UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERALAVIATION ADMINISTRATION WASHINGTON, DC

Regulatory DocketNo.

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IN THEMATTER OF THE PETITION FOREXEMPTION OF: Robert ScottButton •' ••.' A"••

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FORAN 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)(l), 91.409(a)(1) & (a)(2),AND 91.417(a) & (b) CONCERNING COMMERCIAL DJI INSPIRE 1UNMANNEDAIRCRAFT SYSTEMS PURSUANTTO SECTION 333 OF THE FAA MODERNIZATIONANDREFORMACTOF 2012 (PUBLIC LAW 112-95)

Submitted on October 26,2015

Robert Scott Button 59 Route 6A

Unit 19-5 Dennis, MA02638TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS

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SUMMARY

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INTRODUCTIONAND INTERESTS OF PETITIONER.

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BACKGROUND

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BASIS FORPETITION

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NAMEANDADDRESS OF PETITIONER

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THE SPECIFIC SECTIONS OF 14 C.P.R. FROM WHICH Robert Scott Button SEEKS EXEMPTION

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THE EXTENT OF RELIEF Robert Scott Button SEEKS AND THE REASON Robert Scott Button SEEKS THE RELIEF

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THE REASONS WHY GRANTING Robert ScottButton REQUEST WOULD BE IN THE PUBLIC INTEREST

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THE REASONS WHY GRANTING THEEXEMPTION WOULDNOT ADVERSELYAFFECT SAFETY

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CONCLUSION

....................................................................................................................... 19AGL AOI ATC ATO AV CFR COA 

### FAA FAR GCS GPS 

### LOL NAS NOT AM PIC Section 333 

# so SOP UA UAS VFR VLOS VMC VTOL DJI ESC FPV LI-PO RCV GLOSSARY OFABBREVIATIONS

Above Ground Level Area ofInterest AirTraffic Control AirTraffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization FederalAviationAdministration FederalAviation Regulation Ground Control Station Global Positioning System Loss ofLink NationalAirspace System Notice toAirman Pilot In Command FAAModernization and ReformAct of2012 (FMRA) Safety Observer Standard Operating Procedures UnmannedAircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing UAV manufacturer Electronic speed control First Person View Lithium Polymerbattery Radio Controlled vehicleBACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS Robert Scott Button seeks an exemption to operate DJI systems for compensation orhire within the NAS. DJI Inspire 1 are vertical takeoffand landing (VTOL) UnmannedAircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smartphone systems. The DJI Inspire 1has a maximum gross weight of6pounds 7.5 ounces, a length of 17.3 inches, width of17.7 inches, height of

11.8 inches, and a maximum speed ofapproximately 42 knots. The DJI Inspire 1 UAis equipped with four main rotors; driven by Lithium Polymerbatterypowered electric motors.

The DJI Inspire 1UAthat will be operated by Robert Scott Button will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, 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 Markings.

BASIS FORPETITION

Petitioner, Robert Scott Button, pursuantto the provisions ofthe Federal Aviation Regulations (14 C.F.R. §I1.61) and the FAA Modernization and ReformAct of2012 (FMRA), Section 333, Special Rules for CertainUnmannedAircraft Systems, hereby petitions theAdministrator to commercially operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Robert Scott Button operation ofthe DJI Inspire 1 UAS meets the conditions ofFMRASection 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH.

Accordingly, Robert Scott Button requests relieffrom 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.

Robert ScottButton submits that the requested reliefis proper since anequivalent level ofsafety will be ensured. Robert Scott Buttonwill use experiencedpersonnel ortechnicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction Manual). Furthermore, Robert ScottButton will document and maintain all maintenance records for the DJI Inspire 1UAS.

Relieffrom certain requirements ofSection 61.113(a) and (b), entitled Private pilotprivileges and limitations: Pilot in command, is requested by Robert Scott Buttonto 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, thatthe PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Robert Scott Button seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because theSUMMARY

Robert Scott Button 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 UnmannedAircraft System pursuant to Section 333 oftheFAAModernization and ReformAct of2012 (FMRA). This exemption will permitRobert Scott Button to operate an UnmannedAircraft System (UAS) for the commercial purpose ofconducting aerial video and photography for marketing, film sets, real estate photography, commercials, special events, wedding cinematography, and landscape over certain areas ofthe United States.

