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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

NORCAL AERIALS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS

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 November 15, 2015

NORCAL AERIALS

6413 Via Giardiano

Modesto, CA. 95357-0661

209-304-5600

NorCalAerials@yahoo.com
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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........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH NORCAL AERIALS

SEEKS EXEMPTION.............................................................................................6

THE EXTENT OF RELIEF NORCAL AERIALS SEEKS AND THE REASON 

NORCAL AERIALS SEEKS THE RELIEF.............................................10

THE REASONS WHY GRANTING NORCAL AERIALS’S REQUEST

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..................26

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT NORCAL AERIALS’S REQUEST.........27

CONCLUSION....................................................................................................................27

APPENDICES........................................................................................28
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

BFR Bi-annual Flight Review

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOA Letter of Agreement

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

NORCAL AERIALS seeks exemption from the requirements of 14 C.F.R §§ 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 

NORCAL AERIALS to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, and 

landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

NORCAL AERIALS owner, James B. McKay, holds a Private Pilot certificate 3138737 

with an IFR rating. Mr. McKay has a current BFR, Airman Third Class Medical and has 

over 1,000 PIC time free of any accidents or incidents. Additionally, Mr. McKay received 

his Drone Certification from DRONE University USA Sacramento California on July 12, 

2015. He has over four years of flying sUAS aircraft. The objective of NORCAL

AERIALS and his aerial operations is to provide high quality imaging for a variety of

commercial, public, and residential uses, specifically targeting but not limited to:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Event and Small Business Marketing

• Aerial acquisitions used for inspections of public and private 

structures.

• Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

NORCAL AERIALS seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned 
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Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart

phone systems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a

length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of

approximately 42 knots. The DJI Inspire 1 UAS is equipped with four main rotors;

driven by Lithium Polymer battery powered electric motors.

The DJI Inspire 1 UAs that will be operated by NORCAL AERIALS 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, NORCAL AERIALS, 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 UAS in the

National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R §§ 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, NORCAL AERIALS operation of 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, NORCAL AERIALS 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.

NORCAL AERIALS submits that the requested relief is proper since an equivalent level 

of safety will be ensured. NORCAL AERIALS will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance 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, 

NORCAL AERIALS will document and maintain all maintenance records for the DJI 

Inspire 1 UAS.

NORCAL AERIALS 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, NORCAL AERIALS submits 

that he will ensure that the DJI Inspire 1 UAS are 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.
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NORCAL AERIALS 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 1UAs will be provided 

to the PIC via Global Positioning System (GPS) equipment and radio communications 

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

flight path. This altitude information, combined with NORCAL AERIALS’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.

Additionally, NORCAL AERIALS seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. NORCAL AERIALS

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 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.

In accordance with 14 C.F.R. § 11.81, NORCAL AERIALS 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: 

NORCAL AERIALS

4613 Via Giardiano

Modesto, CA. 95357-0661

209-304-5600

NorCalAerials@yahoo.com

B. The Specific Sections Of 14 C.F.R. From Which NORCAL AERIALS Seeks

Exemption.

1. NORCAL AERIALS 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.
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2. NORCAL AERIALS 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.

3. NORCAL AERIALS 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.

4. NORCAL AERIALS 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[.]

5. NORCAL AERIALS Seeks Exemption From The Requirements Of

Section 91.407(a)(1)
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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[.]

6. NORCAL AERIALS Seeks Exemption From The Requirements Of

Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

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

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

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

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

chapter; or

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

accordance with part 21 of this chapter.

7. NORCAL AERIALS 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 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
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(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 

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.
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C. The Extent Of Relief NORCAL AERIALS Seeks And The Reason

NORCAL AERIALS Seeks The Relief.

1. The Extent Of Relief NORCAL AERIALS Seeks And The Reason

NORCAL AERIALS Seeks The Relief From Section 91.7(a).

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

required to allow NORCAL AERIALS 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 NORCAL AERIALS Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Inspire 1

Instruction Manual).

NORCAL AERIALS 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, NORCAL AERIALS 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 Inspire1 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.

2. Extent Of Relief NORCAL AERIALS Seeks And The Reason NORCAL 

AERIALS 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), NORCAL AERIALS 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.

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.
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3. Extent Of Relief NORCAL AERIALS Seeks And The Reason NORCAL 

AERIALS Seeks 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 UAs 

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

(VFR), for a total duration of 13.5 minutes to the first point of intended landing and,

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

AERIALS 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 that NORCAL

AERIALS 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 NORCAL AERIALS’s proposed operating

limitations, ensure that NORCAL AERIALS 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 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.

