UNITED STATES OF AMERICA DEPARTMENT OF 

TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Sky Media NV LLC  FOR AN EXEMPTION SEEKING RELIEF 

FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.101(e)(4) & (5), 

61.113(a) & (b), 61.23(a), 61.315(a), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 

1 UNMANNED AIRCRAFT SYSTEMS  PURSUANT TO 

SECTION 333 OF  THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted on July 20, 2015 

Paul C Tronier Sky Media NV LLC 336 Omni dr Sparks, NV 89441 

Tel: (775) 772-1413 Email: Skymedianv@yahoo.com 

TABLE OF CONTENTS 

 

Page 

GLOSSARY OF ABBREVIATIONS

..................................................................................3

SUMMARY 

.....................................................................................................................

..... 4 

INTRODUCTION AND INTERESTS OF 

PETITIONER....................................................4 
BACKGROUND........................................................................................

............................4 

BASIS FOR 

PETITION...................................................................................................

..... 5 

NAME AND ADDRESS OF PETITIONER. 

........................................................... 7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SKY 

MEDIA NV LLC SEEKS EXEMPTION .................................................. 

8 

THE EXTENT OF RELIEF SKY MEDIA NV LLC SEEKS AND THE 

REASON SKY MEDIA NV LLC SEEKS THE RELIEF............... . 11 

THE REASONS WHY GRANTING SKY MEDIA NV LLC’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST 

..................................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY 

......................................................................... 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL 

REGISTER. .... 34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT SKY MEDIA NV LLC’S REQUEST.... 

.....................................................................................................................

......... 34 

CONCLUSION 

.....................................................................................................................

....... 35 

APPENDICES........................................................................................37 
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 of Federal Regulations Certificate of Authorization Federal 

Aviation Administration Federal Aviation Regulation Ground Control 

Station 

Global Positioning System Loss of Link National Airspace System 

Notice to Airman 

Pilot In Command FAA Modernization and Reform Act of 2012 

(FMRA) Section 333 Safety Observer Standard Operating Procedures

Unmanned Aircraft Unmanned Aircraft System Visual Flight 

Rules Visual Line of Site Visual Meteorological Conditions

Vertical Takeoff and Landing 

3 

SUMMARY 

PAUL C. TRONIER seeks exemption from the requirements of 14 

C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b), to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit Sky Media NV LLC to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting aerial 

video and photography of construction sites, building inspections, 
agricultural lands, wineries, outdoor recreational facilities, real estate, 

special events, and landscapes within the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Sky media NV LLC will provide its clients with the highest quality 

digital content for use in their commercial, personal, and non-profit 

multimedia projects. Sky Media NV LLC will bring together years of 

professional marketing expertise, award-winning production talent and 

state-of-the-art technology to make studio quality productions within 

reach for organizations of any size. Sky Media NV LLC will also 

leverage years of professional Private Pilot experience and aerial 

knowledge to become a leading provider of geomapping and image 

analysis services to the civil engineering and environmental monitoring 

industries. Sky media NV LLC has over 10 years of recreational/hobby 

aircraft, rotorcraft and multi rotorcraft experience and over 1 year in all 

aspects of aerial video and photography. The objective of Sky Media 

NV LLC is to provide aerial video and photography operations in high 

quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting: 

•

• Aerial event filming and photography 

• Promotional videos for businesses, non-profits & government entities 

• Local Search and Rescue missions 

• Agricultural surveys and environmental monitoring 

• Civil engineering inspection and documentation 

4 
BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS Sky Media NV LLC 

seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Inspire 1 (Inspire 1) is a 

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

Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. The Inspire 1 is an electric powered rotary wing UAS that is 

capable of transmitting live airborne video images and location 

information to a Ground Control Station (GCS). The Inspire stores the 

photographs and data on board and makes them available for download 

after completion of the flight. The Inspire is 22 in x 22 in x 8 in and 

weighs 6.4 pounds, well under the 55 lbs mandated in the FMRA. The 

Inspire can conduct hovering flight and has a maximum cruising speed 

of 42 knots. It is battery powered, has a flight endurance of 15-22

minutes and can operate in temperatures ranging from 0° to 40° C. The 

Inspire’s omni-directional antenna has a range of 2.1 km and operates in 

the 2.420 – 2.483 GHz frequency range. 

The Inspire 1 that will be operated by Sky Media NV LLC will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, 

as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking. 

