Name and Address of Petitioner

Rielly Milne, Member

Enlim Productions, LLC

19805 North Creek Parkway #300

Bothell, WA 98011

(425) 301 4683

Riellymilne@enlimproductions.com

(I) Introduction

As set forth herein, to commercially operate small Unmanned Aircraft Systems 

(UAS) safely and legally in the National Airspace System (NAS), Rielly Milne of 

Enlim Productions, LLC, Bothell, Washington, seeks an exemption from Federal 

Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA 

Modernization and Reform Act of 2012. 

Section 333 states that the FAA may issue a certificate of waiver upon a finding 

that a type of UAS, as a result of its size, weight, speed, operational capacity, 

proximity to airports and populated areas, and operations within visual line of 

sight do not create a hazard to users of the NAS or the public or pose a threat to 

national security. The grant of such an exemption is consistent with Congress’ 

intent, reflected in Section 333, that safe systems be permitted in the national 

airspace prior to the issuance of final regulations governing general use of these 

systems. 

Being “unmanned aircraft and associated elements, including communication 

links and the components that control the unmanned aircraft that are required for

the pilot in command to operate safely and efficiently in the national airspace 

system,” Enlim Production’s UAS meet the Section 331 definition of “small 

unmanned aircraft.” 

Section 332 provides for such integration of civil unmanned aircraft systems into 

our national airspace system as it is in the public’s interest to do so. We would 

like to operate our small UAS(s) prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft, thereby providing 

direct experience and valuable information for formal regulation. 
																																																																																																											

(II) Public Benefit

Enlim Productions intends to use small UAS to provide aerial photography and 

videography services to businesses, organizations and community members. 

More specifically, we intend to: 

 Enable businesses to improve marketing and outreach through the use of 

state-of-the-art high definition aerial imagery and videography.

 Provide economic stimulus and public benefit by providing an effective 

means by which companies or individuals can use up-to-date, highquality photos and videos to learn about properties, neighborhoods and 

communities.

 Help communities realize economic benefit by encouraging public 

participation and encouraging tourism; by showcasing community 

buildings and landscapes; and by documenting community events in 

low-cost ways not previously available to them. 

 Increase awareness/knowledge of the amenities of a local area by the 

general public and byvisiting tourists.

 Provide non-profit organizations as well as schools and universities and 

local municipalitiesways to showcase facilities, document events, and 

educate the public.

All of these above services:

 Are otherwise unavailable to the public, given the UAS’s ability to:

 Safely capture images from 0 to 400 feet.

 Create images that are more up-to-date and more closely defined 

than Google-Earth type satellite images.

 Create images at prices lower than that of traditional helicopter and 

airplane photography and videography.

 Increase safety of and reduce risk to the public and the NAS by:

 Replacing large manned helicopters and airplane flights with small 

UAS flights, thereby reducing air and noise pollution as well as the 

dangers inherent in flying aircraft loaded with crewmembers and 

combustible fuel close to people and property.

 Reduce environmental pollution and reliance on fossil fuels by replacing 

fueled aircraft flights with battery-operated UAS flights.
																																																																																																											

(III) Specific Sections Seeking Exemption 

We understand that we are entitled to submit a Petition for Exemption if we 

believe that following a rule will burden us, we can provide a level of safety at 

least equal to that provided by the rule, and our request is in the public interest. 

Therefore we seek relief from the following sections of the current regulations:

14 C.F.R. 21 subpart H - Certification procedures; Airworthiness 

Certificates

14 C.F.R. 45.23 - Display of Marks

14 C.F.R. 61.113 (a) & (b) - Private Pilot Privileges and Limitations

14 C.F.R. 91.105 - Flight crewmembers at stations

14 C.F.R. 91.109 (a) - Flight Instruction

14 C.F.R. 91.119 (c) - Minimum safe altitudes

14 C.F.R. 91.121 - Altimeter Settings

14 C.F.R. 91.151 (a) - Fuel Requirements for flight in VFR Conditions

14 C.F.R. 91.203 - Carrying Civil Aircraft Certification and Registration

14 C.F.R. 91.405 (a) 14 C.F.R. 91.407 (a) (1), 14 C.F.R. 91.409 (a) (2) -

Maintenance required; Operation after Maintenance, preventative 

maintenance, rebuilding or alteration

14 C.F.R. 91.417 (a) & (b) - Maintenance Records

14 C.F.R. 91.7 (a) - Civil Aircraft Airworthiness

14 C.F.R. 91.9 (b) - Civil Aircraft fight manual, marking and placard 

requirements

This application is similar to many which have received FAA approval. As stated 

in Exemption #11639, the FAA has found that the enhanced safety achieved 

using an UAS with the specifications described by herein, 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 such exemption is in the public interest. Since we are applying 

