Spitz	Industrial	Design	- Petition	for	Exemption	 1

UNITED	STATES	OF	AMERICA	

DEPARTMENT	OF	TRANSPORTATION	

FEDERAL	AVIATION	ADMINISTRATION	

WASHINGTON,	DC

Regulatory	Docket	No.	_______________

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:

Spitz	Industrial	Design	,	LLC	

FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF	TITLE	14	

OF	THE	CODE	OF	FEDERAL	REGULATIONS	SECTIONS	21	subpart	H,	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)	CONCERNING	COMMERCIAL	OPERATION	OF	THE	DJI	

INSPIRE	1	UNMANNED	AIRCRAFT	SYSTEM	PURSUANT	TO	SECTION	333	OF	THE	

FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012	(PUBLIC	LAW	112-95)	

Submitted	on	June 3,	2015

Robert	Spitz

Spitz	Industrial	Design,	LLC

31	Edgewood	Run

Amherst,NH	03031

603-420-8025

rspitz@spitzindustrial.com
Spitz	Industrial	Design	- Petition	for	Exemption	 2

TABLE	OF	CONTENTS	

GLOSSARY	OF	ABBREVIATIONS PAGE	3

SUMMARY PAGE	4

INTRODUCTION	AND	INTEREST	OF	PETITIONERS PAGE	4

BACKGROUND PAGE	5

BASIS	FOR	PETITION PAGE	6

NAME	AND	ADDRESS	OF	PETITIONERS PAGE	8

THE	SPECIFIC	SECTIONS	OF	14	C.F.R.	FROM PAGE 8

WHICH	SPITZ	INDUSTRIAL	DESIGN

SEEKS	EXEMPTION	

THE	EXTENT	OF	RELIEF SPITZ	INDUSTRIAL	DESIGN PAGE 10

SEEK	AND	THE	REASON	SPITZ	INDUSTRIAL	DESIGN

SEEKS	THE	RELIEF

THE	REASONS	WHY GRANTING	REQUEST	WOULD	BE	IN PAGE 13

THE	PUBLIC	INTEREST

THE	REASONS	WHY	GRANTING	THE	EXEMPTION	WOULD PAGE 15

NOT	ADVERSELY	AFFECT SAFETY

A	SUMMARY	THAT	CAN	BE	PUBLISHED	IN	THE PAGE 27

FEDERAL	REGISTER

CONCLUSION PAGE 28

APPENDIX PAGE 29
Spitz	Industrial	Design	- Petition	for	Exemption	 3

GLOSSARY	OF	ABBREVIATIONS	

AGL Above	Ground	Level

AMA Academy	of	Model	Aeronautics

AOI Area	Of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AUVSI Association	for	Unmanned	Vehicle	Systems	International

AV Aerial	Vehicle	

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization	

FAA Federal	Aviation	Administration	

FAR Federal	Aviation	Regulation	

GCS Ground	Control	Station	

GPS Global	Positioning	System	

LOL Loss	of	Link

PIC	 Pilot	In	Command

Section	333	

FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	

Section	333

SO	 Safety	Observer

SOP	 Standard	Operating	Procedure

UA	 Unmanned	Aircraft

UAS	 Unmanned	Aircraft	System

VFR	 Visual	Flight	Rules

VLOS	 Visual	Line	Of	Sight

VMC	 Visual	Meteorological	Conditions

VTOL	 Vertical	Takeoff	And	Landing	
Spitz	Industrial	Design	- Petition	for	Exemption	 4

SUMMARY	

Robert	Spitz,	owner	of	Spitz	Industrial	Design LLC,	(hereafter	referred	to	as Spitz	

Industrial	Design),	seeks	exemption	from	the	requirements	of	14	C.F.R	§§	21	

subpart	H,	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	

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

This	exemption	will	permit	Spitz	Industrial	Design to	operate	an	Unmanned	Aircraft	

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

photography	to	be	used	in	construction	&	industrial	infrastructure	projects	and	land	

development planning	and	review,	over	certain	areas	of	the	United	States.	