BASIS FOR PETITION 

Petitioner, Sky Media NV LLC, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization 

and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator 

to commercially operate the DJI Inspire 1 in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R 

§§ 

5 
61.101(e)(4) and (5), 61.315(a), 61.23(a), 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, Sky Media’s 

operation of the DJI Inspire 1 UAS meets the conditions of FMRA 

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

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

Accordingly, Sky Media NV LLC requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as 

these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. 

Sky Media NV LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Sky Media NV LLC will use 

experienced personnel or technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, 

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

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

Furthermore, Sky Media NV LLC will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

Relief from certain requirements of Section 61.101(e)(4) and (5) entitled 

Recreational pilot privileges and limitations: Pilot in command, and 

from Section 61.315(a) entitled What are the privileges and limits of my 

sport pilot certificate, and from Section 61.23(a) entitled Medical 

certificates: Requirements and duration, is requested by Sky Media NV 

LLC to the extent necessary to allow a Pilot in Command (PIC) holding 

a sport pilot or higher level certificate, as well as a valid driver’s license, 

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 

6 

exemption, including evasive and emergency maneuvers and 
maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Sky Media NV LLC 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.F.R. Part 21, Subpart 

H. As such, Sky Media NV LLC submits that it will ensure that the DJI 

Inspire 1 UAS are in an airworthy condition, prior to every flight, by 

determining that the UASs 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. 

Sky Media NV LLC also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UA will 

not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Inspire 1 UA will be provided to the PIC via 

Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UA to the GCS for active 

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

Sky Media LLC’s operation of the DJI Inspire 1 UAS within visual line 

of sight (VLOS), at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, Sky Media NV LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight 

in VFR conditions. Sky Media NV LLC submits that safety will not be 

affected by operation of the DJI Inspire 1 UA during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), 

with enough battery power to fly for a total duration of approximately 

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

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

7 

In accordance with 14 C.F.R. § 11.81, Sky Media NV LLC provides the 
following information in support of its petition for exemption: A. 

Name And Address Of The Petitioner.

  The name and address of the Petitioner and point of contact is: 

Paul Tronier Sky Media NV LLC 7336 omni dr Sparks, NV 

89441 Tel: (775) 772-1413 Email: Skymedianv@yahoo.com

B. The Specific Sections Of 14 C.F.R. From Which Sky Media NV 

LLC Seeks Exemption. 

1. Sky Media NV LLC Seeks Exemption From The Requirements 

Of Section 61.101(e)(4) and (5). 

Section 61.101, entitled Recreational pilot privileges and limitations: 

Pilot in command, subsection (e)(4) and (5) prescribe the following, in 

relevant part: 

(e) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircraft--

(4) For compensation or hire; (5) In furtherance of a business; 

2. Sky Media NV LLC Seeks Exemption From The Requirements 

Of Section 61.23(a). 

Section 61.23(a), entitled Operations requiring a medical certificate: 

Requirements and duration, subsection (a) prescribe the following, in 

relevant part: 

(f) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircraft--

8 

3. Sky Media NV LLC Seeks Exemption From The Requirements 

Of Section 61.315(a). 

Section 61.315(a), entitled What are the privileges and limits of my sport 
pilot certificate, subsection (a) prescribe the following, in relevant part:

(c) You may not act as pilot in command of a light-sport aircraft: 

(2) For compensation or hire. 

(3) In furtherance of a business.--

4.Sky Media NV LLC 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. 

5. Sky Media NV LLC 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. 

9 
6. Sky Media NV LLC 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. 

7. Sky Media NV LLC 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[.] 

8. Sky Media NV LLC From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a)(1), states the 

following: 

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

preventive maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized 

under § 43.7 of this chapter[.] 

9. Sky Media NV LLC Seeks Exemption From The Requirements 

Of Sections 91.409(a)(1) and 91.409(a)(2). 
Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may 

operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and 

has been approved for return to service by a person authorized by § 43.7 

of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance 

10 

with part 21 of this chapter. 

10. Sky Media NV LLC 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 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

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

the work performed; and 

(ii) The date of completion of the work performed; and 
(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

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

and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance. 

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

which are required to be overhauled on a specified time basis. 

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

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

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

safety directives including, for each, the method of compliance, the AD 

or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

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

11 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

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

periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed. 