at a time when the FAA is using a “summary grant process” be informed that 

while developing this request we reviewed, among others, exemptions #11636, 

#11639, #11595, #11596, #11564, #11569, #11616 and#12641

(IV) Justification for Each Exemption Request

Extent of relief and reason for seeking Relief; why the exemption would not 

adversely affect safety, or how the exemption would provide a level of safety

equal to existing rule 

Part 21 Airworthiness Certification; Subpart H Certification procedures for 

products and parts, Airworthiness Certificates

This section outlines requirements for the issue of design and production 

approvals, airworthiness certificates, and other airworthiness approvals. We seek 

relief from this rule because the size, weight and enclosed operational area of 

our UAS, as described elsewhere in this document, permit exemption from Part 

21 because our UAS meet and exceed an equivalent level of safety pursuant to 

Section 333 of the Reform Act. 
																																																																																																											

The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Therefore, relief from 14 C.F.R. part 21, and any associated noise 

certification and testing requirements of part 36, is not necessary. 

Instead of following this requirement, we will as outlined in this document, as per 

our Operations of the Unmanned Aircraft to Minimize Risk to the NAS, People 

and Property (Part V) and Flight Operations and Procedures Manual and 

Training Manual (currently in development), Enlim Productions seeks to uphold 

the same level or exceeded level of safety as described in Part 21 of 14 C.F.R. 

Therefore this exemption will not adversely affect safety or will provide a level of 

safety equal to the existing rule. 

14 C.F.R. 4 5.23 Display of Marks

This section outlines regulations requiring specific location(s) and size of aircraft 

marks. We seek relief from this rule because, given the size of our UAS, and the 

lack of cabin, cockpit or pilot station, two-inch lettering is difficult to place on such 

small aircraft. 

Instead of following this requirement, we will mark the UAS in lettering that is as 

large as practicable by placing an N number registered with the FAA on its 

fuselage so that the PIC, VO, or other observers will see the markings. This 

exemption will therefore not adversely affect safety or will provide a level of 

safety equal to the existing rule. 

14 C.F.R. 61.113 (a) & (b) Private Pilot Privileges and Limitations

This section describes regulations concerning certification of pilots. We seek 

relief from this rule because the risks associated with the operation of a UAS are 

lesser than and often uncorrelated with the risks associated with the commercial 

and private aircraft operations contemplated by Part 61 when drafted. The skills 

required to fly large, manned aircraft are substantially different from the skills 

required to remotely operate a small UAS. Also, manned aerial vehicles weighing 

significantly more than small drones (such as ultralight vehicles) as well as small 

UAS legally operated by hobbyists, operate without the need for pilot certification. 

Requiring a private or commercial pilot certificate would provide no appreciable 

safety benefit and would needlessly impose an undue burden of time and cost on 

Enlim Productions, most particularly in light of the FAA’s Small UAS Notice of 

Proposed Rulemaking which proposes that small UAS pilots be considered 

‘operators’ required to meet certain requirements that do not include pilot’s 

license. 

Instead of following this requirement, to minimize risk and maximize safety, all 

UAS operations will be controlled and limited, and all flights will be planned and 

coordinated prior to operations: 

 Prior to operations, Enlim Production’s PIC(s) will go through a 

documented process of dedicated ground school and flight lessons in 

accordance with manufacturer and industry guides.
																																																																																																											

 All PIC’s will only operate the UAS as stated in this document and in our 

Flight Operations and Procedures Manual, flying at altitudes well below 

the permissible limits for other civil aircraft, and within a geographical 

envelope under the control of Enlim Production’s clients.

 The PIC will be designated before a flight and will not transfer control at 

any time during a flight. 

 Enlim Production’s PICs will comply with upcoming FAA Operator 

Certification and Responsibilities once they are finalized. 

