September 3, 2015

Exemption No. 12754 Regulatory Docket No. FAA

− 20 15

− 0827

Mr. Robert Wise ImageWise Video LLC
18150 NW Clarno C our t Portland

, OR 97229

Dear Mr. Wise :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter posted to the public docket on June 2, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption

. You requested to operate a n unmanned ai rcraft system (UAS) to conduct aerial photos and videos of property or events, for purposes including real estate listings, insurance property claims, search and rescue, building and property inspections and review, land surveying or for use a s a marketing tool for businesses

, and for video/film production

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and
the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS pr oposed by the petitioner is a DJI Inspire 1

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the
aircraft and its operation, the Secretary of Transportation has determined that this aircraft
meets the con ditions of Section 333. Therefore, the FAA finds that the requested relief from
14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition.
In Grants of Exe mption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in a ll material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by th e Administrator, Mr. Robert Wise is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by
instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Mr. Robert Wise is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exempt ion are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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 or
U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PI C always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic 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 VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditi ons and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator must follow the procedures as outlined in its operating
docum ents. 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 or any law enforcement official upon request. The operator must a lso present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator mus t petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC wi th a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to en sure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, i noperable components, items, or equipment. 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 condi tion for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and
aircraft components.

12. Each UAS operated under this exemption must comply with all manufa cturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a
current FAA airman medical certificate or a valid U.S. driver’s l icense issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be5

operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with
14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and V Os (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA
wi th appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights
under s pecial visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve

power r ecommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification6

(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating 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 in a manner ensurin g the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property w ith permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTS B) per instructions
contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditi ons and limitations apply.7

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities
must include at least the f ollowing:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and ser ial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list o f those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminat es on September 30

, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/
John S. Duncan Director, Flight Standards Service

EnclosuresJames	M	Crotty

Manager,	Aircraft	and	Airport	Rules	Division 800	Independence	Ave	S.W. Washington	DC	20591

Re: Public	Docket	FAA

- 2015

- 0827

– Exemption	/	rulemaking	request

Your	name	and	mailing	address. You	may	include	other	contact	information	such	as	a	fax number,	telephone	number,	or	email	address;

Robert	Wise ImageWise	Video	LLC
18150	NW	Clarno	Ct.
Portland	OR	97229

503	724	5460 Rob@imagewisevideo.com

**The	extent	of	relief	you	seek	and	the	reason	you	seek	the	relief;**

14	C.F.R.	Part	21 14	C.F.R.	45.23(b) 14	C.F.R.	61.113(a)	&	(b) ; 14	C.F.R.	61.133(a) ; 14	C.F.R.	91.7(a) ; 14	C.F.R.	91.9(b)(2)	&	(c)
14	C.F.R.	91.103 ; 14	C.F.R.	91.109(a) ; 14	C.F.R.	91.119 ;14 C.F.R.	91.151(a) ; 14	C.F.R.	91.203(a)	&	(b) ; 14	C.F.R.	91.405(a) ; 14	C.F.R.	91.407(a)(1) ; 14	C.F.R.	91.409(a)(2) ;	14	C.F .R.	91.417(a).

Sec	333	prohibits	the	use	of	a	sUAS for	commercial	purposes	on	private	property.	I	am	the owner	of	a	video	production	company	that	providing	video	services	for	private	and corporate	special	events,	and	corporate	information	and	recording	service.	I	am petitioning	for	an	exemption	to	provide a	commercial	service	to	private	and	public	land owners	and	companies	who	wish	to	obtain	and	capture	aerial	photos	and	videos	of	said
property or	events, for	purposes	including	real	estate	listings,	insurance	property	claims, search	and	rescue,	building	an d	property	inspections	and	review, land	surveying	or for use	as	a	marketing	tool	for	businesses. Additional	use	may	be	for	video/film	production. I	would	like	to	be	able	to	accept	payment	for	these	services	therefore	making this	a
commercial	use	of	a	sUAS.**How	your	request	would	benefit	the	public	as	a	whole;**

My	request	benefits	the	public	as	a	whole	by	providing	an	opportunity	for	small	business

owners, real	estate	agents,	and	other	business	owners who	wish	to	document	their	land

, property ,		product or	company, to	take	advantage	of	the lower	cost	and technology	that
now	exists	in	the	form	of	sUAS’s	and	allows	them	to	do	so	us ing	an	experienced	and RC Pilot	in	Command	that	understands	how	to	safely	operate	such	technology.