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

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

43.11 of this chapter shall be retained until the defects are repaired and 

the aircraft is approved for return to service. 

C. The Extent Of Relief Sky Media NV LLC Seeks And The Reason 

Sky Media NV LLC Seeks The Relief. 

1. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky 

Media NV LLC Seeks Relief From Section 61.113(a) and (b). 

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

and limitations: Pilot in command, is requested to the extent necessary 

to allow a PIC holding a private pilot or higher level certificate, as well 

as a current and valid airman medical certificate, and who has met 

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

UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 

61.113(a) and (b) state that a private pilot may, for compensation or hire, 

act as PIC of an aircraft in connection with any business or employment 

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

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

or hire. 

As set forth more fully below, Feather Light Media LLC submits that an 

equivalent 

level of safety will be maintained because no PIC will be allowed to 

operate the DJI Inspire 

1 UAS UA unless that PIC has met certain flight-hour and currency 

requirements, 

12 

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, Sky Media NV LLC 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 Sky Media NV LLC business; and (2) will not 

carry passengers or property for compensation or hire. 

2. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky 

Media NV LLC Seeks Relief From Section 61.23(a). 

Relief from Section 61.23(a), entitled Operations requiring a medical 

certificate: Requirements and duration, is requested to the extent 

required to necessary to allow a PIC holding a sport pilot certificate or 

higher level certificate, as well as a current and valid driver’s license, to 

conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.23(a) 

otherwise require the PIC of any flight for compensation or hire to hold 

a comprehensive FAA issued medical certificate. In Exemption No. 

11213 to Aeryon Labs, Inc., the FAA “finds that, because of the risk 

mitigations established in the conditions and limitations of this 

exemption, a person that holds a U.S. issued driver’s license who is 

operating a UAS will not adversely affect safety. The FAA is granting 

relief from § 61.23(a) to allow any pilot that holds one of the pilot’s 

certificates discussed above to operate a UAS under this exemption with 

a U.S. issued driver’s license, in lieu of an FAA-issued medical 

certificate. The FAA is also granting relief from § 61.23(c) to allow 

sport pilot certificate holders to operate aircraft other than LSA with a 

U.S. issued driver’s license under this exemption.” 

13 

3. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky 
Media NV LLC Seeks Relief From Section 61.315(a). 

Relief from Section 61.315(a) entitled What are the privileges and limits 

of my sport pilot certificate, is requested to the extent necessary to allow 

a PIC holding a sport pilot or higher level certificate to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 

61.315(a) restrict a sport pilot from acting as the PIC of any flight for 

compensation or hire, or for the furtherance of any business. 

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re-assessed the 

level of pilot certificate that would be appropriate for the petitioner’s 

operations. In evaluating this petition, similar to the evaluation of the 

private and commercial pilot certificates in Exemption No. 11062, the 

agency compared the aeronautical knowledge requirements of the 

recreational and sport pilot certificates to those of the private pilot 

certificate. They found that the aeronautical knowledge requirements 

that would be applicable to a UAS operation for a recreational pilot and 

sport pilot certificate are substantially similar as those for a private pilot 

certificate. 

Additionally, similar to the private and commercial pilot certificates, 

holders of recreational and sport pilot certificates are subject to security 

screening by the Department of Homeland Security (DHS). 

Therefore, because they must demonstrate aeronautical knowledge 

relevant to UAS operations and are subject to DHS screening, factors 

that were considered by the FAA in allowing private pilot operations 

under previous exemptions, the FAA now determines that holders of 

recreational and sport pilot certificates may serve as the PIC for UAS 

operations. 

14 

4. Extent Of Relief Sky Media NV LLC Seeks And The Sky Media 

NV LLC 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 Feather Light Media LLC 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., the DJI Inspire 1 Maintenance Manual, 

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

Sky Media NV LLC seeks the requested relief because the DJI Inspire 1 

UAS do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Sky Media NV LLC 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 Instruction Manual) prior to every flight, and 

further, determine that the aircraft are in condition for safe flight, as 

stated in the conditions and limitations below. 

5. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky 

Media NV LLC Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required 

to allow flight operations of the DJI 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), Sky Media NV LLC seeks the requested relief because the DJI 

Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, 

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

flight. 

15 

Considering the limited altitude of the proposed operations, relief from 

14 CFR 91.121 is sought to the extent necessary to comply with the 

applicable conditions and limitations stated below. As more fully set 
forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 UA (s) 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. 