 All of Enlim Production’s PICs will have exclusive training on one single 

type of UAS (DJI Inspire 1) and therefore have thorough insight on 

operations.

This exemption will therefore not adversely affect safety or will provide a level of 

safety equal to the existing rule. More information about pilot safety can be found 

in the Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People 

and Property (Part V) section of this document. 

14 C.F.R. 91.105 Flight crewmembers at stations

This section outlines regulations for flight crewmembers inside an aircraft. We

seek relief from this rule because there is no flight crew onboard a small UAS. 

Instead of following this requirement, in keeping with the direction of the 

regulation, the PIC of the UAS and VO will be at their respective crewmember 

stations on the ground during takeoff and landing as well as the complete 

duration of the flight. By instituting this procedure this exemption will therefore not 

adversely affect safety or will provide a level of safety equal to the existing rule. 

14 C.F.R. 91.109 (a) Flight Instruction

This section provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. We seek relief from this rule because UAS do 

not have fully functioning dual controls. 

Instead, flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. This exemption will 

therefore not adversely affect safety or will provide a level of safety equal to the 

existing rule. 

14 C.F.R. 91.119 (c) Minimum safe altitudes: General.

This section establishes minimum altitudes for operation of civil aircraft. We seek 

relief from this rule because the services we intend to provide for the public good 

may require photo or video images captured from an altitude of less than 500 

feet. 
																																																																																																											

Instead of following this requirement, all UAS flights will be conducted with within 

visual line of sight and with prior permission from the owner of the property or 

municipality. All persons, vessels, vehicles, not directly involved with the 

operation will be notified and cleared of the area where UAS operations will be 

conducted. Given our policies of advance notice and access restricted area, and 

given the size, weight, maneuverability and speed of our UAS, we will maintain 

an equivalent or higher level of safety of that described in this rule. 

14 C.F.R. 91.121 Altimeter settings

This section defines regulations for altimeter settings. We seek relief from this 

rule concerning altimeter settings because: our UAS has no altimeter settings. 

Instead, electronic GPS downlinks telemetry data in real time to the PIC’s 

ground-based on-screen display as to the altitude (AGL) of the UAS above the 

takeoff location. 

This exemption will not adversely affect safety, as our PIC will provide a level of 

safety equal to the existing rule by confirming the altitude of the launch site 

shown on the GPS altitude indicator prior to each flight. 

14 C.F.R. 91.151 (a) Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane 

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 – (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes.” We seek relief 

from this rule because our UAS runs on battery instead of fuel, most of our UAS 

flights last less than the 30-minute reserve requirement, and we do not fly at 

night. 

Instead of following this requirement, an equivalent level of safety will be 

achieved by following the UAS manufacturer’s operating documents with regard 

to battery voltage. To ensure safety and maintain adequate communication 

between radio control and the UAS, our PIC will not begin a flight with a battery 

holding less than 80% charge; and will not begin a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly to the intended 

landing point at normal cruising speed and land the UAS with no less than 30% 

of battery power. A landing sequence will be initiated at the 30% warning and the 

UAS automatically initiates landing sequence at 15% charge while still under PIC 

control. 

Through implementation of these procedures, this exemption will not adversely 

affect safety or will provide a level of safety equal to the existing rule. 
																																																																																																											

14 C.F.R. 91.203 Carrying Civil Aircraft Certification and Registration

This regulation pertains to display of airworthiness certification within an aircraft. 

We seek relief from this rule because our small UAS each weigh less than 10 

pounds, and are operated without an onboard pilot. There are passengers or 

crew; and no cabin or cockpit entrance upon which to display certificates. An 

equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the PIC will have immediate access to them, and be 

able to provide them upon request. 

14 C.F.R. 91.405 (a) Maintenance required; 14 C.F.R. 91.407 (a) (1) Operation

after maintenance, preventive maintenance, rebuilding, or alteration; 14 

C.F.R. 91.409 (a) (2) Inspections; and14 C.F.R. 91.417 (a) & (b) 

Maintenance records

We seek relief from these 4 rules because these regulations only apply to aircraft 

with an airworthiness certificate, and will not, therefore, apply to Enlim 

Production’s UAS. We seek relief also because the FAA has not developed 

maintenance standards for UAS that would allow an UAS operator to meet the 

part 91 maintenance requirements. In particular, there are no individuals 

authorized by the FAA to approve a UAS for return to service or to conduct the 

initial airworthiness and annual return to service inspections as required.