INTRODUCTION	AND	INTEREST	OF	THE	PETITIONER	

Robert	Spitz is	the	owner	of	Spitz	Industrial	Design located	in	Amherst,	New	

Hampshire.	Spitz	Industrial	Design was	founded	in	2007.	Robert	Spitz	&	his	partner	

John	Spitz	have	extensive	experience	with	Radio	Control	(R/C) flight. John	is	

designated as	PIC	and	head	of	operations.	John has	15	years	of	Radio	Control	(R/C)	

aircraft	flight	experience.	John	is	highly	skilled	in	RC	fixed	wing,	helicopter,	and	

multi-rotor	operation	&	flight. John	personally	serves	as	the	field	marshal	at	the	

Southern	New	Hampshire	Flying	Eagles,	a	local	community	AMA R/C	club	airfield.	

John	is a	qualified	AMA	R/C	aircraft	flight	instructor.	John	also	serves	as	an advisor	

in	personal	sUAS	vehicles	to	the	local	community	builder	maker	space,	MakeIt	Labs,	

in	Nashua,	New	Hampshire.

John’s educational	background	is	in	aviation	technology	and	mechanical	

engineering.	He	is a	trained Airframe	& Power	Plant aircraft	mechanic.

Both	Robert	and	John	Spitz have over	3 years	of	experience	with	hundreds	of	hours	

with	sUAS	for	recreational	use.	John	has	accrued	20 hours	as	PIC	with	the	DJI	Inspire	

1	model	UAS.	 Spitz	Industrial	Design	has	taught	courses	in	safely	flying &	using	

personal	sUAS	vehicles	for	recreational	purposes,	including	FAA,	AMA,	and	AUVSI	

guidelines	and	regulations.	

Spitz	Industrial	Design has	clients	in	the Industrial	Construction,	Land	Development,	

arenas	as	well	as	educational	institutions.	The	objective	of	Spitz	Industrial	Design is	

to	facilitate	ecologically	sound,	lower	impact	development	projects	for	a	variety	of

commercial	and	public	uses.	Spitz	Industrial	Design	also	wishes	to	serve	as	a	model	

and	provide	training	safe	and effective	professional	usage	of	UAS	operations	in	our	

community.	
Spitz	Industrial	Design	- Petition	for	Exemption	 5

BACKGROUND	

Unmanned	Aircraft	Systems:	DJI	Inspire	1	UAS	

Spitz	Industrial	Design seeks	an	exemption	to	operate	DJI	systems	for	compensation	

or	hire	within	the	NAS.	The	DJI	Inspire	1	is	a	vertical	takeoff	and	landing	(VTOL)	

Unmanned	Aircraft	(UA)	with	a	Ground	Control	Station	(GCS)	utilizing	electronic	

tablet	or	smart	phone	systems.	The	DJI	Inspire	1	has	a	maximum	gross	weight	of	6	

pounds	7.5	ounces,	a	length	of	17.3	inches,	width	of	17.7	inches,	height	of	11.8	

inches,	and	a	maximum	speed	of	approximately	42	knots.	The	DJI	Inspire	1	UA	is	

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

electric	motors.	The	DJI	Inspire	1	UA	that	will	be	operated	by	Spitz	Industrial	Design

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.	

The	Inspire	1	UAS is	a	highly	improved	model	from	the	previous	DJI	popular	and	

reliable	DJI	Phantom	series.	The	DJI	Inspire	1	is	a	6.47lb	multi-rotor	(4	rotors)	UAS	

with	approximately	18	minutes	of	endurance.	The	Inspire	1’s	purpose	is	to	carry	a	

small	camera	as	its	payload.	The	Inspire	1	has	the	ability	to	be	controlled	by	a	single	

crewmember	acting	as	pilot	in	command	by	wireless	remote	control	on	a	2.4GHz	

band	having	a	transmitting	distance	of	2km	(1.08nm).	 The	Inspire	1	is	equipped	

with	lost	link	protection	(referred	to	as	“Return	To	Home”	(RTH)	in	the	Inspire	1	

