Petition for Exemption Filed Under Section 333

Petitioner:

Ethan Perdue

616 Scottwoods Dr.

Auburn, AL 36830

(334) 663-4541

Objective:

The objective of this petition is to seek FAA exemption to Title 14 of Code of Federal 

Regulations, Part 21, Subpart H, 45.23(b) 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119(c), 

91.121, 91.151(a)(1), 91.203 (a)&(b), 91.405(a), 91.407(a)(l), 91.409(a)(l)&(2), 91.417(a)&(b).

Summary: 

I, Ethan R. Perdue, the petitioner request exemptions in order to operate a DJI Inspire 1 

Unmanned Aircraft System (UAS) within the National Airspace System. This is done in pursuant 

to Section 333 of the Federal Aviation Administration Modernization and Reform Act (FMRA) of 

2012. The purpose of this exemption is to allow Ethan R. Perdue to operate a UAS for the 

purpose of aerial photography and videography, primarily for real estate, surveying, 

landscaping, construction, and agricultural purposes.

The owner has UAS flight experience since June, 2015 with no incidents of financial loss to 

property and no instances of harm to the general public including a complete absence of “near 

misses.” Until the approval of this exemption, the owner is strictly experienced as a hobbits of 

UAS flight. 

Currently, the petitioner has taken steps to obtain the necessary licensing to fly a UAS for a 

commercial purpose. The petitioner is aware of this necessary step in order to fly for commercial 

purposes. Though this necessary step is not fully complete, it is noteworthy that the differences 

between the UAS system and small aircraft are quite different. However, it is noted that a 

knowledge of the available airspace between the two should be obtained for the sake of public 

safety. Therefore, the petitioner will not allow the UAS to be piloted for commercial purposes 

unless the controls are manned by a pilot with an appropriate license. 

Business Description/Public Interest:

Ethan R. Perdue (hereafter referred to as “the petitioner”) plans to offer contract aerial 

photography and videography for purposes for real estate, surveying, landscaping, and 

agricultural purposes. The nature of the images produced will be either utilitarian, entertaining, 

or both.

The purposes of the petitioner’s UAS operation is to provide quality video and photo imagery for 

the flowing:

! !

-Aerial video and images of potential real estate sales
-Aerial video and images of land sales

-Aerial video and images of landmarks

-Aerial video and images of building construction

-Aerial video and images pertaining to land surveys

-Aerial video and images of crops

-Aerial video and images of livestock

-Aerial video and images of land with stationary objects.

The petitioner will use a DJI Inspire 1 UAS as the flying object. This particular model has key 

features that enhance safety during flying. These features include:

! !

-GPS and GLONASS

-Visual sensors

-Live first-person view at the pilot controls

-Flight termination and return to home features

-Advanced power management system

-Flight telemetry (altitude, speed, distance)

-Built-in no-fly zones

-High definition graphic output

Exact specifications of the aircraft are as follows:

-Make/model: DJI Inspire 1 T600

-Class: Rotocraft

-UA max takeoff weight: 6.47 pounds

-Category: Land

-Engine manufacturer: DJI

-Engine model designation: DJI 3510

-Number of engines: 4

-Engine power output: 14 lbs. max thrust

-Engine type: electric

Regulatory Relief Requests and Reasoning:

Part 21, Subpart H

The operated UAS will not carry pilots, passengers, explosive materials, or flammable materials. 

Due to the size, speed, range, and weight of the UAS, I request an exemption. The restricted 

environment and conditions of use will be as safe or safer than a conventional aircraft operating 

with an airworthiness certificate without said restrictions.

45.23(b) 

The size of the UAS does not allow the option of a cockpit, cabin, or pilot station that would 

allow the use of particular words and phrases. Lettering would be difficult or impossible to place 

on an aircraft of such a small scale and would force the lettering to be under the size for the 

required minimum. The aircraft will be marked with an assigned number on the crafts exterior 

fuselage.

91.7(a)

Since there will be no airworthiness certificate for this aircraft, provided this exemption becomes 

granted, no FAA regulatory standard will exist for determining airworthiness. However, the 
petitioner of the UAS will ensure proper airworthiness through preflight checks and based upon 

the manufacturers operations manual

91.9(b)(2)

The small size of the aircraft does not allow the ability to carry a flight manual on the aircraft. In 

lieu of this, a proper manual will be available at the ground location where the petitioner will 

have immediate access to the required document.

