### August 19, 2015

Exemption No. 12520 Regulatory Docket No. FAA

– 20 15

– 2245

Mr. Brendan Carlisle Interior Pixels, Inc. 5640 Via Bonita Newbury Park, CA 91320

Dear Mr. Carlisle : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter dated May 26, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Interior Pixels, Inc. ( hereinafter petitioner or operator ) for an ex emption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.
Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 and DJI Inspire 1

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

### 2

finds that relie f from 14 CFR part 21
, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision
You have requested to u se a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that th e UAS operation enabled by this exemption is in the public interest.
Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Interior Pixels, Inc. is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operat e a UAS to perform aerial data collection

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

Conditions and Limitations

In this grant of exemption, Interior Pixels, Inc. is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 and DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.
2. Operations for the purpose of closed

- set motion picture and television filming are not permi tted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;
e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised

### 4

documents to the Administrator or any law enforcement official upon request. The operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.
, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.
, inoperable comp onents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and main taining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

### 5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (trai ni ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operat ions may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport sy mbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management mus t be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibi ted from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to co nduct operations that cannot be conducted under the terms of the attached COA

.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) ma rkings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

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

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

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

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

e. Name and certific ate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available t o the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essenti al to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.
Unless otherwise specifie d in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded.
Sincerely, / s/ John S. Duncan Director, Flight Standards Service

EnclosuresUNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC
Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

INTERIOR PIXELS, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS
SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 2 AND DJI INSPIRE 1 UNMANNE D

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012
(PUBLIC LAW 112

- 95)

Submitted on May 26, 2015

Brendan Carlisle

Interior Pixels, Inc.

5640 Via Bonita
Newbury Park, CA 91320
Tel: (818) 427

- 9863

TABLE OF CONTENTSGLOSSARY OF ABBREVIATIONS...................................................................................3

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

INTRODUCTION A ND INTERESTS OF PETITIONER....................................................4

BACKGROUND................................................................................................................... .4

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH IN TERIOR PIXELS SEEKS EXEMPTION.................................................................8

THE EXTENT OF RELIEF INTERIOR PIXELS SEEKS AND THE

REASON INTERIOR PIXELS SEEKS THE RELIEF.........................11

THE REASONS WHY GRANTING INTERIOR PIXEL’S REQUES T

WOULD BE IN THE PUBLIC INTEREST .........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT INTERIOR PIXEL’S REQUEST.........34

CONCLUSION.................................................................................................. ..................35

APPENDICES........................................................................................37

3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control
ATO Air Traffic Organization

AV Aerial VehicleCFR Code of Federal Regulations

COA Certificate o f Authorization

FAA Federal Aviation Administration
FAR Federal Aviation Regulation

GCS Ground Control Station
GPS Global Positioning System

LOL Loss of Link
NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SOP Standard Operating Procedures

UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules

VLOS Visual Line of Site
VMC Visual Meteorological Conditions

VTOL Vertic al Takeoff and Landing

4

SUMMARY

Interior Pixels seeks exemption from the requirements of 14 C.F.R §§
61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),
and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of
the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permitInterior Pixels to operate an Unmanned Aircraft System (UAS) for the
commercial purpose of conducting aerial real estate and landscape video and p hot ography for the
purpose of producing real estate videos and commercials.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Interior Pixels provides its clients with expertise and knowledge in various aspects of aerial video and
photography. The objective of I nterior Pixel ’s aerial video and photography operations is to
provide low cost, high quality imaging for a variety of commercial and residential

customers.

BACKGROUND

Unmanned Aircraf t Systems: DJI Phantom 2 , DJI Inspire 1 UASs

Interior Pixels seeks an exe mption to operate DJI systems for
compensation or hire within th e NAS. The DJI Phantom 2 and DJI Inspire 1 are
vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control
Station (GCS) utilizing electronic tablet or smart p hone systems. The DJI Phantom 2
has a maximum gross weight of approximately 2 pounds 11 ounces, while having
a length of 16 inches , width of 16 inches, height of 8 inches, and a maximum speed of

5
approximately 29 knots. The DJI Inspire 1 has a maximum gross w eight of 6 pounds 7.5
ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a
maximum speed of approximately 42 knots. The DJI Phantom 2 and DJI Inspire
1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered

electric motors.