User	Manual),	allowing	the	UAS	to	automatically	climb	vertically	to	a	safe	altitude	to	

clear	obstacles;	then	proceed	to	a	pre-designated	point	to	automatically	land.	At	

anytime	the	UAS	and	the	controller	reestablish	link,	the	PIC	can	cancel	the	RTH	and	

resume	control	of	the	UAS.	In	the	event	of	lost	GPS	signal,	control	to	the	Inspire	UAS	

is	not	lost.	Since	all	operations	will	be	conducted	under	Visual	Line	of	Sight	VLOS	the	

PIC	can	control	the	aircraft	back	to	a	safe	location	to	land.	

The	DJI	Inspire	UAS	operates	on	the	2.4GHz	frequency	band	for	both	UAS	control	as	

well	as	video	downlink.	Both	the	Inspire	1	UAS	as	well	and	the	UAS	remote	

controller	comply	with	part	15	of	the	FCC	rules	(see	page	appendix	A,	page	62	of	the	

DJI	Inspire	user	manual).	The	Inspire	1	is	equipped	with	a	vision	positioning	system	

along	with	a	sonar	system	in	order	to	be	able	to	fly	inside	a	building	and	still	remain	

stable.	The	Inspire	1’s	primary	payload	is	a	small	X3	model	FC350	camera	mounted	

with	a	Zenmuse	X3 gimbal.	
Spitz	Industrial	Design	- Petition	for	Exemption	 6

BASIS	FOR	PETITION	

Petitioner,	Robert	Spitz	of	Spitz	Industrial	Design 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	petition	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	§§	21	subpart	H,	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,	Spitz	Industrial	Design ‘s	operation	of	

the	DJI	Inspire	1	UAS	meets	the	conditions	of	FMRA	Section	333	and	therefore,	will	

not	require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	

Subpart	H.	

Accordingly,	Spitz	Industrial	Design 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.	

Spitz	Industrial	Design submits	that the	requested	relief	is	proper	since	an	

equivalent	level	of	safety	will	be	ensured.	Spitz	Industrial	Design will	use	

experienced	personnel	or	technicians	to	perform	maintenance,	alterations,	or	

preventive	maintenance	on	the	UAS	using	the	methods,	techniques,	and	practices	

prescribed	in	the	operating	documents	(i.e.,	Monthly	Maintenance	Log,	DJI	Inspire	1	

Instruction	Manual,	and	will	follow	company aircraft	maintenance	procedures.	This	

includes following the	manufactures	recommended	inspection	interval	to	preform	

comprehensive	maintenance	of	the	Inspire	1	every 50	flight	hours	or	200	flights.

Furthermore,	Spitz	Industrial	Design will	document	and	maintain	all	maintenance	

records	for	the	DJI	Inspire	1	UAS.	

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

privileges	and	limitations:	Pilot	in	command,	is	requested	by	chief	of	operations	to	

the	extent	necessary	to	allow	a	Pilot	in	Command	(PIC),	holding	an	airman	medical	

certificate,	and	qualified as	an	AMA	R/C	flight	instructor,	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,	vehicles	and	structures.	

Spitz	Industrial	Design	seeks	relief	from	Section	91.7(a),	entitled	Civil	aircraft	

airworthiness,	because	the	DJI	Inspire	1	UAS	does	not	require	an	airworthiness	

certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	As	such,	Spitz	Industrial	

Design submits	that	they	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	
Spitz	Industrial	Design	- Petition	for	Exemption	 7

the	operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	DJI	Inspire	1	

Instruction	Manual,	and	company	maintenance	procedures),	and	that	the	aircraft	

are	in	a	condition	for	safe	flight.	

