.I.-~uedeke Aviation Consulting, LLC - DBA "Aeroview Solutions" 

}__ ... ! 

Attn: 

4008 Farben Way 

Fort Mill, SC 29715 

980-272-7248 

JDLuedeke@mac.com 

U. S. Department of Transportation Docket Operations West Building Ground Floor, 

Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: LUEDEKEAVIATION CONSULTING, LLC DBAAEROVIEW SOLUTIONS 

REQUEST AN EXEMPTION 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)(l) & (a)(2),AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI Inspire 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

JustinD~ 

owner~ 

Luedeke Aviation Consulting, LLC 

4008 Farben Way 

Fort Mill, SC 29715 

JDLuedeke@mac.com 

(980)-272-7248 
TABLE OF CONTENTS 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER. ...................................................................... 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROMWHICHAEROVIEW SOLUTIONS 

SEEKS EXEMPTION ............................................................................... 7 

THE EXTENT OF RELIEF THE AEROVIEW SOLUTIONS SEEKS AND THE 

REASON THE AEROVIEW SOLUTIONS SEEKS THE 

RELIEF ............................................................................................... 10 

THE REASONS WHY GRANTING AEROVIEW SOLUTIONS REQUEST WOULD 

BE IN THE PUBLIC INTEREST .................................................................................... 12 

THE REASONS WHY GRANTING THE EXEMPTION TO AEROVIEW SOLUTIONS 

WOULD NOT ADVERSELY AFFECT SAFETY ........................................................... 14 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ............... .25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT AEROVIEW SOLUTION'S REQUEST .......................................... 25 

CONCLUSION .................................................................................................................. 25 

APPENDICES ...................................................................................... 26 

2 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOTAM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofF ederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Airman 

Pilot in Command 

FAA Modernization and Reform Act of2012 (FMRA) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Sight 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 
SUMMARY 

Luedeke Aviation Consulting, LLC, dba. Aeroview Solutions hereafter referred to as 

AEROVIEW SOLUTIONS 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)(l) & (a) 

(2), and 91.417(a) & (b), to operate an UnrnannedAircraft System (Dll Inspire 1) 

pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (FMRA). 

This exemption will permitAEROVIEW SOLUTIONS to operate an UnrnannedAircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of 

construction sites, residential and commercial real estate, civil landscapes and events over 

certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

AERO VIEW SOLUTIONS and its owner, Justin D. Luedeke have worked in the NAS in 

various capacities for over 16 years as a pilot operating aircraft from single engine 

propeller aircraft up to and including transport category jetliners. Having over 5,000 

flight hours and licensed as an Airline Transport Pilot, I hold a perfect safety record with 

an intimate knowledge of all aspects of the NAS. The objective of AERO VIEW 

SOLUTIONS and our Unmanned Aircraft System (DJI Inspire 1) aerial operations is to 

provide a more affordable, high-quality video and production system for a variety of 

governmental, commercial, public, and residential uses, specifically targeting 

• Agricultural mapping 

• Appraisals 

• Business Marketing 

• Auto Dealers 

• Pipeline and Power Line observation and monitoring 

• Real Estate 

• Construction sites 

• Civic Landmarks 

• Special Events 

• Training in the private and governmental sectors 

4 
BACKGROUND 

Unmanned Aircraft Systems: Dn Inspire 1, UAS 

AERO VIEW SOLUTIONS seeks and exemption to operate the DJI to operate the Dll 

Inspire 1 system for compensation or hire within the NAS. The DJI Inspire 1 is a 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizing an electronic tablet or smart phone system. The Dll Inspire 1 has 

a maximum gross weight of approximately 6 lbs while having dimensions of 

438x451x301 mm. The maximum speed is approximately 22m/sand a maximum flying 

height of 400'. The Dll Inspire 1 is equipped with four main rotors, driven by Lithium 

Polymer battery powered electric motors. 

The Dll Inspire 1 that will be operated by AEROVIEW SOLUTIONS will be registered 

in accordance with 49 U.S. C., 44103, Registration of Aircraft, as well as 14 C.P.R. Part 

47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification 

and Registration Marking. 

BASIS FOR PETITION 

Petitioner, AEROVIEW SOLUTIONS, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.P.R.§ 11.61) and the FAA Modernization and Reform Act of2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator 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 of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, AEROVIEW SOLUTION'S operation ofDll Inspire 

1 UAS meets the conditions ofFMRA Section 333 and therefore, will not require an 

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

Accordingly,AEROVIEW SOLUTIONS requests relieffrom Sections 91.405(a), 

91.407(a)(l), 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. 