The DJI Phantom 2 and DJI Inspire 1 UAs that will be operated by

Interior Pixels 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 inacc ordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Interior Pixels , pursuant to the provisions of the Federal
Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of
2012 (FM RA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially o perate the DJI Phantom 2 , DJI
Inspire 1 UASs in the National Airspace System (NAS), and for an exemption from the
requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
In consideration of the speed, weight, size, and limited operating area associated

with the unmanned aircraft and i ts operation, Inte rior Pixels ’s operation of DJI

Phantom 2 and DJI Inspire 1 UASs meets the conditions of FMRA Section 333
and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R.
Part 21, Subpart H.

6
Accordingly, Interior Pixels requests r elief from Sections 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth
requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Interior Pixels submits that the requested relief is proper since an
equivalent level of safety wil l be ensured. Interior Pixels will use experienced
personnel or technicians to perform maintenance, alterations, or preventive maintenance on
the UASs using the methods, te chniques, and practices prescribed in the operating

documen ts (i.e., the Interior Pixels Aerial Operations Manual, Monthly

Mainten ance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual).

Furthermore, Interior Pixels will document and maintain all maintenance recordsfor the DJI Phantom 2 and DJI Inspire 1 UASs.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by Interior Pixels to
the extent necessary t o 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

o perate the DJI Phantom 2 and DJI Inspire 1 UASs in a manner consistent with
this exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and structures.

Interior Pixels seeks relief from Section 91.7(a ), entitled Civil aircraft

airworthiness, b ecause the DJI Phantom 2 and DJI Inspire 1 UASs do not require
an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Interior Pixels submits that it will ensur e that the DJI Phanto m 2 and

7
DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that
the UASs are in compliance with the operat ing documents (i.e., the Interior Pixels Aerial Operations
Manual, Monthly Mai ntenance Log, and DJI Phantom 2 a nd DJI Inspire 1 Instruction Manual),

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

Interior Pixels also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settin gs, as the DJI Phantom 2 and DJI Inspire 1 UAs

will not have a typical barometric altimeter onboard. However, altitude information of the

DJI Phantom 2 and DJI Inspire 1UAs will be provided to the PIC via Global
Positioning System (GPS) equipment and radio communications telemetry data link, which

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with Interior Pixel ’s operation of the DJI Phantom 2and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will

ensure a level of safety equivalent to Section 91.121.
Additionally, Interior Pixels seeks an exemption from the requirements
of Section 91.151(b), entitled Fuel requirements for f light in VFR conditions Interior Pixels
submits that safety will not be affected by operation of the DJI Phantom 2
and 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.

8

In accordance with 14 C. F.R. § 11.81, Interior Pixels provides the
following information in support of its petition for exemption:

A. Name And Address Of T he Petitioner.
The name and address of the Petitioner and point of contact is:

Brendan Carlisle

Interior Pixels, Inc.

5640 Via Bonita
Newbury Park CA 91320
Tel: (818) 427

- 9863

E mail: bcarlisle@interiorpixels.com
B. The Specific Sections Of 14 C.F.R. From W hich Interior Pixels Seeks

Exemption.

1. Interior Pixels 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 passeng ers or property for compensation or hire.

2. Interior Pixels 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 ai rcraft unless it is in an airworthy condition.

9

3. Interior Pixels 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;
(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting of an appropriate

available station; or
(iii) In the case of an airc raft not equipped with a radio, the elevation of the
departure airport or an appropriate altimeter setting available before

departure.

4. Interior Pixels Seeks Exemption From The Requirements Of
Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection
(b), states the following:
(b) No person may begin a flight in a rotorcraft under VFR conditions unless
(considering wind and forecast weather conditions) there is enough fuel to fly
to the first point of intended landing and, assuming normal cruising speed, to
fly after that for at least 20 minutes.

5. Interior Pixels Seeks Exemption From The Requirement Of
Section 91.405(a).
Section 91.405, entitled Maintenance required, subsection (a), state s 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[.]

10

6. Interior Pixels 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. Interior Pixels 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

-- (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. Interior Pixels 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) Record s 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 app liance of an aircraft. The records mustinclude

--

11
(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 t he 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 airf rame, 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)(1) of this section shall be retained

unti l 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.

12

C. The Ext ent Of Relief Interior Pixels Seeks And The Reason Interior Pixels

Seeks The Relief.

1. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior Pixels
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 flig ht operations for compensation or hire.
This relief is requested since the limitations set forth in Section 61.113(a) and (b)
state that a private pilot may, for compensation or hire, act as PIC of an aircraft in
connection with any business or employment if: (1) The flight is only incidental to that
business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.As set forth more fully below, Interior Pixels submits that an equivalent
level of safety will be mai ntained because no PIC will be allowed to operate the DJI

Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour
and currency requirements, demonstrating that the PIC is able to safely operate either the

DJI Phantom 2 or 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, Interior Pixels submits that a ll flights of the DJI Phantom 2
and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this

13
Petition: (1) will be incidental to Interior Pixel ’s business; and (2) will not carry
passengers or property for compensation or h ire.

2. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior Pixels
Seeks Relief From Section 91.7(a).
Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent requ ired to allow Interior Pixels to determine that the DJI Phantom 2
and DJI Inspire 1 UASs are in airworthy condition prior to every flight by
ensuring that the UAS is in compliance with the operat ing documents (i.e., the Interior Pixels

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2
and DJI Inspire 1 Instruction Manual).

Interior Pixels seeks the requested relief because the DJI Phantom 2
and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance
with 14 C.F.R. Part 21, Subpart H. Therefore, Interior Pixels will ensure that the

DJI Phantom 2 and DJI Inspire 1 UASs are in airworthy condition based upon its
compliance with the operating documen ts (i.e., the Interior Pixels AerialOperations Manual, Monthly Maintenanc e Log, and DJI Phantom 2 and DJI

Inspi re 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.

3. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior

Pixels Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Altimeter settings, may be required to allow
flight operati ons of the DJI Phantom 2 and DJI Inspire 1 UASs, which utilize a
barometric pressure sensor, GPS equipment, and a radio commu nications telemetry data
link to downlink altitude information from the UA to the PIC at the ground control station
(GCS). Since the FAA requires that any altitude information concerning UAS operations

14
be reported to air traffic control (ATC) in feet a b ove ground level (AGL), Interior

Pixels seeks the requested relief b ecause the DJI Phantom 2 and DJI Inspire
1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local
barometric pressure or field altitude, before each flight.

Consid ering the limited altitude of the proposed operations, relief from 14 CFR
91.121 is sought to the extent necessary to comply with the applicable conditions and
limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are equipped with a
barometric pressure sensor and GPS equipment, which automatically ensures that a ground
level pressure setting will be established prior to each flight, and provides the PIC with

altitude information of the UA on the heads

- up display of the GCS.

4. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior

Pixels Seeks Relief From Section 91.151(b).
Relief from Section 91.151(b) entitled Fuel requirements for flight i n VFRconditions, is requested to the extent required to allow flights of the battery powered DJI

Phantom 2 and DJI Inspire 1 UAs 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. Interior Pixels seeks the requested relief because without an
exemption from Section 91.151(b), the flight time duration of the battery powered DJI

Phantom 2 and DJI Inspire 1 UAs will severely constrain the practicality of any
aerial video or still photo flight op erations that Interior Pixels proposes to
conduct pursuant to this Petition.

15
Significantly, as set forth below, the technical specifications of the DJI Phantom 2

and DJI Inspire 1 UASs, the DJI Phantom 2 and DJI Inspire 1 operating

d ocuments, and Interior Pixel ’s proposed operating limitations, ensure that

Interior Pixels will safely operate the batte ry powered DJI Ph antom 2
and 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
13.5 minutes to the first point of intended landing and, assuming norma l cruising speed, to
fly after that for at least 4.5 minutes.

5. Ext ent Of Relief Interior Pixels Seeks And The Reason Interior

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

Since Sections 9 1.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
only apply to aircraft with an airworthiness certificate, Interior Pixels requests

relief from these Sections because the DJI Phantom 2 and DJI Inspire 1 UASs do
not require airworthiness c ertificates. As set forth more fully below, the DJI Phantom 2
and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operationwithout an airworthiness certificate. Accordingly, Interior Pixels will use trained
technicians to perform maintenance, alterations, or preventive maintenance on the UASs
using the methods, techniques, and practices prescribed in the UAS operating documents
(i.e., the Interior Pixels Aerial Operations Manual, Monthly Maintenance Log,

and DJI Phantom 2 and DJI I nspire 1 Instruction Manual). Furthermore,

Interior Pixels will document and maintain all maintenance records for the DJI

Phantom 2 and DJI Inspire 1 UASs.

D. The Reasons Why Granting Interior Pixel ’s Request Would Be In The

Public Interest; That Is, How I t Would Benefit The Public As A Whole.