Spitz	Industrial	Design	also	seeks	an	exemption	from	the	requirements	of	Section	

91.121,	entitled	Altimeter	Settings,	as	the	DJI	Inspire	1	UA	will	not	have	a	typical	

barometric	altimeter	onboard.	However,	altitude	information	of	the	DJI	Inspire	1UA	

will	be	provided	to	the	PIC	via	Global	Positioning	System	(GPS)	equipment	and	radio	

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

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

Industrial	Design’s	operation	of	the	DJI	Inspire	1	UA	within	visual	line	of	sight,	at	or	

below	500	feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121.	

Additionally,	Spitz	Industrial	Design	seeks	an	exemption	from	the	requirements	of	

Section	91.151(b),	entitled	Fuel	requirements	for	flight	in	VFR	conditions.	Spitz	

Industrial	Design submits	that	safety	will	not	be	affected	by	operation	of	the	DJI	

Inspire	1	UA	during	daylight	hours	in	visual	meteorological	conditions	(VMC)	under	

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

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

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

In	accordance	with	14	C.F.R.	§	11.81,	Spitz	Industrial	Design	provides	the	following	

information	in	support	of	their	petition	for	exemption:	
Spitz	Industrial	Design	- Petition	for	Exemption	 8

A.	Name	and	Address	Of	The	Petitioner	

Robert	Spitz,	 Spitz	Industrial	Design LLC ,	31	Edgewood	Run	Amherst,	NH	03031	

rspitz@spitzindustrial.com,	Phone	603-420-8025.

B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Spitz	Industrial	Design Seeks	

Exemption.	

1.	Spitz	Industrial	Design Seeks	Exemption	From	The	Requirements	Of	Section	

Part	21,	Subpart	H	

14	C.F.R.	Part	21,	Subpart	H,	establishes	the	procedural	requirements for	the	

issuance	of	airworthiness	certificates	as	required	by	14	C.F.R.	§91.203(a)(1)	

2.	Spitz	Industrial	Design 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.	

3.	Spitz	Industrial	Design 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.	

4.	Spitz	Industrial	Design	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.	
Spitz	Industrial	Design	- Petition	for	Exemption	 9

5.	Spitz	Industrial	Design 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.	

6.	Spitz	Industrial	Design 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[.]	

7.	Spitz	Industrial	Design 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[.]	

8.	Spitz	Industrial	Design	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.	

9.	Spitz	Industrial	Design 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	
Spitz	Industrial	Design	- Petition	for	Exemption	 10

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	lifelimited	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	Spitz	Industrial	Design Seeks	And	The	Reason	Spitz	

Industrial	Design Seeks	The	Relief.	

1.	Spitz	Industrial	Design Seeks	Exemption	From	The	Requirements	Of	Section	

Part	21,	Subpart	H	

Given	the	size	and	limited	operating	area	associated	with	the	UAS	to	be	utilized	by	

the	Spitz	Industrial	Design,	an	exemption	from	Part	21	Subpart	H	meets	the	

requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	the	

Reform	Act.	

The	Federal	Aviation	Act	(49	U.S.C.§	44701(f))	and	Section	333	of	the	Reform	Act	

both	authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for	an	

airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	operational	

capability,	and	proximity	to	airports	and	populated	areas	of	the	particular	UAS.	
Spitz	Industrial	Design	- Petition	for	Exemption	 11

In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	

an	airworthiness	certificate,	in	the	restricted	environment	and	under	the	conditions	

proposed	will	be	at	least	as	safe,	or	safer,	than	a	conventional	rotorcraft	operating	

with	an	airworthiness	certificate	without	the	restrictions	and	conditions	of	the	

proposed	UAS	operations.	

2.	Extent	Of	Relief	Spitz	Industrial	Design Seeks	And	The	Reason	Spitz	

Industrial	Design 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	valid	airman	medical	certificate,	and qualified	as	an	AMA	R/C	flight	

instructor, 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,	Spitz	Industrial	Design	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	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,	Spitz	Industrial	Design	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	

Spitz	Industrial	Design business;	and	(2)	will	not	carry	passengers	or	property	for	

compensation	or	hire.	

3.	Extent	Of	Relief	Spitz	Industrial	Design Seeks	And	The	Reason	Spitz	

Industrial	Design 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	Spitz	Industrial	Design to	determine	that	the	DJI	Inspire	1	

UAS	are	in	airworthy	condition	prior	to	every	flight	by	ensuring	that	the	UAS	is	in	

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

DJI	Inspire	1	Instruction	Manual,	and	company	maintenance	procedures).	

Spitz	Industrial	Design seeks	the	requested	relief	because	the	DJI	Inspire	1	UA	does	

not	require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	

Subpart	H.	Therefore,	Spitz	Industrial	Design	will	ensure	that	the	DJI	Inspire	1	UAS	

is	in	airworthy	condition	based	upon	its	compliance	with	the	operating	documents	
Spitz	Industrial	Design	- Petition	for	Exemption	 12

(i.e.,	Monthly	Maintenance	Log,	and	DJI	Inspire	1	Instruction	Manual,	and	company	

maintenance	procedures)	prior	to	every	flight,	and	further,	determine	that	the	

aircraft	are	in	condition	for	safe	flight,	as	stated	in	the	conditions	and	limitations	

below.	

4.	Extent	Of	Relief Spitz	Industrial	Design Seeks	And	The	Reason	Spitz	

Industrial	Design 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),	

Spitz	Industrial	Design 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	UA	is	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.	

5.	Extent Of	Relief	Spitz	Industrial	Design Seeks	And	The	Reason	Spitz	

Industrial	Design 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	UA	during	daylight	hours	in	visual	meteorological	conditions	

(VMC),	under	visual	flight	rules	(VFR),	for	a	total	duration	of	13.5	minutes	to	the	

first	point	of	intended	landing	and, assuming	normal	cruising	speed,	to	fly	after	that	

for	at	least	4.5	minutes.	Spitz	Industrial	Design seeks	the	requested	relief	because	

without	an	exemption	from	Section	91.151(b),	the	flight	time	duration	of	the	battery	

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

or	still	photo	flight	operations	that	Spitz	Industrial	Design 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

Spitz	Industrial	Design ’s proposed	operating	limitations,	ensure	that	Spitz	

Industrial	Design will	safely	operate	the	battery	powered	DJI	Inspire	1	UA	during	

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

(VFR),	with	enough	battery	power	to	fly	for	a	total	duration	of	13.5	minutes	to	the	

first	point	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	

for	at	least	4.5	minutes.	
Spitz	Industrial	Design	- Petition	for	Exemption	 13

6.	Extent	Of	Relief	Spitz	Industrial	Design Seeks	And	The	Reason	Spitz

Industrial	Design 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, Spitz	Industrial	Design

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

an	airworthiness	certificate.	As	set	forth	more	fully	below,	the	DJI	Inspire	1	UAS	

meets	the	conditions	of	FMRA	Section	333	for	operation	without	an airworthiness	

certificate.	Accordingly,	Spitz	Industrial	Design 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, DJI	Inspire	1	Instruction	Manual,	and	company	

maintenance	procedures).	Furthermore,	Spitz	Industrial	Design will	document	and	

maintain	all	maintenance	records	for	the	DJI	Inspire	1	UAS.

D.	The	Reasons	Why	Granting	Spitz	Industrial	Design ’s Request	Would	Be	In	

The	Public	Interest;	or	How	It	Would	Benefit	The	Public	As	A	Whole.	

Granting	the	present	petition	will	further	the	public	interest	by	allowing	Spitz	

Industrial	Design to	safely,	efficiently,	and	economically	perform	aerial	video	

surveys	of	infrastructure	&	land	development	projects over	certain	areas	of	the	

United	States.	Furthermore,	it	will	benefit	the	public	as	a	whole	by enabling	more	

cost	effective	ecological	planning &	monitoring of	such	projects.	Additionally,	use	of	

the	DJI	Inspire	1	UAS	will	decrease	congestion	of	the	NAS,	and	reduce	pollution.	