6. Extent Of Relief Sky Media NV LLC Seeks And The Sky Media 

NV LLC Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in 

VFR conditions, is requested to the extent required to allow flights of the 

battery powered DJI Inspire 1 UA (s) during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a 

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

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

Sky Media NV LLC seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery 

powered DJI Inspire 1 UA will severely constrain the practicality of any 

aerial video or still photo flight operations that Sky Media NV 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, and Sky Media 

NV LLC’s proposed operating limitations, ensure that Sky Media NV 

LLC will safely operate the battery powered DJI Inspire 1 UA (s) during 

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

flight rules (VFR), with enough battery power to fly for a total duration 

of 13.5 minutes to the first point of intended landing and, assuming 

normal 

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

16 

7. Extent Of Relief Sky Media NV LLC Seeks And The Reason Sky 

Media NV LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 
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, Sky Media NV 

LLC requests 

relief from these Sections because the DJI Inspire 1 UAS does not 

require airworthiness 

certificates. As set forth more fully below, the DJI Inspire 1 UAS meets 

the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Sky Media NV LLC 

will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and 

practices 

prescribed in the UAS operating documents (i.e., the DJI Inspire 1 

Maintenance Manual, 

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

Furthermore, Sky 

Media NV LLC will document and maintain all maintenance records for 

the DJI Inspire 1 

UAS. 

D. The Reasons Why Granting Sky Media NV LLC 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 and safety 

by allowing Sky Media NV LLC to safely, efficiently, and economically 
conduct aerial video and photography of construction sites, building 

inspections, agricultural lands, wineries, outdoor recreational facilities, 

Assistance in Search and Rescue applications, real estate, special events, 

and landscapes over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of 

the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of Sky Media NV LLC’s proposed 

operation of the DJI Inspire 1 UAS will be realized without implicating 

any privacy issues. 

17 

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

The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to 

obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of 

a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the safety of life 

and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the 

NAS, congestion around airports caused by arriving and departing 

aircraft will be reduced. The DJI Inspire 1 UAS do not require an airport 

to takeoff or land. Likewise, a reduction of manned aircraft conducting 

aerial video and photography missions would result in fewer aircraft that 

must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The 

DJI Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial 
video and still photography flight operations. By using battery power 

and electric motors, the DJI Inspire 1 UAS produce no air pollution, and 

is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, 

while reducing the carbon footprint of aerial acquisitions, also eliminates 

noise pollution, as the UASs are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

18 

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack 

of flight crew members located onboard the aircraft, the DJI Inspire 1 

UAS (weighing approximately 6.5 pounds maximum gross weights with 

a length of 17.3 inches, width of 17.7 inches, and with no fuel on board), 

has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with 

a wingspan of approximately 42 feet, a length of 34 feet, and a fuel 

capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The 

DJI Inspire 1 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Inspire 1 is also an 

economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Inspire 1 UAS will allow 

United States based companies, like Sky Media NV LLC, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, 

with the rising cost of aviation fuel and the Environmental Protection 

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, 

U.S. owned and operated companies must adopt new and alternative 
technology in order to remain competitive. Operating the battery 

powered DJI Inspire 1 UAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, 

but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the DJI Inspire 1 UAS, companies such as Sky Media NV 

LLC, 

can remain competitive and profitable, and therefore, provide greater job 

stability to 

employees and contractors, which will ultimately contribute to growth of 

the U.S. 

19 

economy. Improved financial performance of U.S. companies, through 

commercial use of the DJI Inspire 1 UAS, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development 

in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, Sky Media NV LLC proposed operation of the 

DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, 

the DJI Inspire 1 UAS will be operated only in compliance with the 

conditions set forth in any exemption granted under this petition. 

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 Sky Media NV LLC Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 
In consideration of the size, weight, speed, and limited operating area 

associated with the unmanned aircraft and its operation, Sky Media NV 

LLC operation of the DJI Inspire 1 UAS meet the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in 

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

Section 333 provides authority for a UAS to operate without 

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 (NAS) before 

completion of the plan and rule making required by section 332 of this 

Act or the guidance required by section 334 of this Act. 

20 

(b) Assessment of Unmanned Aircraft Systems.--In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum--

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

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a 

hazard to users of the national airspace system or the public or pose a 

threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under 
this section that certain unmanned aircraft systems may operate safely 

in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft systems in the 

national airspace system. 

In seeking this exemption, Sky Media NV LLC submits that the DJI 

Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 

UAS; (b) the pilot certification requirement; and (c) the specific 

operating limitations. 

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its 

Safe Characteristics. 

The DJI Inspire 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 DJI Inspire 1 UAS. 

The technical specifications of the DJI Inspire 1 UAS is set forth by the 

DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit 

A. 

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation 

Modes Enable The UAS To Remain Within A Defined Operational 

Area. 

The DJI Inspire 1 UAS may be operated in both manual and fully 

autonomous flight 

modes. A complete description of the flight and navigational modes of 

the DJI Inspire 1 

21 

UAS is provided in the DJI Inspire 1 User Manual, attached hereto as 

Exhibit B. 
iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link 

Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 UA will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Inspire 1 UA does not reacquire control link data from the GCS, the UA 

will assume that the Control Link is lost and the UA will return to the 

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

takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 

UAS are set forth in the DJI Inspire 1 User Manual, attached hereto as 

B. 

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 in the DJI Inspire 

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

B. 

b. Flight Operations Of DJI Inspire 1 UAS Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

Sky Media NV LLC will only utilize certificated pilots who possess a 

current and valid airman medical certificate to act as a pilot in command 

(PIC) of the DJI Inspire 1 UAS. Additionally, a safety observer will 

assist all pilots during flight time. 

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, 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 UASs 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1 

Unmanned Aircraft System. 

22 

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 500 feet 

above ground level (AGL), as indicated by the procedures specified in 

the operating documents unless a special request is made and approved 

by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the 

PIC at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate. 

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 perform the functions 

prescribed in the operating documents. 
8. The SO must not perform any other duties beyond assisting the PIC 

with seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or 

other instruments. 

9. The operating documents and the grant of exemption must be 

accessible during UAS operations 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 

23 

condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating 

until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station 

must be included in the preflight inspection. All maintenance and 
alterations must be properly documented in the aircraft records. 

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

the UAS operation or flight characteristics, e.g. replacement of a 

flight critical component, must undergo a functional test flight. The 

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

the aircraft records. 

12. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment, 

not already covered in the relevant sections of the operating 

documents. 

13. The operator must follow the UAS manufacturer’s 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. 

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

record keeping requirements, in accordance with the operating 

documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the 

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

accomplished, and the signature of the authorized person returning 

the UAS to service. 

15. Each UASs operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

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

the corrective action taken against discrepancies discovered 

between inspections. 

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

a current third- class medical certificate. 
18. The operator may not permit any PIC to operate unless the PIC 

meets the operator’s qualification criteria and demonstrates the 

ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs 

are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the 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. § 

19.1. All operations must be conducted under visual meteorological 

24 

conditions (VMC). If flight at night is required, a special request will be 

made at the FAA office closest to proposed area of operations. Flights 

under special visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport 

reference point as denoted on a current FAA-published 

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

management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. 

The letter of agreement with the airport 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. 

22. If the UA loses communications or loses its GPS signal, it must 

return to a pre- determined location within the planned operating 

area and land or be recovered in accordance with the operating 

documents. 

23. The PIC must abort the flight in the event of unpredicted 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 (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used 

for operation and control of the 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. 

25 

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 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. Permission from land owner/controller 

or authorized representative will be obtained for each flight to be 

conducted. 

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

lateral or vertical boundaries of the operational area as defined by 

the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety. 

Sky Media NV LLC submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained because no 

PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the 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. 

26 

Considering Sky Media NV LLC proposed area of operations, and the

operating limitations set forth-above; the parallel nature of sport 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, Sky Media NV LLC 

submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship 

skills necessary for Sky Media NV LLC 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). 

