November 3, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590

Re: Petition of Droneye LLC for Exemption from Certain Federal Aviation 

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 

333 of the FAA Modernization and Reform Act.

Dear Sir or Madam: 

DRONEYE LLC hereafter referred to as DRONEYE seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned 

Aircraft System (DJI Inspire 1) pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit DRONEYE to operate an 

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

and photography of construction sites, residential and commercial real estate, civil 

landscapes and events over certain areas of the United States. Because this petition is 

similar in all material respects to previously-granted Section 333 petitions, DRONEYE

requests expedited approval pursuant to the FAA's summary grant process.

I. Proposed Operations & Public Interest Benefits

DRONEYE is a Start-up Business located in Sussex County, NJ. Our pilots have over 

100 hours of Unmanned Aircraft System (UAS) experience without incident. The 

objective of DRONEYE and our UAS (DJI Inspire 1) aerial operations is to provide a 

more affordable, High-quality production system for a variety of commercial and 

Residential uses, specifically targeting 

• Construction sites progress

• Aerial Surveying

• Real-estate marketing

• Structural Inspection
• Civic landmarks

• Special event coverage

• Agriculture

II. Background

DRONEYE seeks an exemption to operate DJI Inspire 1 system for compensation or 

hire within the NAS. The DJI Inspire 1 already has authorized use by the FAA. The DJI 

Inspire 1 is vertical takeoff and landing (VTOL) Unmanned 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 approximately 6.5 lbs with a maximum speed of 

approximately 16.4 fps and a maximum flying height of 400 feet. The DJI Inspire 1 is 

equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors.

The DJI Inspire 1 operated by DRONEYE 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.

III. Basis for petition 

Petitioner, DRONEYE, 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 §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

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

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

the unmanned aircraft and its operation, DRONEYE operation of the DJI Inspire 1UAS 
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, DRONEYE 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.

DRONEYE submits that the requested relief is proper since an equivalent level of safety 

will be ensured. DRONEYE will only 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,

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

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

privileges and limitations: Pilot in command, is requested by DRONEYE to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by 

meeting minimum flight hour and currency requirements, that the PIC is able to safely 

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

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, airports, vehicles and structures.

DRONEYE 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, DRONEYE will ensure that the DJI Inspire 

1 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are 

in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.
DRONEYE also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UAS does not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Inspire 1 UAS will be broadcasted 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 DRONEYE operation of the DJI 

Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121.

Additionally, DRONEYE seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. DRONEYE submits 

that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with 

enough battery power to fly for a total duration of approximately 23 minutes. Battery 

power indicators are also able to show exactly how much battery power is left, as well 

as how much time is needed to return safely back to point of take-off. 

In accordance with 14 C.F.R. § 11.81, DRONEYE provides the following information in 

support of its petition for exemption:

A. The name and address of the Petitioner.

Norman Harris III

President

DRONE LLC

42 Bunn Rd

Hamburg, NJ 07419

908-509-4885

Droneye1@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which DRONEYE Seeks Exemption.

1. DRONEYE Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b).

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

subsections (a) and (b) prescribe the following, in relevant part:
(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

connection with any business or employment if—

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

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

2. DRONEYE 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.

3. DRONEYE Seeks Exemption from the Requirements of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

I. The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft;

II. If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; 

or

III. In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before departure.

4. DRONEYE Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the
first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes.

5. DRONEYE Seeks Exemption From The Requirement Of Section 91.405(a).

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

Each owner or operator of an aircraft—

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

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

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

6. DRONEYE Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7

of this chapter[.]

7. DRONEYE 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.

8. DRONEYE 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

(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.

C. The Extent Of Relief DRONEYE Seeks And The Reason DRONEYE Seeks The 

Relief.

1. Extent Of Relief DRONEYE Seeks And The Reason DRONEYE Seeks Relief 

From Section 61.113(a) And (b).

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

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

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

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

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that business or 

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

compensation or hire.
As set forth more fully below, DRONEYE submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless 

that PIC has met certain flight-hour and currency requirements, demonstrating that the

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

the operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures.

Further, DRONEYE submits that all flights of the DJI Inspire 1 UAS, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to DRONEYE’s business; 

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief DRONEYE Seeks And The Reason DRONEYE Seeks Relief 

From Section 91.7(a).

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

required to allow The DRONEYE 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., Monthly Maintenance Log, and DJI Inspire 1 Instruction 

Manual).

DRONEYE 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,

DRONEYE will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon 

its compliance with the operating documents (i.e., Monthly Maintenance

Log, and DJI Inspire 1) prior to every flight, and further, determine that the aircraft are in

condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief DRONEYE Seeks And The Reason DRONEYE 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), DRONEYE 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.

4. Extent Of Relief DRONEYE Seeks And The Reason DRONEYE 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 23 minutes. The DRONEYE 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 DRONEYE 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 DRONEYE’s proposed operating limitations, 

ensure that DRONEYE will safely operate the battery powered DJI Inspire 1 UAS during 
daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), 

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

5. Extent Of Relief DRONEYE Seeks And The Reason DRONEYE 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, DRONEYE 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, DRONEYE 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., Monthly Maintenance Log,

and DJI Inspire 1 Instruction Manual). Furthermore, DRONEYE will document and 

maintain all maintenance records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting DRONEYE Request Would Be In The Public 

Interest; 

Granting the present Petition will further the public interest by allowing DRONEYE to 

safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, events and civic 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 

DRONEYE 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 Inspire 1 UAS would reduce the 

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

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

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

congestion around airports caused by arriving and departing aircraft will be reduced. 

The DJI Inspire 1 UAS does not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 

UAS.