Notably,	the	benefits	of	Spitz	Industrial	Design 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	do	not	require	an	airport	to	takeoff	or	land.	Likewise,	

a	reduction	of	manned	aircraft	conducting	aerial	video	and	photography	missions	

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

ground,	takeoff,	departure,	arrival,	and	landing	phases	of	flight	operations.	
Spitz	Industrial	Design	- Petition	for	Exemption	 14

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	

produces	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	significant	

quantities	of	aviation	fuel.	The	DJI	Inspire	1	UA,	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	UA	(weighing	approximately	6	pounds	7.5	ounces	respectively,	at	its	

maximum	gross	weight	with a	length	of	17.3	inches	and	width	of	17.7	inches,	and	

with	no	fuel	on	board),	has	less	physical	potential	for	collateral	damage	to	life	and	

property	on	the	ground,	and	in	the	air,	compared	to	the	manned	aircraft	that	

typically	conduct	similar	operations.

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	is	also	an	economical	

alternative	to	using	manned	aircraft	to	conduct	similar	aerial	operations.	As	such,	

operation	of	the	DJI	Inspire	1	UAS	will	allow	United	States	based	companies,	like	

Spitz	Industrial	Design	,	to	remain	competitive	and	contribute	to	growth	of	the	U.S.	

economy.	Specifically,	with	the	rising	cost	of	aviation	fuel	and	the Environmental	

Protection	Agency	(“EPA”)	regulatory	actions	phasing	out	leaded	aviation	fuels,	U.S.	

owned	and	operated	companies	must	adopt	new	and	alternative	technology	in	

order	to	remain	competitive.	

Operating	the	battery	powered	DJI	Inspire	1	UAS	is	one	such	technology	that	not	

only	allows	companies	greater	operational	flexibility	compared	to	manned	aircraft,	

but	provides	such	flexibility	without	the	high	operational	cost	of	a	traditional	

manned	aircraft.	

By	operating	the	DJI	Inspire	1	UAS,	companies	such	Spitz	Industrial	Design ,	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.	
Spitz	Industrial	Design	- Petition	for	Exemption	 15

4.	There	Are	No	Privacy	Issues.	

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

for	decades,	Spitz	Industrial	Design’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,	company	maintenance	procedures),	

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	Spitz	Industrial	Design Seeks	

Exemption.	

1.	Reasons	Why	The	DJI	Inspire	1	UA	Meets	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,	Spitz	Industrial	Design’s	operation	of	the	DJI	Inspire	1	

UAS	meets	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	
Spitz	Industrial	Design	- Petition	for	Exemption	 16

airspace	system.	

In	seeking	this	exemption,	Spitz	Industrial	Design submits	that	the	DJI	Inspire	1	UAS	

can	operate	safely	in	the	NAS	pursuant	to	FMRA	Section	333,	as	demonstrated	by:	

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

requirement;	and	(c)	the	specific	operating	limitations.	

a.	The	Specifications	Of	The	DJI	Inspire	1	UAS	Demonstrates	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	

Specifications	and	Data	Sheet.	

ii.	The	DJI	Inspire	1	UAS	Autonomous	Flight	And	Navigation	Modes	Enable	The	

UAS	To	Remain	Within	A	Defined	Operational	Area.	The	DJI	Inspire	1	UAS	may	

be	operated	in	both	manual	and	fully	autonomous	flight	modes.	A	complete	

description	of	the	flight	and	navigational	modes	of	the	DJI	Inspire	1	UAS	is	provided	

at	pages	12-16	and	45-50	of	the	DJI	Inspire	1 User	Manual,	attached	hereto	in

Appendix B.	

iii.	The	DJI	Inspire	1	UAS	Is	Designed	For	Automatic	Return	To	Home	Point	Or	

Hover	In	The	Event	Of	Loss	Of	The	Control	Link	Or	Navigation.	