Sky Media NV LLC 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 of 

UAS to be used for operations under the exemption). In addition to the 

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

the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented 

flight 

27 

experience that was obtained in compliance with applicable regulations 

will ensure an equivalent level of safety during Sky Media NV LLC 

proposed operations. The Administrator has held that prior documented 

flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

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

operations for the purpose of motion picture filming (or similar 
operations), the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 

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

multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a 

UAS pilot operating the same make and model of UAS to be used for 

operations under the exemption. For clarification, the FAA considers 

these minimum hour requirements to be inclusive rather than additive; 

i.e. 5 hours make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 hours 

of UAS rotorcraft time. In addition to the hour requirements, the PIC 

must accomplish 3 takeoffs and landings in the preceding 90 days (for 

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

requirements in Exemption No. 11062 are appropriate to practice and 

build proficiency in the skills necessary to safely conduct the petitioner’s 

proposed operations. The FAA also finds that prior documented flight 

experience that was obtained in 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, Sky Media NV will 

ensure safe operations by not allowing any 

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

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

PIC is able to safely operate the 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 

28 

because prior to every flight, Sky Media NV LLC 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. Exemption Nos. 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 UAS to 

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

altitude information, combined with Sky Media NV LLC’s operation of 

the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet 

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

altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to 

UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption 

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

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 
11161). 

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety 

established by 

29 

14 C.F.R. 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, Sky Media NV will ensure that it will safely operate the 

battery powered DJI Inspire 1 UA during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 

minutes to the first point of intended landing and, assuming normal 

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

Here, as in Exemption No. 11109, the technical specifications 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 UAS, in 

circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 

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

30 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) 

Would Not Adversely Affect Safety. 

In seeking this exemption, Sky Media NV LLC 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)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Sky 

Media NV LLC 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 

DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual). Furthermore, Sky Media Nv LLC 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, Sky Media NV LLC 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 Manuals are attached 

hereto as Exhibit B; a copy of the DJI Inspire 1 Maintenance Manual is 

attached hereto as Exhibit C; a copy of the DJI Inspire 1 UAS 

Maintenance LOG is attached hereto as Exhibit D. 

Likewise, the exemption sought will not adversely affect safety because 

Sky Media NV LLC will use trained technicians to perform 

maintenance, alterations or preventive maintenance on the UAS using 

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

Furthermore, the exemption sought would maintain an equivalent level 

of safety established by Sections 91.407, 91.417(a) and 91.417(b), 

because all maintenance of the DJI Inspire 1 UAS will be performed by 

trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. 

31 

Significantly, previous exemptions granted by the FAA concerning 

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

(b) establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. 

In consideration of Sky Media NV LLC proposed operating limitations, 

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

UAS, Sky Media NV LLC 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, 

Sky Media NV LLC 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, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b). Such special conditions will permit safe operation of the UAs for 

the limited purpose of conducting aerial video and photography over 

certain areas of the United States for compensation or hire. FMRA 

Section 333 sets forth the requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security; and further, provides the 

32 

authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant 

to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design 

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

the following: 

If the FAA finds that the airworthiness regulations of this subchapter do 

not contain adequate or appropriate safety standards for an aircraft, 

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

of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller 

as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 

333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation 

of the DJI Inspire 1 UAS, which contain such safety standards that the 
Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which Sky Media NV LLC Seeks 

Exemption: 

Sky Media NV LLC seeks exemption from the requirements of 14 C.F.R 

Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Sky Media 

NV LLC Seeks: 

This exemption will permit Sky Media NV LLC to commercially operate 

an 

33 

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

video and photography over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To 

Support Sky Media NV LLC 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, Sky Media NV LLC request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a 
UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification. 

As discussed in detail above, Sky Media NV LLC will operate the DJI 

Inspire 1 UASs safely in the NAS, without creating a hazard to users of 

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

CONCLUSION 

As set forth herein, Sky Media NV LLC seeks an exemption pursuant to 

14 C.F.R § 11.61 and Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA), which will permit safe 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 Sky Media NV LLC to safely, 

efficiently, and economically operate the DJI Inspire 1 UAS 

34 

commercially within the NAS. WHEREFORE, in accordance with 

the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Sky Media NV 

LLC respectfully requests that the Administrator grant this Petition for 

an exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) 

and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Sky 

Media NV LLC to operate the DJI Inspire 1 UAS commercially for the 

purpose of conducting aerial video and photography over areas of the 

United States.