16
Granting the present Petition will further the pu blic interest by allowing Interior

Pixels to safely, efficiently, and economically perform aerial video and photography

of real estate and landscape over certain are as of the United States.
Additionally, use of the DJI Phantom 2 and DJI Inspire 1 UASs will
decrease congestion of the NAS, reduce pollution, and provide significant benefits to the

economy. Notably, th e benefits of Interior Pixel ’s proposed operation of the DJI

Phantom 2 and DJI Inspire 1 UASs will be realized without implicating any

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

The DJI Phantom 2 and DJI Inspire 1 UAs are battery powered and serve

as a safe, e fficient, 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 th e use of a DJI Phantom 2 or 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,

conges tion around airports caused by arriving and departing aircraft will be reduced. The

DJI Phantom 2 and DJI Inspire 1 UAs do not require an airport to takeoff or land.
Likewise, a reduction of manned aircraft conducting aerial video and photography

operations would result in fewer aircraft that must be handled by air traffic control during
the ground, takeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Ph antom 2 and DJI Inspire 1 UASs.
Conducting aerial acquisitions with the DJI P hantom 2 and DJI Inspire 1
UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the
levels of air and noise pollution generated during traditi onal aerial video and still
photography flight operations. By using battery power and electric motors, the DJI

Phantom 2 and DJI Inspire 1 UASs produce no air pollution, and is the most
viably environmentally conscious alternative to the cabin class, six cylinder internal
combustion engine aircraft that are typically utilized for aerial video and photography,
while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI

Ph antom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial

operations , also eliminates noise pollution, as the UAs are propelled by battery powered
electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 and DJI Inspire 1 UASs to perform aerial

operations , 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 air craft, the DJI Phantom 2 and DJI Inspire 1 UAs (weighing

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at theirmaximum gross weights with lengths of 16 inches and 17.3 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 co nduct similar operations (weighing approximately
6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel
capacity of 180 gallons).

17
3. Performing Aerial Video and Photography Operations With The DJI

Phantom 2 and DJI Inspire 1 UASs Will Benefit The Economy.
In addition to being safe and effi cient, the DJI Phantom 2 and DJI Inspire
1 UASs are also an economical alternative to using manned aircraft to conduct similar
aerial operations. As such, operat ion of the DJI Phantom 2 and DJI Inspire 1

UASs will allow United States based co mpanies, like Interior Pixels , to remain
competitive and contribute to growth of the U.S. econom y. Specifically, with the
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

Phantom 2 and DJI Inspire 1 UASs is one such technolog y that not only allows
greater operational flexibility compared to manned aircraft, but provides such
flexibility without the high operational cost of a traditional manned aircraft.

By ope rating the DJI Phantom 2 and DJI Inspire 1 UASs, companies such

as Interior Pixels , 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

com mercial use of the DJI Phantom 2 and DJI Inspire 1 UASs, provides a stablework force that increases consumer spending; improves local, state, and federal tax

revenues and; allows companies to invest in research and development in order to remain

competiti ve both in the United States

. 4. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Interior Pixel ’s proposed operat ion of the DJI Phantom 2 and

18
DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2
and DJI Inspire 1 UASs will be operated only in compliance with operating

documen ts (i.e., the Interior Pixels Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual)

which require 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 Ru le From Which Interior Pixels Seeks Exemption.

1. Reaso ns Why The DJI Phantom 2 and DJI I nspire 1 UAs Meet The
Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA)

Section 333.
In consideration of the size, weight, speed, and limited operating area associated

with the unmanned aircraft and i ts operations. Interior Pixel ’s operatio n of the

DJI Phantom 2 and DJI Inspire 1 UASs meet the conditions of FMRA Section
333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,
Subpart H.Section 333 provides authority for a UAS to operate without airworthin ess
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 Genera l.

-- 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 airspac e 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.

19
(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under
subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and
populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a
threat to national security; and
(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems
identified under paragraph (1).
(c) Requirements for Safe Operation.

-- If the Secretary determines under this
section that certain unmanned aircraft systems may operate safely in the
national airspa ce system, the Secretary shall establish requirements for the safeoperation of such aircraft systems in the national airspace system.

20
In seeking thi s exemption, Interior Pixels submits that the DJI Phantom 2
and DJI Inspire 1 UASs can operate safely i n the NAS pursuant to FMRA Section
333, as demonstrated by: (a) the characterist ics of the DJI Phantom 2 and DJI
Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating

limitations.
a. The Specificati ons Of The DJI Phantom 2 and DJI Inspire 1

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 and DJI Inspire 1 UASs do not create a hazard to users
of the NAS or the public, or otherwise pose a threat to national security considering its
size, weight, speed, and operat ional capability.
i. Technical Specificati ons Of The DJI Phantom 2 and DJI

Inspire 1 UASs.
The technical specificati ons of the DJI Phantom 2 and DJI Inspire 1 UASs

are set fo rth by the DJI Phantom 2 and DJI Inspire 1 Specifications and Data

Sheet, attached hereto as Exhibit A and B.

21

ii. The DJI Phantom 2 and DJI Inspire 1 UASs Autonomous
Flight And Navigation Modes Enable The UASs To Remain Within
A Defined Operational Area.

The DJI Phantom 2 and DJI Inspire 1 UASs may be operated in both

manual and fully autonomous flight modes. A complete description of the flight and
navigational mo des of the DJI Phantom 2 and DJI Inspire 1 UASs is provided at

pages 25

- 35 of the DJI Phantom 2 and pages 12

- 16 and 45

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

iii. The DJI Phantom 2 and DJI Inspire 1 UASs Are Designed

For Automatic Return To Home Point Or Hover In The Event Of
Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 and DJI Inspire 1 UAs
will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom

2 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs
will assume that the Control Link is lost and the UAs will return to the home p osition (i.e.,

fail safe mode) via GPS, and will descend to the takeoff position and shutdown.
A complete description of the Failsafe Functi ons of the DJI Phantom 2
UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15

o f the DJI Phantom 2 and DJI Inspire 1 User Manuals, attached hereto as Exhibit

C and D.

iv. The DJI Phantom 2 and DJI Inspire 1 GCS And Its

Operation.
A complete description of the operation and specifications of the DJI Phantom 2

and DJI Inspire 1 GCS an d flight control software is provided at pages 32 through

43 of the DJI Phantom 2 User Manual and pages 40 through 47 of the DJI Inspire

22

1 Us er Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached

hereto as Exhibits C and D.
b. Flight Ope ra tions Of DJI Phantom 2 and DJI Inspire 1 UASs
Are Limited To The Line Of Sight Of A Certificated Pilot in Command
With A Safety Observer.

Interior Pixels will only utilize certificated pilots who possess a currentand valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom

2 and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots
during flight time.

c. Flights Of DJI Phantom 2 and DJI Inspire 1 UASs Will Be
Conducted Pursuant To Specific Operating Limi tations.
In seeking th is exemption, Interior Pixels proposes to commercially
operate DJI Phantom 2 and DJI Inspire 1 UASs for the special purpose of
conducting aerial video and photography over certain areas of United States, pursuant to
the following spec ific 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 gro ss weight: DJI Phantom 2 and DJI Inspire
1 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 photo graphy.
3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.
4. The UA must be operated at an altitude of no more than 500 feet above ground
level (AGL), as indicated by the procedures specified in the operating

documents unless a speci al request is made and approved by ATC. All altitudes
reported to ATC must be in feet AGL.
5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all

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

device ot her than corrective lenses, as specified on the PIC’s FAA

- issued airman

medical certificate.23
6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy
the VLOS requirement as long as the PIC always maintains VLOS capability.
The SO and PIC must be able to communicate verbally at all times. Electronic
messaging or texting is not permitted during flight operations. The PIC must be

designate d before the flight and cannot transfer his or her designation for the
duration of the flight. The PIC must ensure that the SO can perform the
functions prescribed in the operating documents.
8. The SO must not perform any other duties beyond assisting the PIC with seeing
and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible during

UAS operations an d 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 g rant 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 up date or revision would affect the basis upon which the FAA grantedthe 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 re visions 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

funct ional 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 documen ts.

24
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 ac cordance 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 t he authorized person returning theUAS to service.
15. Each UASs operated under this exemption must comply with all manufacturer
Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the
corrective action taken against di screpancies 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 qualif ication 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 m ay
only be conducted during dedicated training sessions. During training,
proficiency, and experience

- building flights, all persons not essential for flight
operations are considered nonparticipants, and the PIC must operate the UA
with appropriate distanc e from nonparticipants in accordance with 14 C.F.R. §

91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §
1.1. All operations must be conducted under visual meteorological conditions
(VMC). If flight at night is required , a special request will be made at the FAA
office closest to proposed area of operations. Flights under special visual flight
rules (SVFR) are not authorized.20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of
agreement with that airport’s management is obtained, and the operation is
conducted in accordance with a NOTAM as required by the operator’s COA.
The letter of agreement with the airport managem ent must be made available to
the Administrator upon request.