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

for	3	seconds	or	more.	If,	after	3	seconds,	DJI	Inspire	1	UA	do	not	reacquire	control	

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

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

takeoff	position	and	shutdown.	

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

forth at	pages	13	through	15	of	the	DJI	Inspire	1	User	Manual,	attached	hereto	as	

Exhibit	A.	

iv.	The	DJI	Inspire	1	GCS	And	Its	Operation.	

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

and	flight	control	software	is	provided	at	pages	40	through	47	of	the	DJI	Inspire	1	

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

b.	Flight	Operations	Of	DJI	Inspire	1	UAS	is	Limited	To	The	Line	Of	Sight	Of	A	

Certificated	Pilot	in	Command	With	A	Safety	Observer.	
Spitz	Industrial	Design	- Petition	for	Exemption	 17

Spitz	Industrial	Design will	only	utilize	certificated	pilots	to	act	as	a	pilot	in	

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

pilots	during	flight	time.	

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

Operating	Limitations.	

In	seeking	this	exemption, Spitz	Industrial	Design proposes	to	commercially	operate	

the	DJI	Inspire	1	UAS	for	the	special	purpose	of	conducting	aerial	video	and	

photography	over	certain	areas	of	United	States,	pursuant	to	the	following	specific	

operating	limitations:	

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

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

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

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

amend	this	grant.	

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

the	purpose	of	aerial	video	and	photography.	

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

4.	The	UA	must	be	operated	at	an	altitude	of	no	more	than	500	feet	above	ground	

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

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

must	be	in	feet	AGL.	

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

This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any	device	other	

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

certificate.	

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

permitted.	

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

the	VLOS	requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	SO	

and	PIC	must	be	able	to	communicate	verbally	at	all	times.	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.	
Spitz	Industrial	Design	- Petition	for	Exemption	 18

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.	
Spitz	Industrial	Design	- Petition	for	Exemption	 19

17.	The	PIC	must	meet	possess	at	least	a	current	medical	certificate.

18.	The	operator	may	not	permit	any	PIC	to	operate	unless	the	PIC	meets	the	

operator’s	qualification	criteria	and	demonstrates	the	ability	to	safely	operate	the	

UAS	in	a	manner	consistent	with	how	the	UAS	will	be	operated	under	the	

exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	

appropriate	distances	from	persons,	vessels,	vehicles	and	structures.	PIC	

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

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

under	the	terms	of	the	exemption.	However,	training	operations	may	only	be	

conducted	during	dedicated	training	sessions.	During	training,	proficiency,	and	

experience-building	flights,	all	persons	not	essential	for	flight	operations	are	

considered	non-participants,	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	
Spitz	Industrial	Design	- Petition	for	Exemption	 20

requirements	in	the	ATO	issued	COA	including	class	of	airspace,	altitude	level	and	

potential	transponder	requirements.	

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

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

identification	(N- Number)	markings	in	accordance	with	14	C.F.R.	part	45,	Subpart	C.	

Markings	must	be	as	large	as	practicable.	

27.	Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	

and	control	of	the	UA	must	comply	with	the	Federal	Communications	Commission	

(FCC)	or	other	appropriate	government	oversight	agency	requirements.	

28.	The	documents	required	fewer	than	14	C.F.R.	91.9	and	91.203	must	be	available	

to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time	the	UAS	is	operating.	

These	documents	must	be	made	available	to	the	Administrator	or	any	law	

enforcement	official	upon	request.	

29.	The	UA	must	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation	

operations	and	activities	at	all	times.	