INTRODUCTIONAND INTERESTS OFTHEPETITIONER

My name is Robert Scott Button, and I am a drone operator (pilot) with expertise and knowledge in all

aspects ofoperating multiple types ofUAS'S along with camera setup and operation. Robert Scott

Button also provides clients with the highest quality digital content for use intheir commercial, personal, and non-profit multimediaprojects. Robert Scott Button has 25 years ofRCV experience and ·

10 years ofradio controlled helicopter**experi~.::nce.** Robert Scott Button is recognized as an expert in this field

..

The objective ofRobert Scott Button aerial video and photography operations is toprovide high quality

imaging for a variety ofcommercial, public, and residential uses drones for clients in a safe location away from all obstacles and people at all times. Robert Scott Buttonwill also provide knowledge of UAS and promote safe UAS operations.DJI Inspire 1 UAS does not require an airworthiness certificate inaccordance with 14 C.F.R. Part 21, SubpartH. As such, Robert Scott Button submits that he will ensure thatthe DJI Inspire 1 UAS is in an airworthy condition, priorto every flight, by determining thatthe UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1Instruction Manual), and that the aircraft are in a condition for safe flight.

Robert Scott Button also seeks an exemption from the requirements ofSection 91.121, entitled Altimeter Settings, as the DJI Inspire 1UAS will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI 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 UAto the GCS for active monitoring ofthe flight path. This altitude information, combined with Robert Scott Button operation ofthe DJI Inspire 1UAS within visual line ofsight, at orbelow 400 feet AGL, will ensure a level ofsafety equivalentto Section 91.121.

Additionally, Robert Scott Button seeks an exemptionfrom the requirements ofSection 91.151(b), entitled Fuel requirements for flight inVFRconditions. Robert Scott Button submits that safety will not be affected by operation ofthe DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough batterypower to fly for a total duration ofapproximately 15.5 minutes to the first point ofintended 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, Robert ScottButton provides the following information in support ofits petition for exemption:



### A. NameAnd Address OfThe Petitioner. The name and address ofthe Petitioner and point ofcontact is: Robert Scott Button 59 Route 6A Unit# 19-5 Dennis, MA02638 robertbutton@comcast.net 774-836-5117



### B. TheSpecific Sections Of 14 C.F.R. from Which Robert ScottButton Seeks Exemption.

1. Robert ScottButton Seeks Exemption From The Requirements OfSection 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 privatepilotcertificate may act as a pilot in command (PIC) of

an aircraft that is carryingpassengers orproperty for compensation orhire; normay that person, for compensation orhire, act as PIC ofan aircraft. b. Aprivate pilot may, for compensation orhire, act as PIC ofan aircraft in connection with any business or employment if

### i. The flight is only incidental to thatbusiness or employment; and ii. The aircraft does not carry passengers orproperty for compensation orhire. 2. Robert Scott Button Seeks Exemption From The Requirements OfSection 91.7(a). Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) No personmay operate a civil aircraft unless it is in an airworthy condition. 3. Robert Scott Button Seeks Exemption From TheRequirements OfSection 91.121. Section 91.121, entitledAltimeter settings, subsection (a), states the following, inpart:

a. Eachperson operating an aircraft shall maintainthe cruising altitude orflight level of that aircraft, as the case may be, byreference to an altimeter that is set, when operating-- Below 18,000 feet MSL, to---

1. The currentreported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft;

u. Ifthere is no station within the area prescribed inparagraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station;

111. In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 4. Robert ScottButton Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements for flight inVFRconditions, subsection (b), states the following: (b) Noperson may begin aflight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel tofly to the firstpointof intended landing and, assuming normal cruising speed, tofly after that for at least 20 minutes. 5. Robert ScottButton Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner
or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 6. Robert ScottButton SeeksExemption From The Requirements OfSection 91.407(a) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No personmay 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 ofthis chapter [.] 7. Robert ScottButton Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendarmonths, it has had-- (1) An annual inspection in accordance with part 4 3 ofthis chapter andhas been approved for
return to service by a person authorized by§ 43.7 ofthis chapter; or (2) An inspectionfor the issuance ofan airworthiness certificate inaccordance with part 21 of this chapter.