AEROVIEW SOLUTIONS submits that the requested relief is proper since an equivalent 

level of safety will be ensured. AEROVIEW SOLUTIONS will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance 

5 
on the UAS using the methods, techniques, and practices prescribed in the operating 

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

Furthermore, AERO VIEW SOLUTIONS will document and maintain all maintenance 

records for the DJI Inspire 1 UAS. 

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

privileges and limitations: Pilot in command, is requested by AEROVIEW SOLUTIONS 

to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or 

higher level certificate, as well as an airman medical certificate, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC 

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

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

AEROVIEW SOLUTIONS seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Inspire 1 UAS do not require an airworthiness certificate 

in accordance with 14 C.P.R. Part 21, Subpart H. As such, AERO VIEW SOLUTIONS 

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

prior to every flight, by determining that the UAS are in compliance with the operating 

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

that the aircraft are in a condition for safe flight. 

AEROVIEW SOLUTIONS also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Inspire 1 U AS 

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 withAEROVIEW 

SOLUTION'S operation of the DJI Inspire 1 UAS within visual line of sight, at or below 

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

Additionally, AEROVIEW SOLUTIONS seeks an exemption from the requirements of 

Section 91.151 (b), entitled Fuel requirements for flight in VFR conditions. AERO VIEW 

SOLUTIONS submits that safety will not be affected by operation of the DJI Inspire 1 

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

rules (VFR), with enough battery power to fly for a total duration of approximately 23 

minutes. Battery power indicators are also able to show exactly how much battery power 

is left, as well as how much time is needed to return safely back to point of take off 

6 
In accordance with 14 C.F.R. § 11.81, AEROVIEW SOLUTIONS provides the following 

information in support of its petition for exemption: 

A. Name and Address Of The Petitioner 

Justin D. Luedeke 

Owner 

Luedeke Aviation Consulting, LLC dba. Aeroview Solutions 

4008 Farben Way 

Fort Mill, SC 29715 

(980) 272-7248 

JDLuedeke@mac.com 

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

Exemption. 

1. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if-

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of Section 

91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) 

No person may operate a civil aircraft unless it is in an airworthy condition. 

7 
3. AEROVIEW SOLUTIONS 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) of this section, 

the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure. 

4. AERO VIEW SOLUTIONS 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. AEROVIEW SOLUTIONS Seeks Exemption From The Requirement Of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of Section 

91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

8 
(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 ofthis 

chapter[.] 

7. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of 

Sections 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) 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 4 3 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. AEROVIEW SOLUTIONS Seeks Exemption From The Requirements Of 

Sections 91.417(a)And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section: 

( 1) Records of the maintenance, preventive maintenance, and alteration and records of the 

1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance 

of an aircraft. The records must include--

( i) A description (or reference to data acceptable to the Administrator) of the work 

perfonned; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

9 
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its appliances 

are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines. rotors. propellers. and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) ofthis section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 4 3.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent Of Relief AEROVIEW SOLUTIONS Seeks And The Reason 

AEROVIEW SOLUTIONS Seeks The Relief. 

1. Extent OfReliefAEROVIEW SOLUTIONS Seeks And The ReasonAEROVIEW 

SOLUTIONS Seeks ReliefFrom Section 61.113(a)And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical certificate, 

and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113( 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 

10 
employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire. 

As set forth more fully below, AEROVIEW SOLUTIONS submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the Dll 

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 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, AEROVIEW SOLUTIONS submits that all flights of the DJI Inspire 1 UAS, 

conducted by the PIC pursuant to the grant of this Petition: ( 1) will be incidental to The 

AEROVIEW SOLUTION'S business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief AERO VIEW SOLUTIONS Seeks And The Reason AERO VIEW 

SOLUTIONS Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow AEROVIEW SOLUTIONS to determine that the DJI Inspire 1 UAS are 

in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., AEROVIEW SOLUTIONS Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

AEROVIEW SOLUTIONS seeks the requested relief because the DJI Inspire 1 UAS do 

not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. 

Therefore, The AEROVIEW SOLUTIONS will ensure that the DJI Inspire 1 UAS are in 

airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Inspire 1) 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 Of Relief The AEROVIEW SOLUTIONS Seeks And The Reason The 

AEROVIEW SOLUTIONS Seeks ReliefFrom Section 91.121. 

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

operations of the Dll Inspire 1 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), AEROVIEW SOLUTIONS seeks 

the requested relief because the DJI Inspire 1 UA's altimeter may be set on the ground to 

zero feetAGL, rather than the local barometric pressure or field altitude, before each 

flight. 

11 
Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since the DJI Inspire 1 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. Extent Of Relief AERO VIEW SOLUTIONS Seeks And The Reason AERO VIEW 

SOLUTIONS Seeks Relief From Section 91.15l(b ). 

Relief from Section 91.151 (b) entitled Fuel requirements for flight in VFR conditions, is 

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

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

rules (VFR), for a total duration of23 minutes. AEROVIEW SOLUTIONS seeks the 

requested relief because without an exemption from Section 91.151 (b), the flight time 

duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality 

of any aerial video or still photo flight operations thatAEROVIEW SOLUTIONS 

proposes to conduct pursuant to this Petition. 

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

DJI Inspire 1 operating documents, andAEROVIEW SOLUTIONS proposed operating 

limitations, ensure thatAEROVIEW SOLUTIONS will safely operate the battery 

powered 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 23 minutes. 

5. Extent OfReliefAEROVIEW SOLUTIONS Seeks And The ReasonAEROVIEW 

SOLUTIONS Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), 

And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, AEROVIEW SOLUTIONS requests 

relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

AEROVIEW SOLUTIONS 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., AEROVIEW SOLUTIONS 

Aerial Operations Manual, Monthly Maintenance Log, DJI Inspire 1 Maintenance 

Manual and DJI Inspire 1 Instruction Manual). Furthermore, AEROVIEW SOLUTIONS 

will document and maintain all maintenance records for the DJI Inspire 1 UAS. 

12 
D. The Reasons Why Granting AERO VIEW SOLUTION'S Request Would Be In 

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

Granting the present Petition will further the public interest by allowing AERO VIEW 

SOLUTIONS to safely, efficiently, and economically perform aerial video and 

photography of agricultural and construction sites, real estate, events and civic landscape 

over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 UAS will benefit the local economy, open new 

opportunities for business expansion among customers of AERO VIEW SOLUTIONS, 

decrease the use of fossil fuels currently used in manned aircraft. allow cutting edge 

technology to decrease the costs associated with traditional advertising and marketing, 

decrease pesticide and fertilizer use in agricultural operations and provide an localized 

operation that eliminates privacy concerns. Furthermore, AERO VIEW SOLUTIONS and 

the DJI Inspire 1 will be a much safer means of aerial acquisitions compared to 

traditional aircraft. 

1. The Public Will See Both an Economical and Safety Benefit From The Use of the 

DJI Inspire 1. 

The DJI Inspire 1 will allow a safer, more economical means of marketing local 

businesses and their products compared to conventional aircraft. While a conventional 

manned aircraft may weigh thousands of pounds, produce noise levels significantly 

higher than the DJI Inspire 1 and emit pollutant inducing exhaust, all while creating a 

safety threat much higher than any UAS, the DJI Inspire 1 and AERO VIEW 

SOLUTIONS will operate a UAS weighing less than 10 lbs, produce very little noise and 

allow access to areas that traditional aircraft would find impossible to access. This 

ability, coupled with the new found advertising and marketing exposure of local 

businesses will drive interest and traffic to these businesses to new levels. 

2. AEROVIEW SOLUTIONS And The DJI Inspire 1 Will Allow A Reduction of 

Fertilizers and Pesticides. 

Currently, agricultural operations use a blanket pesticide and fertilizer approach to 

maintaining optimum health of their plants. With the Dll Inspire 1, we can identify 

specific areas of a field that may need fertilizer of pesticides vs. areas that do not. This 

will allow the owner to precisely apply fertilizers and pesticides which will save 

thousands of gallons of chemicals from the environment each year. 

3. Businesses Will Have a New, Efficient Option to Better Showcase Their Products 

In order to remain competitive in the United States marketplace, businesses are 

constantly looking to innovate their advertising and marketing By using the DJI Inspire 

1, AEROVIEW SOLUTIONS can provide an economically efficient means of aerial 

13 
video and picture acquisition from angles never previously available. The Dll Inspire 1 

can do this for a fraction of the cost of traditional aircraft, and do so quietly (battery 

operated), safely and efficiently (less than 23 minutes of flight time). 

4. Privacy issues will be non-existent. 

The use of the DJI Inspire 1 will be operated with strict compliance to the DJI Inspire 1 's 

operating manual, maintenance manual and all applicable FAA Regulations. 

Furthermore, as traditional aircraft have always had to operate in a much larger space, 

covering multiple private properties in order to arrive at their destination, the DJI Inspire 

1 does not require an airport, and can be launched and landed at the property of intention, 

thereby eliminating privacy concerns. Also, AEROVIEW SOLUTIONS will maintain 

communication with law enforcement, and gain approval from the local land owner for 

all operations requiring such. 

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

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which AEROVIEW SOLUTIONS Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of2012 (FMRA) Section 333. 

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

unmanned aircraft and its operation, AEROVIEW SOLUTION'S operation of the DJI 

Inspire 1 UAS meet the conditions ofFMRA Section 333, and will not require an 

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

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users 

of the NAS or the public, or otherwise pose a threat to national security. Specifically, 

FMRA Section 333 states the following, in part: 

(a) In GeneraL--Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rule making required by section 332 of 

this Act or the guidance required by section 3 34 of this Act. 

(b) Assessment ofUnmannedAircraft 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 

14 
(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 airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft systems in 

the national airspace system. 

In seeking this exemption, AERO VIEW SOLUTIONS submits that the Dll Inspire 1 

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 

(a) the characteristics of the Dll Inspire 1 UAS; (b) the pilot certification requirement; 

and (c) the specific operating limitations. 

a. The Specifications Of The Dll Inspire 1 UAS Demonstrate Its Safe Characteristics. 

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

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

operational capability. 

i. Technical Specifications Of The Dn Inspire 1 UAS. 

The technical specifications of the Dll Inspire 1 UAS are set forth by the Dll Inspire 1 

User Manual, attached hereto as Appendix A 

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain Within 

A Defined Operational Area 

The Dll Inspire 1 UAS may be operated in both manual and global positioning flight 

modes. A complete description of the flight and navigational modes of the DJI Inspire 1 

UAS is provided at page 12 ofthe DJI Inspire 1 User Manual attached hereto as 

Appendix A. 

iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To Horne Point Or Hover 

In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 

3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control 

link data from the GCS, the UAS will assume that the Control Link is lost and will return 

to the horne position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. 

15 

15 
A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set forth at 

pages 12 through 14 and page 50 of the DJI Inspire 1 User Manual, attached hereto as 

Appendix A. 

iv. The DJI Inspire 1 GCS And Its Operation. 

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

flight control software is provided at pages 12 through 18 and pages 45 through 51 ofthe 

DJI Inspire 1 User Manual. The DJI Inspire 1 User Manual is attached hereto as 

Appendix A. 

b. Flight Operations OfDJI Inspire 1 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

AEROVIEW SOLUTIONS staff will be the only persons to act as a pilot in command 

(PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will assist him at all times 

during flight time. 

c. Flights OfDJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, AERO VIEW SOLUTIONS proposes to commercially operate 

DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography 

over certain areas of United States, pursuant to the following specific operating 

limitations. 

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: 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 photography. 

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 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 

feetAGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 

16 
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 designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perfonn 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 and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 

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

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

revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, 

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

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

revisions to the operating documents. 

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

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records. 

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

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry 

in the aircraft records. 

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

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

17 
13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

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

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator's 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator's 

PICs are permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized. 

20. The 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 NO TAM as required by the operator's CO A. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

21. The 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 
22. If the UA loses communications 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 ofunpredicted obstacles or emergencies in 

accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the 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 airspace, 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

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

control of the UA must 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 of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

29. The 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: 

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 

19 
nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/ or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119( a). 

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Pennission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

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

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113( a) And (b) 

Would Not Adversely Affect Safety. 

AEROVIEW SOLUTIONS 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 Dll Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the Dll Inspire 1 

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

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

structures. 

Considering AEROVIEW SOLUTIONS proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, AEROVIEW 

SOLUTIONS submits that the additional manned airmanship experience of a 

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

AEROVIEW SOLUTIONS 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 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). 

20 
AEROVIEW SOLUTIONS will not allow any PIC to operate the DJI Inspire 1 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely 

operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b ), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAS pilot operating the same make and model 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 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 AEROVIEW SOLUTIONS proposed operations. The Administrator has 

held that prior documented flight experience that was obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows: 

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

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

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

and model 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 of multi-rotor time and the 

10 hours may be included in the total25 hours ofUAS rotorcraft time. In addition to the 

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

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

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner's proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfY this requirement. Training, proficiency, and 

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

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

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, AERO VIEW SOLUTIONS will ensure safe operations by not allowing any 

PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

21 
minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 

Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, AEROVIEW SOLUTIONS will ensure that the DJI Inspire 1 UAS is 

in an airworthy condition based upon the UAS's compliance with its operating documents 

and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, 

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

ExemptionNos. 11062, 11063, 11064, 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 level of safety established by Section 91.121 will be maintained because 

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

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

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

information, combined withAEROVIEW SOLUTION'S operation of the DJI Inspire 1 

UAS within visual line of sight, at or below 400 feetAGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UAS at ground level. 

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

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

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

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons \Yhy An Exemption From The Requirements Of Section 91.15l(b) Would 

Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 

C. FR. Section 91.151 (b) as a result of ( 1) the technical specifications of the DJI Inspire 1 

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

proposed flight operations. Accordingly, AERO VIEW SOLUTIONS will ensure that it 

will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 23 minutes. 

22 
Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; 

the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151 (b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible 

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

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

again at approximately 10% remaining battery power. At the critically low battery level, 

the DJI Inspire 1 UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to U AS, 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 Why An Exemption From The Requirements Of Sections 91.405(a), 

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

Safety. 

In seeking this exemption, The AERO VIEW SOLUTIONS submits that the equivalent 

level of safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) will be met becauseAEROVIEW SOLUTIONS will use trained technicians to 

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

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

AERO VIEW SOLUTIONS Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Inspire 1 User Manual). Furthermore, AEROVIEW SOLUTIONS will document and 

maintain all maintenance records for the DJI Inspire 1 UAS. 

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, 

AEROVIEW SOLUTIONS will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User 

Manual is attached hereto as Appendix A; a copy of the DJI Inspire 1 UAS Maintenance 

Manual is attached hereto as Appendix B. 

Likewise, the exemption sought will not adversely affect safety because AERO VIEW 

SOLUTIONS will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents. 

23 
Furthermore, the exemption sought would maintain an equivalent level of safety 

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

DJI Inspire 1 UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. 

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

91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration ofAEROVIEW SOLUTION'S proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Inspire 1 UAS, AEROVIEW 

SOLUTIONS 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 Special Conditions,AEROVIEW SOLUTIONS 

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

Inspire 1 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

SubpartH, 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 NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 

21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or 

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states 

the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

24 
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.P.R.§ 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.P.R. § 21.16, the FAA may 

prescribe special conditions for AEROVIEW SOLUTION'S intended operation ofthe 

DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.P.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). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which AEROVIEW SOLUTIONS Seeks Exemption: 

AEROVIEW SOLUTIONS 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). 

ABriefDescription OfThe Nature OfThe ExemptionAEROVIEW SOLUTIONS Seeks: 

This exemption will permitAEROVIEW SOLUTIONS to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To Support 

AEROVIEW SOLUTION'S Request 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, AEROVIEW SOLUTION'S 

request for exemption may be granted pursuant to the authority ofFMRA Section 333 

and 14 C.P.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; 

and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, AEROVIEW SOLUTIONS will operate the DJI Inspire 1 

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security. 

25 
CONCLUSION 

As set forth herein, AEROVIEW SOLUTIONS seeks an exemption pursuant to 14 C.P.R. 

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), 

which will permit safe operation of the DJI Inspire 1 UAS 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 

AEROVIEW SOLUTIONS to safely, efficiently, and economically operate the DJI 

Inspire 1 UAS commercially within the NAS. 

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

Modernization and Reform Act of2012, Section 333, AEROVIEW SOLUTIONS 

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)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and pennitAEROVIEW 

SOLUTIONS to operate the DJI Inspire 1 UAS commercially for the purpose of 

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

Dated: July 14,2015 

Respectfully submitted, 

Justin D. L~~ 

Owner ~A} 

Luedeke Aviation Consulting, LLC dba. Aeroview Solutions 

4008 Farben Way 

Fort Mill, SC 29715 

(980) 272-7248 

JDL uedeke@mac. corn 

Appendices: 

A- Link to DJI User Manual: Click on link below 

http://download.dji-innovations.com/dm:vnloads/inspire 1/en/ 

Inspire 1 User Manual v1.2 en.pdf 

B- Link to DJI Maintenance Manual: Click on link below 

http://dovm1oad.dji-innovations.com/dovmloads/inspire_l/enl 

Inspire _1_ Maintenance_ Manual V 1. 0 _en. pdf 

26