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

will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using 

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

the most viable environmentally conscious alternative to the cabin class, six cylinder 

internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution, as the 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 6.5 pounds at their maximum gross weight with 

diagonal dimension of 17.2 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, 
compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations with the DJI Inspire 1 

UAS Will Benefit The Economy.

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

DRONEYE, 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 1UAS 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 DRONEYE, 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.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, DRONEYE’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., 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 DRONEYE 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, DRONEYE’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 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, DRONEYE submits that the DJI Inspire 1 UAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

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

and (c) the specific operating limitations.

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

Characteristics.

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

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

operational capability.

i. Technical Specifications Of The DJI Inspire 1 UAS.

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

User Manual (attached).

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

Remain Within A Defined Operational Area.

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

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

UAS is provided in the DJI Inspire 1 User Manual (attached).

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 does not reacquire control 

link data from the GCS, the UAS will assume that the Control Link is lost and the will 
return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown.

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

the DJI Inspire 1 Manual (attached).

iv. The DJI Inspire 1 GCS And Its Operation.

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

flight control software is provided in the DJI Inspire 1 User Manual. 

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.

DRONEYE staff will be the only persons to act as a pilot in command (PIC) of the DJI 

Inspire 1 UAS. Additionally, a safety observer will assist with every flight.

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

Limitations.

In seeking this exemption, DRONEYE proposes to commercially operate DJI Inspire 1

UAS for the special purpose of conducting aerial video and photography over certain

areas of United States, pursuant to the following specific operating limitations.

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

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

55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems.

Proposed operations of any other aircraft will require a new petition or a petition 

to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above 

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

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL.
5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based 

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

instruments.

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

during UAS operations and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions 

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

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

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

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 
exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

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

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

operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in the 

aircraft records.

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

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

must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry in the aircraft records.

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

inoperable components, items, or equipment, not already covered in the relevant

sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person returning the 

UAS to service.

15. Each 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, airports, vehicles and structures. 

PIC qualification flight hours must be logged in a manner consistent with 14 

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

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

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

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

1.1. All operations must be conducted under visual meteorological conditions 

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

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized.

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

as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

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

letter of agreement with the airport management must be made available to the 

Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

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

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and
forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice to 

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (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.

31. Flight operations must be conducted at least 500 feet from all 

nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential 

persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator
must ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately and/or;

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

owner/controller of such vessels, vehicles or structures has granted permission

and the PIC has made a safety assessment of the risk of operating closer to

those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

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

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

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

vertical boundaries of the operational area as defined by the applicable COA 

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

Accidents must be reported to the National Transportation Safety Board (NTSB) 

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

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

(b) Would Not Adversely Affect Safety.

DRONEYE submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering DRONEYE’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to 

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

skills necessary to safely operate the DJI Inspire 1 UAS, DRONEYE submits that the 
additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for DRONEYE’s specific proposed flight 

operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, 

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

Exemption Nos.11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

DRONEYE will not allow any PIC to operate the DJI Inspire 1 UAS unless

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

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

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

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

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

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

5 hours of those hours as a UAS pilot operating the same make and model of UAS to 

be used for operations under the exemption). In addition to the hour requirements, the 

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

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

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during DRONEYE’s proposed operations. The Administrator 

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

applicable regulations would ensure safe operations, stating as follows:

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

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

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

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

PIC must also have accumulated and logged a minimum of 5 hours as a UAS 
pilot operating the same make and model of UAS to be used for operations under 

the exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model 

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

included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

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

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

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

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

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted 

under the grant of exemption to accomplish the required flight time. During 

training, proficiency, and experience-building flights the PIC is required to 

operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, DRONEYE will ensure safe operations by not allowing any PIC to operate 

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

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

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

structures.

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

Not Adversely Affect Safety.

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

prior to every flight, DRONEYE will ensure that the DJI Inspire 1 UAS is in an airworthy 

condition based upon the UAS’s compliance with its operating documents and as stated 

in the conditions and limitations herein.
Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, 

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

Exemption Nos.11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would 

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

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

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

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

information, combined with DRONEYE’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).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

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

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

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

proposed flight operations. Accordingly, DRONEYE will ensure that it will safely operate 

the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with 

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

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).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not 

Adversely Affect Safety.

In seeking this exemption, DRONEYE 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 DRONEYE 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 Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, DRONEYE 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, DRONEYE will maintain the equivalent level of safety established by 

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

Manuals are attached; 
Likewise, the exemption sought will not adversely affect safety because DRONEYE will 

use trained technicians to perform maintenance, alterations or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed by the operating 

documents.

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

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

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

documented and maintained utilizing the monthly maintenance log.

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 DRONEYE’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, DRONEYE 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, DRONEYE 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 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 toestablish a level of safety equivalent to 

that established in the regulations.

See 14 C.F.R. § 21.16.

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

prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 

UAS, which contain such safety standards that the Administrator finds necessary to 

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

H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

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

Rules From Which DRONEYE Seeks Exemption:

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

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).
A Brief Description Of The Nature Of The Exemption DRONEYE Seeks:

This exemption will permit DRONEYE to commercially operate an

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

Photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support

DRONEYE’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, DRONEYE’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, DRONEYE 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, DRONEYE 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 

DRONEYE 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, DRONEYE respectfully

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

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

Edge to operate the DJI Inspire 1 UAS commercially for the purpose of conducting 

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

Respectfully submitted,

Norman Harris III

President

DRONEYE LLC

42 Bunn Rd

Hamburg, NJ 07419

908-509-4885

Droneye1@gmail.com

Appendices:

Link to DJI Inspire 1 Manual: Click on link below

https://www.dji.com/product/inspire-1/download

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf