv. DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications ofDJI Inspire I GCS and flight control 

software is provided at pages 40 through 47 of the DJI Inspire I User Manual. 

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. 

Lockheed Martin Aeronautics will only utilize certificated pilots 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 OfDJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Lockheed Martin Aeronautics proposes to commercially operate the DJI Inspire 

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

States, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the 

operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: the DJI 

Inspire I Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition 

or a petition to amend this grant. 

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

video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 45 knots. 

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

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC.. All altitudes reported to A TC 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 frrst person view (FPV) goggles 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 flight 

instruments, but may relay radio communications. 

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

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

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

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

Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator 

may update or revise its operating documents. It is the operator's responsibility to track such revisions and 

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

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

operator determines that any update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS 

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

operating documents. 

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

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

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

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

and alterations must be properly documented in the aircraft records. 

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

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The 

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

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

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

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

replacement, inspection, and life limit requirements. 

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

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in service, 

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

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

9 
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. 

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 UAS 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 UAS 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 NOT AM as required by the operator's CO A. The letter 

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

21. The UAS 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 UAS loses communications or loses its GPS signal, it must return to a pre- determined location 

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

23. The PIC must abort the flight in the event ofunpredicted 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 

UAS with 25% battery power remaining. 

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

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also 

require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not 

less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude and potential transponder 

requirements. 

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

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

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

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

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

oversight agency requirements. 

10 
28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

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

available to the Administrator or any law enforcement official upon request. 

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

at all times. 

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

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

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

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

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

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.!!ov. 

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

Adversely Affect Safety. 

Lockheed Martin Aeronautics 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, by meeting minimum flight-hour and currency requirements, that the PIC is able to 

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

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

Considering Lockheed Martin Aeronautics' proposed area of operations and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

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

operate the UAS, Lockheed Martin Aeronautics submits that the additional manned airmanship experience 

of a commercially certificated pilot would not correlate to the airmanship skills necessary for Lockheed 

Martin Aeronautics' specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113 (a) and (b) specific to U AS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 

11160, 11161). 

Lockheed Martin Aeronautics will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire I UAS training and 

11 
currency requirements, that the PIC is able to safely operate UAS in a manner consistent with this 

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

people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 

25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption). In addition to 

the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in 

compliance with applicable regulations will ensure an equivalent level of safety during Lockheed Martin 

Aeronautics' proposed operations. The Administrator has held that prior documented flight experience that 

was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: 

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

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

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

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

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

UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum 

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

the 10 hours of multi-rotor time and the 10 hours may be included in the total25 hours ofUAS rotorcraft 

time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely 

conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience 

that was obtained in compliance with applicable regulations would satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is 

required to operate the U AS with appropriate distances in accordance with 14 C.F .R 91.119. 

Exemption No. 11138 at page 15. Accordingly, Lockheed Martin Aeronautics will ensure safe operations 

by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

E.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, Lockheed Martin Aeronautics will ensure that the DJI Inspire 1 UAS is in an airworthy condition 

based upon the UAS's compliance with its operating documents and as stated in the conditions and 

limitations herein. 

Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

E.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 ofDJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio 

12 
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 Lockheed Martin Aeronautics' 

operation ofDJI Inspire I UAS within visual UAS line of sight, at or below 500 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 at ground level. 

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

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

11067,11080,11109,11112,11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161). 

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

Adversely Affect Safety. 

A grant ofthis exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of(l) the technical specifications ofDJI Inspire 1 UAS; (2) the limitations on the 

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

Martin Aeronautics will ensure that it will safely operate the battery powered DJI Inspire 1 UA during 

daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to 

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

minutes. 

Here, as in Exemption No. 11109, the technical specifications ofDJI 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 91.15l(b). Furthermore, safety will be ensured as DJI Inspire 1 

UAS provides audible and visual warnings to the PIC at the GCS when the UA experiences low battery 

voltage, the first warning occurring at approximately 33% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS will 

descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in 

Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

E.6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 

In seeking this exemption, Lockheed Martin Aeronautics submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because Lockheed Martin Aeronautics 

will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Lockheed Martin Aeronautics 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 operating documents, Lockheed Martin 

Aeronautics will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(l), 

and 91.409(a)(2). A copy ofDJI Inspire 1 User Manuals are attached hereto as Appendix B; a copy ofDJI 

Inspire 1 UAS Maintenance Log is attached hereto as Appendix C. 

13 
Likewise, the exemption sought will not adversely affect safety because Lockheed Martin Aeronautics will 

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

the methods, techniques, and practices prescribed by the operating documents. 

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

91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed by trained 

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

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (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 Lockheed Martin Aeronautics' proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1 UAS, Lockheed Martin Aeronautics submits that safety will 

not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and 

(a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063,11064,11065,11066,11067,11080,11109,11110,11112,11136,11138,11150,11153,11156, 

11157,11158,11159,11160, 11161). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. 