Instead of following these requirements, we will:

 Perform preventative and required maintenance on each aircraft as per 

the owner’s manuals.

 Inspect our UAS before and after each flight as per our Operations of the 

Unmanned Aircraft to Minimize Risk to the NAS, People and Property 

(Part V) and Flight Operations and Procedures Manual and Training 

Manual (currently in development) to ensure that the UAS is in a condition 

for safe flight.

 Will conduct a test flight on each aircraft following any major repairs.

 Will properly note all discrepancies, maintenance, and alterations in a 

Maintenance Log. 

 Therefore this exemption would not adversely affect safety or would 

provide a level of safety equal to the existing rule. More information about 

maintenance procedures can be found in the Operations of the Unmanned 

Aircraft to Minimize Risk to the NAS, People and Property (Part V) section 

of this document. 

14 C.F.R. 91.7 (a) Civil aircraft airworthiness

This section states, “no person may operate a civil aircraft unless it is in an 

airworthy condition.” We seek relief from this rule based on the fact that Enlim 

Production’s UAS will not require an airworthiness certificate in accordance with 

14 C.F.R. part 21, Subpart H. Based on the fact that an airworthiness certificate 

will not be issued, exemption from § 91.7(a) is not necessary. 

An equivalent level of safety will be achieved through the guidance from our

Operations of the Unmanned Aircraft to Minimize Risk to the NAS, People and 

Property (Part V) and Flight Operations and Procedures Manual and Training 

Manual (currently in development), pilot training, and operational risk 

management for each activity. 
																																																																																																											

14 C.F.R. 91.9 (b) Civil aircraft flight manual, marking, and placard 

requirements

This section requires an aircraft flight manual in the aircraft. We seek relief from 

this rule based on the small size of our UAS and the fact that our UAS carries no 

onboard pilots or passengers. Given its size and configuration there is no room 

or capacity in our UAS to carry such an item. This regulation is therefore 

inapplicable.

An equivalent level of compliance will be achieved by keeping our versions of 

these documents at the ground control point where the PIC will have immediate 

access and be able to provide them upon request. 

(V) Operations of the Unmanned Aircraft to 

Minimize Risk to the NAS, People and Property

Concerning our commercial UAS flight operations, we take seriously our 

obligation to clearly define operational borders, and implement operational risk 

management procedures to ensure the public safety of persons and property 

both in the air and on the ground. 

While Enlim Productions currently provides photography and videography 

services in Washington State and surrounding states, we may at times contract 

with clients throughout the U.S. Our area of intended operations include a range 

of population areas, from urban to rural, with some areas, especially coastal 

ones, experiencing seasonal increases and decreases in activity from b oth 

people and aircraft. Our operations will take into account these variations in 

populations and activities. 

Meeting or exceeding COA requirements to perform commercial operations in 

low-risk, controlled environments, our UAS will be operated: 

 During daytime Visual Flight Rules (VFR) conditions and visual 

meteorological conditions (VMC).

 Within visual line of sight (VLOS) of the Pilot in Command (PIC) or the 

Visual Observer (VO), in accordance with the statutory Section 333(b)(1) 

mandate. 

 In such a manner that the PIC and VO are able to communicate verbally 

at all times; and that the VO can assist the PIC with seeing and avoiding 

other air traffic and other ground-based obstacles/obstructions. 

We will not operate our UAS:

 At altitudes exceeding 400 feet AGL

 In winds exceeding 25 knots.

 From any moving vehicle or device.

 At airspeeds greater than the maximum recommended by the 

manufacturer.
																																																																																																											

 Less than 500 feet below or less than 2000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC.

 Unless (considering wind and forecast weather conditions) there is 

enough available power for the UAS to conduct the intended operation 

and to operate after that for at least 5 minutes or with the reserve power 

recommended by the manufacturer if greater.

 Near areas where general public is within 200 feet; or directly over any 

person except authorized Enlim personnel and consenting inspection 

personnel, unless operations nearer to the PIC do not present an undue 

hazard to those persons; or unless 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. 

 Near power lines, wind turbines, or elevated lights; or within areas of 

airspace restrictions such as the one imposed by the National Park 

Service.

 Near airports, heliports, or military bases; more specifically: 

 In accordance with the statutory Section 333 mandate regarding 

proximity to airports, we will stay certain distances away from 

airports or heliports: 5 NM from an airport having an operational 

control tower; or 3 NM from airport w/ a published instrument flight 

procedure, but not operational tower; or 2 NM from an airport w/out 

published instrument flight procedure or an operational tower; or 2 

NM from a heliport with a published instrument flight procedure. 

 We will not operate within 5 nautical miles of an airport reference 

point (ARP) as denoted in the current FAA Airport/Facility Directory 

(AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued 

to the exemption holder. The letter of agreement with the airport 

management will be made available to the Administrator or any law 

enforcement official upon request. 

Our Flight Operations and Procedures Manual, will include procedures for: 

*(Currently in development)

 Conducting a preflight safety risk assessment to determine that the UAS is 

in a condition for safe flight, i.e. completing a preflight inspection checklist 

to ensure the UAS’s airworthiness. If the inspection reveals a condition 

that affects the safe operation of the UAS and/or the Ground Control 

Station, the aircraft will be prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a 

condition for safe flight. 

 Maintaining a Flight Log (noting UAS flight time, Control Unit operation 

time, incident reports, etc.); and making said Log available to the FAA if 

requested.
																																																																																																											

 Conducting initial and ongoing training of PICs and VOs, to include 

classroom training, and training, proficiency and experience-building 

flights; all persons not essential for flight operations will be considered 

nonparticipants, and the PIC will operate the UAS with appropriate 

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

 Evaluating the operational abilities of PICs and VOs on a regular basis.

 Maintaining and repairing the aircraft to ensure that it is in a condition for 

safe operation by:

 Following the UAS manufacturer’s maintenance, overhaul,

replacement inspection, and life limit requirements and safety 

bulletins for the aircraft and its components. 

 Installing firmware updates provided by the manufacturer. 

 Keeping a Maintenance Log noting all maintenance, inspection, 

alterations, and status of replacement/overhaul component parts in 

the aircraft records, including total time in service, description of 

work, and signature of the authorized person returning the UAS to 

service and making said Log available to the FAA if requested. 

 Verifying condition of flight batteries and calibrating the Inertial 

Measurement Unit (IMU) using manufacturer software. 

 Conducting a functional test flight on any UAS that has undergone 

maintenance or alterations that affect the UAS operation; said 

functional test flight will be conducted by a PIC with a VO and so as 

to not pose an undue hazard to persons and property; and 

recorded in the aircraft records. 

 Procedures that ensure that the planned operation can be completed 

safely, such as: 

 Checking local sectional (air) charts, NOTAM (notice to airmen), 

etc. prior to the flight. 

 Conducting a pre-flight visual survey of the area to consider 

characteristics of the area of intended operation(s) and the 

associated potential hazards regarding proximity to populated 

areas. 

 Remaining clear and giving way to all manned aviation operations 

and activities at all times. 

 Aborting a flight and landing the UAS at the nearest and safest 

ground point in the event of safety breaches, potential danger,

unpredicted obstacles or emergencies. 

 Using a fresh, fully charged battery with each flight as a safety 

precaution, to ensure safety and maintain adequate communication 

between radio control and the UAS; and not operating our UAS at 

or below manufacturer recommend minimum charge levels for 

operation. 

Also: 

 Flight operations will be performed only at the request of and with the 

authorization and permission of clients (property owner/controller) or 

their authorized representatives. 
																																																																																																											

 Caution signs will be placed at the site of aerial operations to warn people 

that aircraft operations are in progress. 

 Our Client Agreements will reserve us the right to decline a photo shoot if 

conditions of the location (e.g. proximity of power lines) may cause 

unacceptable risk; and to reschedule a photo shoot if weather conditions 

such as precipitation or wind speed become a factor. 

 The operating documents for our UAS, and any revisions, will be 

accessible during UAS operations and made available to the Administrator 

or law enforcement official upon request. 

 We carry comprehensive general liability insurance coverage and an 

additional insurance policy specifically covering our UAS. 

(VI) Summary for Federal Register 

Rielly Milne of Enlim Productions, LLC, Bothell, Washington, seeks exemption 

from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the 

FAA Modernization and Reform Act of 2012 for the purpose of commercially 

operating small Unmanned Aircraft Systems (UAS) safely and legally in the 

National Airspace System. Specifically, Enlim Productions seeks relief from the 

following sections of the current regulations: 14 C.F.R. 21 subpart H -

Certification procedures; Airworthiness Certificates; 14 C.F.R. 45.23 - Display of 

Marks; 14 C.F.R. 61.113 (a) & (b) Private Pilot Privileges and Limitations; 14 

C.F.R. 91.105 Flight crewmembers at stations; 14 C.F.R. 91.109 (a) Flight 

instruction; 14 C.F.R. 91.119 (c) Minimum safe altitudes; 14 C.F.R. 91.121 -

Altimeter settings; 14 C.F.R. 91.151 (a) - Fuel Requirements for Flight in VFR 

Conditions; 14 C.F.R. 91.203 Carrying Civil Aircraft Certification and Registration; 

14 C.F.R. 91.405 (a) 14 C.F.R. 91.407 (a) (1), 14 C.F.R. 91.409 (a)(2) 

Maintenance required; Operation after maintenance, preventive maintenance, 

rebuilding or alteration; 14 C.F.R. 91.417 (a)&(b) Maintenance Records;14 

C.F.R. 91.7 (a) - Civil Aircraft Airworthiness; 14 C.F.R. 91.9 (b) Civil aircraft flight 

manual, marking, and placard requirements. 

Enlim Productions intends to use small UAS to provide aerial photography and 

videography services to businesses, organizations and community members. 

More specifically, we intend to: 

 Enable businesses to benefit through the use of state-of-the-art visual 

marketing materials 

 Provide economic stimulus and public benefit by providing an effective 

means by which companies or individuals can use up-to-date, highquality photos and videos to learn about properties, neighborhoods and 

communities 

 Help communities realize economic benefit by encouraging public 

participation and encouraging tourism; by showcasing community 

buildings and landscapes; and by documenting community events in 

low-cost ways not previously available to them 

 Increase awareness/knowledge of the amenities of a local area by the 

general public and by visiting tourists 
																																																																																																											

 Provide non-profit organizations as well as schools and universities and 

local municipalities ways to showcase facilities, document events, and 

educate the public 

The enhanced safety achieved using an UAS with the specifications described 

herein, and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crewin addition to flammable fuel, 

should give the FAA good cause to find that such exemption is in the public 

interest. By granting this request for exemption, the FAA will facilitate the smooth 

integration of UAS into the NAS.

(VII) Additional Information:Design 

Characteristics, Aircraft Performance and 

Performance Limitations, and Conditions of UAS 

to be Operated 

The UAS described below: 

 Utilizes 4 counter-rotating propellers for balance, control and stability 

 Is equipped with GPS to maintain geospatial orientation and position 

 Use Return Home safety technology and Auto Landing feature if UAS 

loses transmitter signal 

 Are controlled primarily through F CC approved RF spectrum 

transmitter/controller/receivers; and FCC approved RF spectrum EIRP 

with transmitting power of 100 mW for dedicated wifi transmitter/receiver 

between UAS, Range Extender attached to transmitter and mobile 

viewing device displaying operational telemetry and video/photography 

functions. 

 Send real time video and telemetry information is transmitted back to a 

ground control station, allowing PIC to monitor battery level, GPS signal 

strength, altitude (AGL), distance from PIC, camera imagery, and control 

camera angle. 

 Have failsafe modes of operation for either loss of RC or GPS signal. The 

onboard flight controller can maintain altitude and maximum altitude can 

be preprogrammed by the PIC. 

 Have audible and visual sequential low battery warnings set at 30% 

charge and 15% charge remaining. The UAS automatically initiates 

landing sequence at 15% charge while still under PIC control. The 

onboard flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state. An automatic termination 

of flight and landing will be initiated when the battery reaches a 

predetermined low.
																																																																																																											

DJI Inspire 1 

 Gross weight of less than 7 pounds including camera and battery 

 Cruising speed of 15 knots with maximum speed of 42 knots and 

maximum altitude of 4500m 

 Maximum flight time of 18 minutes 

 FCC compliant Radio Frequency (RF) spectrum 5 .725~5.825 GHz and 

2.400~2.483 GHz 

 Manual available: http://www.dji.com/product/inspire-1/info#downloads 

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