91.103

Because FAA approved flight manuals will not be available for the aircraft, an exemption will be 

required. Typical procedures, such as reviewing weather patterns, flight power requirements, 

takeoff and landing distances, along with all information found within the attached document 

(Inspire 1- User Manual). Equivalent levels of safety will be available due to the preflight 

protocol to properly match the machine.

91.109 

The UAS does not have the availability of fully functional dual controls. Flight control is achieved 

by using a radio transmission control device. An equivalent set of controls is not provided 

because no pilots or passengers will be carried in the aircraft.

91.119(c)

The petitioner will not fly the UAS higher than 400” above ground level and will keep the aircraft 

within a line-of-sight over developed and developing residential areas that may be considered 

congested areas. Most often, this will not be the case. Most often, the petitioner will be providing 

a property survey flight over empty lots or acreages with little or no structures. This minimizes 

the amount of bystanders in the surrounding area. In the case of flying over or near existing 

private property while providing residential and commercial marketing material, construction 

process updates, or property inspections, the landowner and nearby residents will be notified in 

person at the site, via telephone before the flight, through cards left behind by the petitioner, or 

through signage created by the petitioner. The petitioner and property owners will review the 

risks to property and bystanders. The small size of the UAS does not present the same level of 

risk as a manned aircraft performing similar duties.

91.121

The UAS does not have a barometric altimeter, but relies on GPS among other electronics to 

determine altitude. In addition, the UAS has built in safeguards that ensure the craft does not fly 

above 400’ above ground level.

91.151(a)(1)

Built in safeguards provide the petitioner with a low battery warning and automatically returns 

the aircraft to the launch point or petitioner location. Upon the first low battery alert, the 

petitioner makes steps to return the UAS to a ground position. During the second warning, and 

automatic pilot feature lands the craft. Flights will be performed during the daylight hours and 

will be done in an unobtrusive manner.

91.203 (a)&(b) 

Due to the size and configuration of the aircraft, there will be no ability to carry certification and 

registration documents on the aircraft itself. Similarly to the pilot’s manual, the necessary 

registration and certification documents will be located at the petitioner location.
91.405(a)

The petitioner will inspect the status of the aircraft prior to each flight to ensure it is an airworthy 

condition. These precautions can be found within the aircraft’s user manual.

91.407(a)(l) 

The petitioner will accept responsibly for the operational safety of the UAS, and will follow the 

manufacturer’s guidelines for maintenance and repair. This includes the usage of first-party 

replacement parts.

91.409(a)(l)&(2)

The petitioner will follow the manufacturer’s guidelines to ensure that the UAS is in a condition 

that is safe for flight.

91.417(a)&(b)

The petitioner will keep a record of all repairs and modifications at the same location as the 

manual, registration information, and certification information.

Public Safety:

*Please see attachment “Inspire 1 User Manual” for safety precautions and steps taken before 

each flight. 

In addition, I (the petitioner) do not operate within no-fly zones centered around airports or other 

no-fly areas. If I must pilot within the no-fly zone of an airport, I shall contact the flight controller 

or airport manager for flight permission. I make landing approaches at the first instance of a low 

power warning. I pilot the UAS within a line-of-sight. The UAS features a GPS and return to 

home feature should radio contact be lost with the aircraft. The aircraft will be updated with the 

latest firmware available within 24 hours of takeoff. I conduct an extensive pre-flight protocol 

which carried safety as the highest priority. Permission is granted before all flights. Flight abort 

shall commence in the event of a safety breach.

Privacy:

Operation of this UAS involves the collection of video and images that have the potential to 

contain the images of bystanders. The operation of this UAS will occur over public lands where 

operation is legal, or over private lands where the petitioner has permission to fly. At the height 

of craft useable operation, it is highly unlikely that an individual will be recognizable in the 

collected images. the absence of a zoom feature on the attached camera ensures that 

bystanders will retain their privacy. By law, bystanders have no expectation of privacy if filming 

is done over public land. Regardless, the primary goal of the petitioner’s operation mostly 

revolves around stationary, non-living objects, and will allow users to have a reasonable 

expectation of privacy.

Conclusion:

Thank you for your time and attention.