25
21. The UA may not be operated less than 500 feet below or less than 2,000 feet
horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

22. If the UA loses com munications or loses its GPS signal, it must return to a predetermined
location within the planned operating area and land or be recovered
in accordance with the operating documents.
23. The PIC must abort the flight in the event of unpredicted obstacles o r
emergencies in accordance with the operating documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and
forecast weather conditions) there is enough power to fly at normal cruising

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

remaining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate
of Waiver or Authorization (COA) prior to conducting any operations under the
grant of exemption. This COA will also require the operator to request a Notice
to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance
with airspace requirements in the ATO issued COA including class of airspa ce,altitude level and potential transponder requirements.
26. All aircraft operated in accordance with the exemption must be identified by
serial number, registered in accordance with 14 C.F.R. part 47, and have
identification (N

- Number) markings in acco rdance with 14 C.F.R. part 45,
Subpart C. Markings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation
and control of the UA must comply with the Federal Communications
Commission (FCC) or othe r appropriate government oversight agency

requirements.
28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be
available to the PIC at the Ground Control Station of the UAS any time the
UAS is operating. These documents must be made availa ble to the
Administrator or any law enforcement official upon request.
29. The UA must remain clear and yield the right of way to all manned aviation
operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all nonparticipating
persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

26

a. Barriers or structures are present that sufficiently protect nonparticipating
persons from the UA and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such
protection. If a situation arises where nonparticipating persons leav e such
protection and are within 500 feet of the UA, flight operations must ceaseimmediately 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 haz ard 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 represen tative 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 Integra tion Office (AFS

- 80) within 24
hours. Accidents must be reported to the National Transportation Safety Board
(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
2. Reasons Why An Exemption From The Requirements Of Section 61.113 (a)
And (b) Would Not Adversely Affect Safety.

Interior Pixels 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 Phant om 2 and DJI Inspire 1 UASs unless that PIC has demonstrated, by
meeting minimum flight

- hour and currency requirements, that the PIC is able to safely

o perate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the
exemption, including evasive and emergency maneuvers and maintaining appropriatedistances from people, vessels, vehicles and structures.
Considering Interior Pixel ’s proposed area of operations, and the
operating limitations set forth

- above; the parallel nature of private pilot aeronautical

27
knowledge require ments to those of commercial pilot requirements (See Exemption No.
11062); and the airmanship skills necessary to safely o perate the DJI Phantom 2

or DJI I nspire 1 UAS, Interior Pixels submits that the additional manned
airmanship experience of a commercia lly certificated pilot would not correlate to the
airmanship skills necessary for Interior Pixel ’s specific proposed flight

operations.
The FAA has previously granted relief from Section 61.113(a) and (b) specific to

UAS, in circumstances similar, in all m aterial 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).

Interior Pixels will not allow any PIC to operate the DJI Phantom 2
or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum
flight

- hour requireme nts or the DJI Phantom 2 or DJI Inspire 1 UAS training and
currency requirements, that the PIC is able to safely o perate the DJI Phantom 2 or

DJI Ins pire 1 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 consis tent
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 requi rements,the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency
purposes).

28
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 Interior Pixel ’s proposed operations. The
Administrator has held that prior documented flight experience that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follow s:
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 an d 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 an d the 10 hours may be included in
the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the
PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for
currency purposes). The FAA finds that at a minimum, the flight

- hour requirements
in Exemption No. 11062 are appropriate to practice and build proficiency in the
skills necessary to safely conduct the petitioner’s proposed operations. The FAA
also finds that prior documented flight experience that was obtained in comp liance
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

experienc e

- building flights the PIC is required to operate the UA with appropriate

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

Exemption No. 11138 at page 15.
Accordingly, Interior Pixels will ensure safe operations by not allowing

any PIC to o perate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has
demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is
able to safely o perate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner
consistent with the exemption, including ev asive 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

becau se prior to every flight, Interior Pixels wil l ensure that the DJI Phantom 2
or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s
compliance with its operating documents and a s stated in the conditions and limitations

herein.
Additionally, the FAA has previously granted relief from Section 91.7(a) specific
to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11 064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons Why An Exemption From The Requirements Of Section 91.121
Would Not Adversely Affect Safety.The equivalent lev el of safety established by Section 91.121 will be maintained

because the altitude informat ion of the DJI Phantom 2 and DJI Inspire 1 UAs will
be provided to the PIC via GPS equipment and a radio communications telemetry data

link, which downlinks from the UA to the GCS for active monitoring of the flight path and

altitude. This altitude information, combined with Interior Pixels ’s operation of

the DJI Phantom 2 and 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. 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 UASs at
ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented herein (e.g. Exemption