**Reasons	why	the	exemption would	not	adversely	affect	safety,	or	how	the**  **exemption	would	provide	a	level	of	safety	at	least	equal	to	the	existing	rule;**

As	a	qualified	and	commercial	videographer	and	member	of	the	Drone	Pilots	Association,	I currently	exercise	many	safety	programs, including	SAFE	technology	and	GPS	navigating. When	flying	for	this	commercial	purpose	I	would	be	flying	at	a	maximum	altitude	of	200 Feet	and	flying	mostly	vertically	for	the	purposes	of	taking	photos,	decreasing	the	risk	of any	interference.	My	general	kn owledge	of	the	aviation	safety	systems	implemented	by the	FAA	would	be	used	to	ensure	that	safety	would	not	be	affected	by	my	operations.	I	will not	be	flying	near	high	traffic	areas	including	airports,	and	I	pay	attention	to	NOTAMS	by following	current	al erts	at	twitter.com/amagov	or	refer	to	pilotweb.nas.faa.gov/PilotWeb/

**I intend to follow these suggested safety regulations**

 Alway s keep aircraft in line of sight and under control.

 Accompan yi ng me will be a second person to moni tor the aircraft along with me.

 Alway s keep ing people and pets at least 35 feet (10 meters) away when the battery

is
connected.

 Keep children out of the vicinity of this product at all times.

 Alway s use full y charged batteries and do not fl y when batteri es are 25% or less power remaining.

 Utilize auto return home prior to batteries remaining power at 25% or less.

 Not fly

within 5 miles of any

airport or fly

in other no fly

zones.

 I have installed the dji Inspire 1 propeller l ocks which were sent out by DJI, which ensure an
added safet y la yer of propellers.

 The auto	home	point	return	feature,	which	returns	the	aircraft	to	either	when	the controller	is	or	where	the	Dji	Ins p ire	1 initially takes	off	from. This	can	be	used	when low	battery	level	customizable	thresholds	are	enabled,	or	if	the	aircraft	drifts,	for simple	recovery	and	automated	return	of	the	aircraft.

**Additional	safety	features	I	will	be	using	to	ensure	a	safe	and	responsible	flight	path**

**, inc**  **luding	the	following.**

**VISION	POSITIONING	SYSTEM** DJI’s	new	Optical	Flow	technology	uses	a	specially	designed	camera	as	well	as	sonic	waves to	bring	simplicity	and	safety	when	taking	off	and	landing. These	sensors	read	the	ground distance	and	ensure	a	smooth	take	off,	landing	or	use	in	doors	if	applicable. Thistechnology	allows	the	Inspire	to	hold	its	position,	stop	when	the	controls	are	released,	and

respond	to	your	commands	even	when	GPS	is	unavail able.

**INTELLIGENT	POWER	MANAGEMENT	SYSTEM** A	fully	integrated	intelligent	battery	powers	the	Inspire	1	and	virtually	manages	itself. When	in	flight, my	remaining	battery	power	is	shown	live,	letting me	know	know	how long	I	can continue	to	fly in	minutes

. Advanced	algorithms	calculate	the	distance	of	your aircraft	and	estimated	time	to	return	home,	letting	you	know	when	it’s	time	to	fly	back. The	battery	tracks	the	voltage	of	each	cell,	the	total	lifetime	charges	and	discharges,	and
the	overall	health	and	b attery	status.