### 8. Robert Scott Button Seeks Exemption FromThe Requirements OfSections 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, eachregistered

owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 1 00-hour, annual, progressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must includei. A description (or reference to data acceptable to the Administrator) ofthe work performed; and

n. The date ofcompletion ofthe workperformed; and

m. The signature, and certificate number ofthe person approving the aircraft for
return to service. Records containing the following information: 1. The total time in service ofthe airframe, each engine, eachpropeller, and eachrotor. 2. The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. 3. The time since last overhaul ofall items installed on the aircraft which

are requiredto be overhauled on a specified time basis. 4. The current inspection status ofthe aircraft, including the time since the last inspection required by the inspectionprogram under which the aircraft and its appliances are maintained. 5. The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, theAD or safety directive number and revision date. IftheAD or safety directive involves recurring action, the time and date when the next action is required. 6. Copies ofthe forms prescribed by§ 43.9(d) ofthis chapterfor each major alteration to the.airframe and currently installed engines, rotors, propellers, and appliances. b. The owner oroperator shall retain the following records for the periods prescribed:

1. 

### The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the workis performed.

n. The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold.

m. A list ofdefects furnished to a registered owner or operator under §

### 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is

· approved for returnto service.



### C. The Extent OfReliefRobert Scott Button SeeksAnd The Reason Robert Scott Button Seeks The Relief. 1. 

### Extent OfReliefRobert Scott Button SeeksAnd The Reason Robert Scott Button Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot incommand, 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 orhire. This reliefis 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 ofan 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, Robert ScottButton submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Inspire 1UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating thatthe PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with the operations specifications

as described inthis exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Robert Scott Button submits that all flights ofthe DJI Inspire 1UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to Robert ScottButtonbusiness; and (2) will not carry passengers orproperty for compensation or hire. 

### 2. Extent OfReliefRobert Scott Button Seeks And The Reason Robert ScottButton Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Robert ScottButton to determine that the DJI Inspire 1UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Robert Scott ButtonAerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Robert Scott Button seeks the requested reliefbecause the DJI Inspire 1UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. Therefore, Robert ScottButton will ensure that the DJI Inspire 1UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction 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. Extent OfReliefRobert Scott Button SeeksAnd The Reason Robert ScottButton Seeks ReliefFrom Section 91.121. Relieffrom Section 91.121, entitledAltimeter settings, may be required to allow flight operations ofthe DJI Inspire 1UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communicationstelemetry data link to downlink altitude information from the UAto the PIC at the ground control station (GCS). Since the FAArequires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Robert Scott Button seeks the requested reliefbecause the DJI Inspire 1UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure orfield altitude, before eachflight. Consideringthe limited altitude ofthe proposed operations, relieffrom 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 ofsafety will be maintained since the DJI Inspire 1 UAis 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, andprovides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS. 

### 4. Extent OfReliefRobert Scott Button Seeks And The Reason Robert ScottButton Seeks ReliefFrom Section 91.151(b).Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extentrequired to allow flights ofthe battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Robert ScottButton seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe battery powered DJI Inspire 1UAS will severely constrain the practicality ofany aerial video or still photo flight operations that Robert Scott Buttonproposes to conductpursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Inspire 1UAS, the DJI Inspire 1 operating documents, and Robert Scott Buttonproposed operating limitations, ensure that Robert Scott Button will safely operate the battery powered DJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough batterypowerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 5. Extent OfReliefRobert ScottButton SeeksAnd The Reason Robert Scott Button Seeks ReliefFrom 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)(l) & (a)(2), and 91.417(a) & (b) only apply
to aircraft with an airworthiness certificate, Robert ScottButtonrequests relieffrom these Sections because the DJI Inspire 1 UAS do notrequire airworthiness certificates. As set forth

more fully below, the DJI Inspire 1 UAS meet the conditions ofFMRASection 333 for operation without an airworthiness certificate. Accordingly, Robert ScottButton will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Robert Scott ButtonAerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Robert Scott Button will document and maintain all maintenance records for the DJI Inspire 1 

### VAS.

D. TheReasonsWhy GrantingRobert ScottButton RequestWould Be In ThePublic Interest: That Is, How ItWould BenefitThe PublicAs AWhole.