4. Extent Of Relief NORCAL AERIALS Seeks And The Reason NORCAL 

AERIALS 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, NORCAL AERIALS 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, 

NORCAL AERIALS 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., the NORCAL AERIALS Aerial

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

Furthermore, NORCAL AERIALS will document and maintain all maintenance records

for the DJI Inspire 1 UAS.
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Granting the present Petition will further the public interest by allowing NORCAL

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

photography of construction sites, real estate, and landscape 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 NORCAL AERIALS’s proposed operation of the DJI Inspire 1 UAS will be

realized without implicating any privacy issues.

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 Phantom 3 or DJI Inspire 1 UAS would reduce the

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase

the safety of life and property in the air and on the ground.

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom

2 and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction

of manned aircraft conducting aerial video and photography 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
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reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the

UAs are propelled by battery powered electric motors, rather than an internal combustion 

engine.

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 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, 

at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively,

widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less

physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically 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 UAS are 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 NORCAL

AERIALS, 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 NORCAL AERIALS, can 

remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through 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.
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Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, NORCAL AERIALS’s 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 operating documents (i.e., the NORCAL AERIALS Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude

requirements of 14 C.F.R. §

91.119.

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

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

Provided By The Rule From Which NORCAL AERIALS Seeks Exemption.

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

FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, NORCAL AERIALS’s 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 before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act.

(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
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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, NORCAL AERIALS 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 do not create a hazard to users of the NAS or the public, or

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

operational capability.

i. Technical Specifications Of The DJI Inspire 1

UAS.

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

User Manuals, attached hereto as Appendix A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation

Modes Enable The UAS To Remain Within A Defined Operational 

Area.
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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 

UAS is provided at pages pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, 

attached hereto as Appendix A.

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 UAs will remain stationary, in flight, for

3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAs do not reacquire control link 

data from the GCS, the UAs will assume that the Control Link is lost and the UAs will 

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

position and shutdown.

A complete description of the Failsafe Functions for the DJI Inspire 1 at pages 13 through 

15 of the DJI Inspire 1 User Manuals, 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 on pages 40 through 47 of the DJI Inspire 1 User

Manual. DJI Inspire 1 User Manuals are attached hereto as Appendix A.

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

Sight Of A Certificated Pilot in Command With A Safety Observer.

NORCAL AERIALS will be the only person to act as a pilot in command (PIC) of the DJI 

Inspire 1 UAS. Additionally, a safety observer will assist him during flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted

Pursuant To Specific Operating Limitations.
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In seeking this exemption, NORCAL AERIALS 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 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.
18

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 

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
19

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 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 

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.
20

§ 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 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.

NorCal Aerials has a current Letter of Agreement with Modesto, CA [KMOD] 

Air Traffic Manager Pete Echevarria dated October 30, 2015. This LOA allows 

NorCal Aerials to practice within a one (1) mile radius of the MOD VOR 

226R/3.5dme, Appendix C defines requirements and restrictions in the 

operation of the Inspire 1 UAS. 

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.
21

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.

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.
22

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.
23

2. 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, NORCAL AERIALS 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).

3. 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 with NORCAL AERIALS’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 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).

4. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

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

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

2 and DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, NORCAL AERIALS 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
24

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).

5. 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, NORCAL AERIALS 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 NORCAL AERIALS 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 NORCAL AERIALS Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1

Instruction Manual). Furthermore, NORCAL AERIALS 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, 

NORCAL AERIALS 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 A; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached 

hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because

NORCAL AERIALS will use trained technicians to perform maintenance,
25

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.

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 NORCAL AERIALS’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, NORCAL AERIALS

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, NORCAL AERIALS

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 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
26

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 NorCal Aerials 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 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 NORCAL AERIALS Seeks Exemption:

NORCAL AERIALS seeks exemption from the requirements of 14 C.F.R Sections

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 NORCAL AERIALS

Seeks:

This exemption will permit NORCAL AERIALS to commercially operate an 

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

photography over certain areas of the United States.
27

• Any Additional Information, Views, Or Arguments Available To

Support NORCAL AERIALS’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, NORCAL AERIALS’s 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, NORCAL AERIALS 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.

CONCLUSION

As set forth herein, NORCAL AERIALS 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

NORCAL AERIALS 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 of 2012, Section 333, NORCAL AERIALS respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 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 James B. McKay 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: November 12, 2015. 
28

Respectfully submitted,

NORCAL AERIALS

James B. McKay - Owner

NORCAL AERIALS

4613 Via Giardiano

Modesto, CA. 95357-0661

209-304-5600
29

Appendices:

A – DJI Inspire 1 Specifications User Manual (See attached documents)

B – Monthly Maintenance Log (See attached documents)

C – Modesto, CA [KMOD] Letter of Agreement