**SAFE FLIGHT**

When GPS is available, the Home Point (the location you are standing) automatically refreshes, so the Inspire 1 always knows where you are even if you move around. When you tell it to come back, or in case of an emergency, it knows exactly where to go and land safely.

**FULL**

**- FEATURED APP**  In addition to line of site, I simultaneously have access to the camera and flight system with a comprehensive mobile app. Everything from manual camera controls to flight telemetry, auto
takeof f and landing are accessible on the controller and the app alike.

 **Position Hold**

– The DJI Inspire 1 uses GPS to hold a given location when this function is activated. If GPS is enabled and has a solid lock, the aircraft will hold its position when elevator or aileron inputs DJI Inspire 1 are at neutral.

 **Throttle provides proportional thrus t** 

– The throttle responds directly to the throttle input, giving the pilot direct control over hovering as well as ascent and descent rates.

**A summary we can publish in the Federal Register**

**—**

I, Robert Wise am seeking an exemption of the FAA’s Sec 333 rules that does not allow the use of a small Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safet y. I am simply petitioning for an exemption to provide a commercial service to private and public land owners and compani es who wish to obtain and capture a erial photos and videos of said property , private or public events, real estate listings, insurance propert y claims, inspections and review, marketing tool for business. As a member of the Drone Pilots
Associations I unde rstanding the importance of different uses and safet y concerns regarding FAA regulated airspace, I would be a good candidate for exemption of Sec 333 while not putting Air Safet y in an y accelerated risk. The specific sUAS ( DJI Inspire 1 whose Operating
Man ual is included in my petition) I am seeking exemption with is one with many safet y programs, including SAFE technology and GPS navigating. When fl yi ng for this commercial purpose I would be fly ing at a maximum altitude, not to exceed 500 feet and fly ing m ostly
verticall y for the purposes of taking photos, decreasing the risk of an y interference. M y general knowledge of the aviation safet y s ys tems implemented by the FAA would be used to ensure
that safet y would not be affected b y m y operations. I would not be fl yi ng near disaster areas sporting events, (unless specificall y hired to do so by the organizing management) or hightraffic areas including airports, and I would monitor and pay attention to NOTAMS. I appreciate the FAA’s consideration of this petitio n for exemption.

**Any additional information, views, or arguments available to support your request;**

I am fully aware of the preflight safet y checks and procedures implicated in the operation
manual for the DJI Inspire 1 and intend to implement preflight safety checks and utilize the
safet y technology provided with this unit. I intend to only

fl y in non

- populated, residential or rural areas and stay

clear of all utility

lines etc. I intend to be fully aware of my

surroundings at all times and to only

fl y the unmanned aircraft within a visual line of sight and only in Visual Flight Conditions and with a spotter.

I understand and will comply with all the health and safet y regulations for PI C’s and will be the only operator under this exemption.

**FCC Complia nce**  This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) This device must accept

any interference received, including interference that may cau se undesired operation. Changes or modifications not expressly approved b y the party

responsible for compliance could void the
user's authorit y to operate the equipment

**General Safety Precautions and Warnings I intend to follow** :

 Follow FAA guidelines for safe usage of sUAS flight.

 Maintain ing flight log data.

 Update the weather, wind and other factors prior to takeoff.

 I u se extreme caution if operating around buildings, people or othe r personal or business propert y, keeping the a ircraft at safe distances away

.

**If you want to exercise the privileges of your exemption outside the United States, you**
**must state the reason.**

Although I have no intention of using this exemption outside the United States at this time

, there may be a time in the future for limited or periodic use of the aircraft, outside the United
States . This could be for relocation

, destination videos for personal or commercial use. If used outside the United States, I w ill comply with that governmen t’s law s, exemptions and other applicable regulations.

I have attached a cop y of the Dji I nspire 1 operating manual and providing y ou with the link to
the manufacturer’s website where you can obtain more insight. http://www.dji.com/product/inspire

- 1/feature

Please contact me if I can follow up with any thing else regarding my

requested exemption. Thank y ou for y our consideration for approval.Sincerel y,

Robert Wise rob@imagewisevideo.com