30

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 111 53, 11156, 11157, 11158, 11159, 11160, 11161).
5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)
Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Phantom 2 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight
operations; and (3) the location of the proposed flight operations. Accordingly, Interior

Pixels will ensure that it will safely operate the battery powered DJI Phantom 2
and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough
battery power to fly for a total duration of 13.5 minutes to the first point of intended
landing and, ass uming normal cruising speed, to fly after that for at least 4.5 minutes.Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2
and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the

location of the proposed operations, will ensure an equivalent level of safety established by
14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2

and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the

GCS when the U As 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 batter y level, the DJI Phantom and DJI Inspire

1 UASs will descend a nd 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 g ranted for manned

31
aircraft to operate at less than the minimums prescribed in Section 91.151, including
Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief
from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to
those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,
11157, 11158, 11159, 11160, 11161).

6. Reasons W hy 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 th is exemption, Interior Pixels submits that the equivalent
level of safety with regard to t he 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 b e met because Interior Pixels will use trained technicians to perform
maintenance, alterations, or preve ntive maintenance on the UASs using the methods,
techniques, and practices prescribed in the opera ting documents (i.e., the Interior

Pixels Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2
and DJI Inspire 1 Instruction Manual). Further more, Interior Pixels will

document and maintain all maintenance recor ds for the DJI Phantom 2 and DJI

Inspire 1 UASs.

Since the DJI Phantom 2 and DJI Inspire 1 UASs will be inspected as
prescribed by the operati ng documents, Interior Pixels will maintain the
equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and
91.409(a)(2). A c opy of the DJI Phantom 2 and DJI Inspire 1 User Manuals are

attached hereto as Exhibit C and D; a c opy of the DJI Phantom 2 and DJI Inspire 1

UAS Maintenan ce LOG is attached hereto as Exhibit E.

32
Likewise, the exemption sought will not advers ely affect safety because Interior

Pixels will use trained technicians to perform maintenance, alterations or preventive
maintenance on the UAS using the methods, tech niques, and practices prescribed by the
operating documents.
Furthermore, the exemption sought would maintain an equivalent level of safety
established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Phantom 2 and DJI Inspire 1 UASs will be performed by trained technicians.
Maintenance will be documented and maintained utilizing the monthly maintenance log.
Significantly, previous exemptions granted by the FAA concerning Sections
91.405(a), 91.407(a)(1), 91.409 (a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is
not adversely affected when the technical characteristics and operating limitations of theUAS are considered.

In con sideration of Interior Pixel ’s proposed operating limitations, the

operating documents, and the technical aspe cts of the DJI Phantom 2 and DJI

In spire 1 UASs, Interior Pixels submits that safety will not be adversely affected
by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2),
91.409(a)(2), and 91.417( a) and (b). The FAA has previously granted relief specific to
UAS in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012
(FMRA) and 14 C.F.R. § 21.16 entitled Specia l Condi tions, Interior Pixels

33
requests that the FAA prescribe special conditions for the intended operation of the DJI

Phantom 2 and DJI Inspire 1 UASs, which contain such safety standards that the
Administrator finds necessary to establish a level of safety e quivalent to that established by
14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,
91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such
special conditions will permit safe operation of the UAs for the limited purpose of
conducting aerial video and photography over certain areas of the United States for
compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a
threat to national security; and further, provides the authority for such UAS to operate
without airworthiness certification in accordance with any requirements that must be
established for the safe operation of the UAS in the N AS.Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.
§ 21.16, for operati on of the DJI Phantom 2 and DJI Inspire 1 UASs, since the
airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate

safet y 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.

35

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe spe cial conditions for Interior Pixel ’s intended operation of the DJI

Phantom 2 and DJI Inspire 1 UASs, which contain such safety standards that the

Administrat or finds necessary to establish a level of safety equivalent to that established by
14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121,
91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

Fro m Which Interior Pixels Seeks Exemption:

Interior Pixels 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 Th e Nature Of The Exemption Interior

Pixels Seeks:
This exemptio n will permit Interior Pixels to commercially operate an
Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and
photography over certain areas of the United States.
G. Any Additional Information, Views, Or Arguments Available To Support

Interior Pixel ’s Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012
(FMRA) Se ction 333, which directs the Secretary of Transportation to determine if certain
UAS may operate safely in the NAS. As such, Interior Pixel ’s request for
exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R.