Granting the present Petition will further the public interest by allowing Robert Scott Buttonto safely, efficiently, and economically perform aerial video and photography ofconstruction sites, real estate, and landscape overcertain areas ofthe United States. Additionally, use ofthe DJI Inspire 1 UAS will decrease congestion ofthe NAS, reduce pollution, crashes and accidents caused by pilot error and provide significant benefits to the economy. Notably, the benefits ofRobert Scott Buttonproposed operation ofthe DJI Inspire 1 

### VAS will berealized without implicating any privacy issues. 

### 1. ThePublicWill BenefitFrom Decreased Congestion OfTheNAS. The DJI Inspire 1UAS is 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 ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Inspire 1UAS would reduce the amount ofmanned aircraft inthe NAS, reduce noise and airpollution, as well as increase the safety oflife and property in the air and onthe ground. Furthermore, by reducing the number ofmanned aircraft operating inthe NAS, congestion around airports causedby arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS does not require an airport to takeofforland. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that mustbehandled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations. 

### 2. The PublicWill BenefitFrom The SafetyAnd Efficiency OfThe DJI Inspire 1 UAS. Conducting aerial acquisitions with the DJI Inspire 1UAS, instead ofmanned aircraft, will greatly benefitthepublic by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using batterypower and electric motors, the DJI Inspire 1UAS produce no airpollution, 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 1UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS

arepropelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Inspire 1UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crewmembers located onboardthe aircraft, the DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces, at the maximum gross weightwith length 17.3 inches, widths 17.7 inches and with no fuel on board), has less physical potential for collateral damage
to life andproperty onthe 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). 

### 3. PerformingAerialVideo and Photography Operations With The DJI Inspire 1 UAS Will BenefitThe Economy. In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative
to using manned aircraft to conduct similar aerial operations. As such, operation ofthe DJI Inspire 1UAS will allow United States based companies, like Robert Scott Button, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, withthe rising cost of aviation fuel and the Environmental ProtectionAgency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in orderto remain competitive. Operating the battery powered DJI Inspire 1UAS is

one such technology that not only allows companies greater operational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the DJI Inspire 1UAS, companies such as Robert ScottButton, canremain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, whichwill ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use oftheDJI Inspire 1UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax
revenues; and allows companies to invest in research and development in orderto remain competitive bothin the United States and abroad. 

### 4. ThereAre No Privacy**Issues~** Similarto the manned aerial acquisition flight operations that have been conducted for decades, Robert Scott Buttonproposed operation ofthe DJI Inspire 1 UAS would not implicate any privacy issues. Specifically, the DJI Inspire 1UAS will be operated only in compliance with operating documents (i.e., Robert Scott ButtonAerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) whichrequires 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 GrantingThe Exemption Would NotAdverselyAffect Safety, OrHow The ExemptionWould ProvideALevel OfSafetyAtLeastEqualTo That Provided By The Rule From Robert Scott Button Seeks Exemption.

1. Reasons WhyThe DJI Inspire 1 UAS Meet The Conditions OfThe FAAModernization and ReformAct of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Robert Scott Button operation ofthe DJI Inspire 1UAS
meet the conditions ofFMRASection 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 ofthe NAS orthe public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, inpart:

a. In General. --Notwithstanding any otherrequirement ofthis subtitle, and not later than 180 days after the date ofenactment ofthis Act, the Secretary ofTransportation shall determine ifcertain unmanned aircraft systems may operate safely inthe national airspace system before completion ofthe plan and rulemaking required by section 332 ofthisAct or the guidance required by section 334 ofthis Act. b. Assessment ofUnmannedAircraft Systems. --In making the determination under subsection (a), the Secretary shall determine, at a minimum

### i. Which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public or pose a threat to national security; and whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certificationunder section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified under paragraph (1).

c. Requirements for Safe Operation. --Ifthe 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 ofsuch aircraft systems in the national airspace system.

In seeking this exemption, Robert Scott Button submits that the DJI Inspire 1UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Inspire 1UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

1. 

### The Specifications OfThe DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. The DJI Inspire 1UAS do not create a hazard to users ofthe NAS orthe public,

or otherwisepose a threat to national security considering its size, weight, speed, and operational capability.

11. 

### Technical Specifications OfThe DJI Inspire 1 UAS. The DJI Inspire 1 Specifications and Data Sheet, attached hereto as Appendix A,
set the technical specifications ofthe DJI Inspire 1 UAS forth.

111. 

### The DJI Inspire 1 UAS Autonomous FlightAnd Navigation Modes Enable The UAS To RemainWithinADefined OperationalArea. The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes oftheDJI Inspire 1UASisprovided at pages 45-50 ofthe DJI Inspire 1User Manuals, attached hereto as Exhibit B.

IV. 

### The DJI Inspire 1 UAS Is Designed ForAutomatic Return To Home Point OrHoverIn The Event OfLoss OfThe Control Link OrNavigation. When the Control Link is lost, the DJI Inspire 1UAS will remain stationary, in flight, for 3 seconds ormore. If, after 3 seconds, the DJI Inspire 1UAS does not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Inspire 1 at pages 13 through 15 DJI Inspire 1 User Manuals, attached hereto as Exhibit B.



### v. The DJI Inspire 1 GCSAnd It's Operation. A complete description ofthe operation and specifications ofthe DJI Inspire 1 GCS and flight control software is provided at pages 40 through 47 ofthe DJI Inspire 1 User Manual. DJI Inspire 1 User Manuals are attached hereto as Exhibits B.

VI. 

### Flight Operations OfDJI Inspire 1 UAS Are Limited To The Line OfSight OfA Certificated Pilot in CommandWithA Safety Observer. Robert Scott Button will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe DJI Inspire 1UAS. Additionally, a safety observer will assist all pilots during flight time.



### vn. Flights OfDJI Inspire 1 UAS Will Be Conducted PursuantTo Specific OperatingLimitations. In seeking this exemption, Robert Scott Button proposes to commercially operate DJI Inspire 1 UAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 UnmannedAircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petitionto amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 4. The UAmust be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAS must be operated within visual line ofsight (VLOS) ofthe 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 onthe PIC's FAA-issued airman medical certificate. 6. The use offirst 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 verballyat all times. Electronic messaging or texting is notpermitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must

ensure that the SO canperform the functions prescribed in the operating documents. 8. The SO must notperform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is notpermitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operationsand made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations contained inthe grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained inthe grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update orrevise its operating documents. It is the operator's responsibility to track suchrevisions and present updated and revised documents to theAdministrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe 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 ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions 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. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed 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 ofa 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 ofthe 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 ofreplacement/overhaul componentparts must be noted in the aircraft records, including total time in service, description ofwork**accomplis~ed,** and the signature ofthe authorized person returning the UAS to service. 15. Any UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry inthe aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC mustpossess at least a private pilot certificate and at least a current third-class medical certificate. 18. The operatormay 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 withhow 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. § 61.5l(b). Flights for the purposes of training the operator's PICs are permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAwith 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.P.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAAoffice closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UAmay not operate within 5 nautical miles ofan airport reference point asdenoted on a current FAA-published aeronautical chart unless a letter ofagreement 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 ofagreement with the airport management must be made available to theAdministrator uponrequest. 21. The UAmay not be operated less than 400 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. Ifthe UAloses communications or loses its GPS signal, it must return to

a pre-determined location within the planned operating area and land or berecovered in accordance with the operating documents. 23. The PIC must abort the flight inthe 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 enoughpowerto fly at normal cruising speed to the intended landing point and land the UAwith 25% batterypowerremaining. 25. The operator must obtain anAirTraffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) priorto conducting any operations under the grant ofexemption. This COAwill also require theoperator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements intheATO issued COAincluding class ofairspace, 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 accordance with 14 C.F.R. part45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAmust comply with the Federal Communications Commission (FCC) or other 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 ofthe 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 UAmust remain clear and yield the right ofway 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 otherthan 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 UAand/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk ofoperating closerto those objects and determined that it does notpresent an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do notpresent an undue hazard to those persons per 

### § 91.119(a). 32. All operations shall be conducted overprivate 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 operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COAmust be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Website: www.ntsb.gov. 

### 2. Reasons WhyAn Exemption From The Requirements OfSection 61.113(a)And (b) WouldNotAdversely Affect Safety. Robert Scott Button submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Robert Scott Button proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those of commercial pilotrequirements (See ExemptionNo. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1UAS, Robert Scott Button submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary for Robert Scott Button specific proposed flight operations. The FAAhas previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153,11156,11158,11159,11160, 11161). RobertScottButtonwillnotallowanyPICto operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour requirements for the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1UAS 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 oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model ofUAS 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 ExemptionNos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during Robert Scott Button proposed operations. TheAdministrator has heldthat prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAArequired that prior to conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC must have accumulated and logged, in

a manner consistent with 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Priorto operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS 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 ofmulti-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 ExemptionNo. 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 experiencebuilding flights can also be conducted under the grant ofexemptionto accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required tooperate the UAwith appropriate distances in accordance with 14 C.F.R 91.119.

ExemptionNo. 11138 atpage 15. Accordingly, Robert ScottButton will ensure safe operations by not allowing any PIC to. operatethe DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1UAS in

a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.



### CONCLUSION

. Robert Scott Button seeks an exemption pursuant to 14 C.F.R. 

### § 11.61 and Section 333

. ofthe FAA Modernization and ReformAct of2012 (FMRA), which will permit safe operation ofthe DJI Inspire 1UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAAAdministrator will be fulfilling the Congressional mandate ofthe FAA Modernization andReform Act of2012, while also advancing the interests ofthe public, · byallowing Robert Scott Buttonto safely, efficiently, and economically operate the DJI Inspire 1UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAAModernization and Reform Act of2012, Section 333, Robert Scott Buttonrespectfully requests that theAdministrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permitRobert ScottButtonto operate the DJI Inspire 1 UAS commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States.

Dated: October 26, 2015 Submitted by Robert Scott Button

### APPENDIX-A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Robert Scott Button only utilizes safe and reliable UAS. DJI is an industry leader in small UAS production. DJI UAS are loaded with ground breaking software enabling the user to setparameters 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 limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC viathe linked monitor (smart phone/tablet devices)

DJI Inspire 1 1.1 Aircraft 1.1.1 Model- T600 1.1.2 Weight (Battery Included)- 6lbs 7.5291oz (2935g) 1.1.3 HoveringAccuracy (GPS Mode) -Vertical: 0.5m; Horizontal: 2.5m
1.1.4 MaxAngular Velocity- Pitch: 3000/s; Yaw: 1500/s
1.1.5 Max TiltAngle- 350 1.1.6 MaxAscent Speed- 5m/s 1.1.7 Max Descent Speed- 4m/s 1.1.8 Max Speed- 22m/s (ATTI mode, no wind- NOT RECOMMENDED) 1.1.9 Max FlightAltitude- 4500m 1.1.10 Max Wind Resistance

- 1Om/s 1.1.11 Max Flight Time -Approximately 18 minutes 1.1.12 Motor Model- DJI 3510 1.1.13 Propeller Model

- DJI 1345
1.1.14 Operating Temperature Range- 14DFto 1040F (-100C to 400C) 1.1.15 Dimensions

- 17 

### W' x 17 %" x 12" 1.2 Gimbal 1.2.1 Model- ZENMUSE X3 1.2.2 Output Power (with camera)- Static: 9W; In Motion: 11W 1.2.3 Operating Current- Static: 750mA; In Motion: 900mA
1.2.4Angular Vibration Range

- ±0.030 1.2.5 Mounting- Detachable
1.2.6 Controllable Range- Pitch: -900 to +300; Pan: ±3200
1.2.7 Mechanical Range- Pitch: -1250 to 450; Pan: ±3300
1.2.8 Max Controllable Speed- Pitch: 1200/s; Pan: 1800/s 1.3 Transmitter 1.3.1 Name- C1 1.3.2 Operating Frequency- 5.728-5:850GHz; 2.400-2.483GHz 1.3.3 Communicating Distance (unobstructed)- 2000m 1.3.4 Output Power- 9W
1.3.5 Operating Temperature Range- 140Fto 1040F (-IOOC to 400C) 1.3.6 Battery- 600mAh LiPo 2SAll specifications canbe found in the attached user manual or at http://www.dji.com/product/inspire-1/spec