Dated: July 20, 2015 
Respectfully submitted, Paul Tronier 

Paul C. Tronier Sky Media NV LLC 336 omni dr Sparks, NV, 89441 

Tel: (775) 772-1413 Email: skymedianv@yahoo.com 

35 

Exhibits: 

A – DJI Inspire 1 Specifications Data Sheet B – DJI Inspire 1 

Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D 

– Monthly Maintenance Log 

EXHIBIT – A DJI Inspire 1 Specifications Data Sheet 

36 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

37 

Aircraft 

Model 

T600 

Weight (Battery Included) 

2935 g 

Hovering Accuracy (GPS Mode) 

Vertical: 0.5 m Horizontal: 2.5 m 

Max Angular Velocity 

Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° 

Max Ascent Speed 

5 m/s 
Max Descent Speed 

4 m/s 

Max Speed 

22 m/s (ATTI mode, no wind) 

Max Flight Altitude 

4500 m 

Max Wind Speed Resistance 

10 m/s 

Max Flight Time 

Approximately 18 minutes 

Motor Model 

DJI 3510 

Propeller Model 

DJI 1345 

Indoor Hovering 

Enabled by default 

Operating Temperature Range 

-10° to 40° C 

Diagonal Distance 

559 to 581 mm 

Dimensions 

438x451x301 mm 

Gimbal 

Model 
ZENMUSE X3 

Output Power (With Camera) 

Static: 9 W In Motion: 11 W

Operating Current 

Station: 750 mA Motion: 900 mA Angular Vibration Range ±0.03° Mounting

  Detachable 

Controllable Range 

Pitch: -90° to +30° 

38 

Pan: ±320° 

Mechanical Range 

Pitch: -125° to +45° Pan: ±330° 

Max Controllable Speed 

Pitch: 120°/s Pan: 180°/s 

Camera 

Name 

X3 

Model 

FC350 

Total Pixels 

12.76M 

Effective Pixels 

12.4M 

Image Max Size 
4000x3000 

ISO Range 

100-3200 (video) 100-1600 (photo) Electronic Shutter Speed 8s - 1/8000s 

FOV (Field Of View) 

94° 

CMOS 

Sony EXMOR 1/2.3” 

Lens 

20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups

Anti-distortion 

Still Photography Modes 

Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 

3/5 bracketed frames at 0.7EV Bias Time-lapse Video Recording Modes  UHD 

(4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 

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

Max Bitrate Of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported SD Card Types 

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required. Operating 

Temperature Range  0° to 40° C 

39 

Remote Controller 

Name 
C1 

Operating Frequency 

922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz 

Transmitting Distance (Outdoor And Unobstructed) 

2 km 

EIRP 

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G 

Video Output Port 

USB, mini-HDMI 

Power Supply 

Built-in battery 

Charging 

DJI charger 

Dual User Capability 

Host-and-Slave connection 

Mobile Device Holder 

Tablet or Phone 

Max Mobile Device Width 

170mm 

Output Power 

9W

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 
Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C Charging 

Temperature Range 0-40° C 

Battery 

6000 mAh LiPo 2S 

Charger 

Model 

A14-100P1A 

Voltage 

26.3 V 

Rated Power 

100 W

Battery (Standard) 

Name 

Intelligent Flight Battery 

Model 

TB47 

Capacity 

4500 mAh 

Voltage 

22.2 V 

Battery Type 

LiPo 6S High voltage battery 

Energy 

40 
99.9 Wh 

Net Weight 

570 g 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C 

Charging Temperature Range 

0° to 40° C 

Max Charging Power 

180 W

Vision Positioning 

Velocity Range 

Below 8 m/s (2 m above ground) 

Altitude Range 

5-500 cm 

Operating Environment 

Brightly lit (lux > 15) patterned surfaces 

Operating Range 

0-250 cm 

Exhibits: 

A – DJI Inspire 1 Specifications Data Sheet B – DJI Inspire 1 

Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D 

– Monthly Maintenance Log 
EXHIBIT – B DJI Inspire 1 Manufacturer’s User Manual 

41 

Exhibits: 

A – DJI Inspire 1 Specifications Data Sheet B – DJI Inspire 1 

Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D 

– Monthly Maintenance Log 

Exhibit – C DJI Inspire 1 Maintenance Manual 

42 

Exhibits: 

A – DJI Inspire 1 Specifications Data Sheet B – DJI Inspire 1 

Manufacturer’s User Manual C – DJI Inspire 1 Maintenance Manual D 

– Monthly Maintenance Log 

EXHIBIT – D Monthly Maintenance Log 

43 

month: year: 

EXHIBIT – D 

MONTHLY MAINTENANCE LOG 

UAS #: Date Issue 

Discovered 

Date Issue 

Addressed Issue Description & Maintenance Conducted 

Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 
Vibration Dampening 

Other: 

44