Part 11, as set f orth 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 with out airworthiness

certification.

36

As discussed in detail above, Interior Pixels will operate the DJI Phantom

2 and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of
the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Interior Pixels 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 operat ion of the DJI Phantom 2 and DJI Inspire 1UASs commercially, without an airworthiness certificate, for the limited purpose of
conducting aerial video and photography over certain areas of the United States. By
granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate

of the FAA Modernization and Reform Act of 2012, while also advancing the interests of
the public , by allowing Interior Pixels to safely, efficiently, and economically

o perate the DJI Phantom 2 and DJI Inspire 1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Interior Pixels respectfully
requests that the Administrator grant this Petition for an exemption from the requirements

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a ) & (b), and permit Interior Pixels to operate the DJI

Phantom 2 and DJI Inspire 1 UASs commercially for the purpose of conducting

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

Dated: May 26 , 2015

Respectfully submitted,

Interior Pixels, Inc.
/s/ Brendan Carlisle

_________________________ Brendan Carlisle

5640 Via Bonita
Newbury Park, CA 91320
Tel: (818) 427

- 9863
Appendices:

A

– DJI Phantom 2 Specifications Data SheetB

– DJI Inspire 1 Specifications Data Sheet

C

– DJI Phantom 2 Manufacturer’s User Manual

D

– DJI Inspire 1 Manufacturer’s User Manual

E

– Monthly Maintenance Log

37

APPENDIX

– A

DJI PHANTOM 2 TECHNICAL SPECIFICATI ONS

Interior Pixels only utilizes safe and reliable UASs. DJI is an industry leader in

small U AS production. DJI UASs are equipp ed 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 flight to no higher than a predetermined and set altitude as well as to 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)

1.1 DJI Phantom 2

1.1.1 Aircraft

1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery
1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)
1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m
1.1.1.4 Max Yaw Angular Velocity

- 2000/s

1.1.1.5 Max Tilt Angel

- 350

1.1.1.6 Max Ascent Speed

– 6m/s

1.1.1.7 Max Descent Speed

– 2m/s

1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal1.1.2.1 Working Current

– Static: 750mA ; Dynamic: 900mA
1.1.2.2 Control Accuracy

- ±0.030

1.1.2.3 Controllable Range

– Pitch:

- 900

- 00

1.1.2.4 Maximum Angular Speed

– Pitch: 900/s

1.1.4 Transmitter

1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz
1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m
1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW
1.1.4.5 Working Voltage

– 120mA@3.7V
1.1.5 Range Extender

38

1.1.5.1 Operating Frequency

– 2412

- 2462MHz

1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m

1.1.5.3 Transmitter Power

– 20dBm

1.1.5.4 Power Consumption

– 2W

39

APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Interior Pixels only utilizes safe and reliable UASs. DJI is an industry leader in

small U AS production. DJI U ASs are equipp ed 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 flight to no higher than a predetermined and set altitude as well as to limit
fligh t 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/tabletdevices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model

– T600
2.2.1.2 Weight (Batte ry Included)

– 6lbs 7.5291oz (2935g)
2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m
2.2.1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s

2.2.1.5 Max Tilt Angle

- 350

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 (ATTI mode, no wind

– NOT
RECOMMENDED)

2.2.1.9 Max Flight Altitude

– 4500m

2.2.1.10 Max Wind Resistance

– 10m/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

– 140F to 1040F (

- 100C to 400C)

2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” 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: 11W

2.2.2.3 Operating Current

– Stat ic: 750mA; In Motion: 900mA
2.2.2.4 Angular Vibration Range

- ±0.030

2.2.2.5 Mounting

– Detachable2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300

2.2.2.8 Max Controllable Speed

– Pitc h: 1200/s; Pan: 1800/s

2.2.4 Transmitter

2.2.4.1 Name

– C1

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

- 140F to 1040F (

- 10 0 C to 400C)

2.2.4.6 Battery

– 600mAh LiPo 2S

APPENDIX

– C (See attachment)

DJI Phantom 2 Vision+ Manufacturer’s User Manual

42

APPENDIX

– D (See attachment)
DJI Inspire 1 Manufacturer’s User Manual

43

APPENDIX

– E
month:_________(year:________
UAS$#:$_ __________ Date(Issue(

Discovered
Date(Issue(

Addressed
Software(Updates
Airframe(Engines
Propellers
Camera(Gimbal
Landing(Gear
Vibration(Dampening

Other:
MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted
Maintenance(Performed(By:(((
Print(&(Sign