§ 21.16 entitled Special Conditions, Lockheed Martin Aeronautics 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 fmds necessary to establish a level of safety equivalent to that established by 14 C.F .R. Part 

21, SubpartH, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (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 Lockheed Martin Aeronautics 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, 

91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

14 
F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

Lockheed Martin Aeronautics Seeks Exemption: 

The Rules From Which Lockheed Martin Aeronautics Seeks Exemption: 

Lockheed Martin Aeronautics 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 OfTbe Exemption Lockheed Martin Aeronautics Seeks: 

This exemption will permit Lockheed Martin Aeronautics to commercially operate an Unmanned Aircraft 

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

States. 

Any Additional Information, Views, Or Arguments Available To Support Lockheed Martin 

Aeronautics' Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012(FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain U AS may operate safely in the NAS. 

As such, Lockheed Martin Aeronautics' 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, Lockheed Martin Aeronautics will operate the Dn 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. 

15 
Conclusion 

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

Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation 

of the Dn Inspire 1 U AS 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 of2012, while also advancing the interests of the public, by allowing Lockheed Martin Aeronautics to 

safely, efficiently, and economically operate the Dn Inspire 1 UAS commercially within the NAS. 

In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, 

Section 333, Lockheed Martin Aeronautics 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)(l) & (a)(2), and 91.417(a) & (b), and permit Lockheed Martin 

Aeronautics to operate the Dn Inspire 1 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Dated: August 24,2015 

Appendices: 

A- DJI Inspire 1 Specifications Sheet 

B-Dn Inspire 1 User Manual 

C - DJI Inspire 1 Monthly Maintenance Log 

16 

Respectfully submitted, 

Coleen Thornton 

Lockheed Martin Aeronautics 

Aviation Safety and Airworthiness 

83 S. Cobb Drive 

Marietta, Georgia 30063-0579 
APPENDIX A 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Lockheed Martin Aeronautics only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which 

will not allow flight into controlled airspace. Parameters can also be set to limit tlight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices) 

2.2 DJI Inspire 1 

2.2 .1 Aircraft 

2.2.1.1 Model- T600 

2.2.1.2 Weight (Battery Included)- 6lbs 7.529loz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode)- Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4MaxAngularVelocity-Pitch: 300°/s; Yaw: 150°/s 

2.2.1.5 Max Tilt Angle - 3 5° 

2.2.1.6 Max Ascent Speed- 5m/s 

2.2.1. 7 Max Descent Speed- 4m/s 

2.2.1.8 Max Speed- 22m/s (A TTl mode, no wind- NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude - 4500m 

2.2.1.10 Max Wind Resistance- lOm/s 

2.2.1.11 Max Flight Time -Approximately 18 minutes 

2.2.1.12 Motor Model- DJI 3510 

2.2.1.13 Propeller Model- DJI 1345 

2.2.1.14 Operating Temperature Range -14°F to 104°F (-10°C to 40°C) 

2.2.1.15 Dimensions - 17 W' x 17 %" x 12" 

2.2.2 Gimbal 

2.2.2.1 Model-ZENMUSE X3 

2.2.2.2 Output Power (with camera)- Static: 9W; In Motion: 11 W 

2.2.2.3 Operating Current- Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.03° 

2.2.2.5 Mounting - Detachable 

2.2.2.6 Controllable Range- Pitch: -90° to +30°; Pan: ±320° 

2.2.2. 7 Mechanical Range- Pitch: -125° to 45°; Pan: ±330° 

2.2.2.8 Max Controllable Speed- Pitch: 120° /s; Pan: 180° /s 

2.2.3 Camera 

2.2.3.1 Name- X3 

2.2.3.2 Model- FC350 

2.2.3.3 Total Pixels- 12.76M 

2.2.3.4 Effective Pixels- 12.4M 

2.2.3.5 Image Max Size- 4000x3000 

2.2.3.6 ISO Range -100-3200 

2.2.3.7 Field of View- 94° 

2.2.3.8 CMOS- Sony EXMOR 112.3" 

2.2.3.9 HD Video Recording- UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 

1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

2.2.3.10 Operating Temperature Range- 32°F- 104°F (0°C- 40°C) 

17 
2.2.4 Transmitter 

2.2.4.1 Name- Cl 

2.2.4.2 Operating Frequency- 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed)- 2000m 

2.2.4.4 Output Power- 9W 

2.2.4.5 Operating Temperature Range- 14°F to 104°F (-10°C to 40°C) 

2.2.4.6 Battery- 600mAh LiPo 2S 

18 
APPENDIXB 

Inspire 1 User Manual (EN) v1.4 

http://www .dji.com/product/inspire-1/download 

19 
APPENDIXC 

DJI INSPIRE 1 Maintenance Log 

MONTHLY MAINTENANCE LOG 

Other: 

20