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

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	
Spitz	Industrial	Design	- Petition	for	Exemption	 21

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	21	Subpart	

H	Would	Not	Adversely	Affect	Safety.__	

Spitz	Industrial	Design submits	that	the	equivalent	level	of	safety	established	by	

Section	61.113(a)	and	(b)	will	be	maintained	because	The	UAS	to	be	operated	

hereunder	weighs	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	

passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operates	

exclusively	within	a	secured	area.	Unlike	other	civil	aircraft,	the	proposed	

operations	in	this	petition	for	exemption	will	be	controlled	and	monitored	by	the	

operator,	pursuant	to	the	Manual's	requirements.	

These	safety	enhancements,	which	already	apply	to	civil	aircraft	operated	in	

connection	with	existing	inspection	operations,	provide	a	greater	degree	of	safety	to	

the	public	and	property	owners	than	conventional	operations	conducted	with	

airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	

application	of	these	same	criteria	demonstrates	that	there	is no	credible	threat	to	

national	security	posed	by	the	UAS,	due	to	its	size,	speed	of	operation,	location	of	

operation,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	inability	to	

carry	a	substantial	external	load.	

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

And	(b)	Would	Not	Adversely	Affect	Safety.__	

Spitz	Industrial	Design 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	Spitz	Industrial	Design’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,	Spitz	Industrial	Design submits	that	the	additional	manned	airmanship	

experience	of	a	commercially	certificated	pilot	would	not	correlate	to	the	

airmanship	skills	necessary	for	Spitz	Industrial	Design’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,	
Spitz	Industrial	Design	- Petition	for	Exemption	 22

11110,	11112,	11136,	11138,	11150,	11153,	11156,	11158,	11159,	11160,	11161).	

Spitz	Industrial	Design 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	Spitz	Industrial	Design’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	experiencebuilding	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,	Spitz	Industrial	Design will	ensure	
Spitz	Industrial	Design	- Petition	for	Exemption	 23

safe	operations	by	not	allowing	any	PIC	to	operate	the	DJI	Inspire	1	UAS	unless	that	

PIC	has	demonstrated,	by	meeting	minimum	flight-hour	and	currency	requirements,	

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

with	the	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining

appropriate	distances	from	people,	vessels,	vehicles	and	structures.	

4.	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,	Spitz	Industrial	Design 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).	

5.	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	UA	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	Spitz	Industrial	Design’s	

operation	of	the	DJI	Inspire	1	U	A	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).	

6.	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,	Spitz	Industrial	Design will	

ensure	that it	will	safely	operate	the	battery	powered	DJI	Inspire	1	U	A	during	
Spitz	Industrial	Design	- Petition	for	Exemption	 24

daylight	hours	in	VFR	conditions,	with	enough	battery	power	to	fly	for	a	total	

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

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

Here,	as	in	Exemption	No.	11109,	the	technical	specifications	of	the	DJI	Inspire	1	

UAS; the	limitations	on	the	proposed	flight	operations;	and	the	location	of	the	

proposed	operations,	will	ensure	an	equivalent	level	of safety	established	by	14	

C.F.R.	Section	91.151(b).	Furthermore,	safety	will	be	ensured	as	the	DJI	Inspire	1	

UAS	provides	audible	and	visual	warnings	to	the	PIC	at	the	GCS	when	the	UA	

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).	

7.	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,	Spitz	Industrial	Design 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	Spitz	Industrial	Design 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.	Operations	Manual,	Monthly	Maintenance	Log, DJI	Inspire	1	

Instruction	Manual,	and	company	maintenance	procedures).	Furthermore,	Spitz	

Industrial	Design 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,	Spitz	Industrial	Design will	maintain	the	equivalent	level	of	safety	

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

Inspire	1	User	Manual	is	attached	hereto	as	Exhibit	C	and	D;	a	copy	of	the	DJI	Inspire	

1	UAS	Maintenance	LOG	is	attached	hereto	as	Exhibit	C.	

Likewise,	the	exemption	sought	will	not	adversely	affect	safety	because	Spitz	
Spitz	Industrial	Design	- Petition	for	Exemption	 25

Industrial	Design e	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.	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	Spitz	Industrial	Design proposed	operating	

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

UAS,	Spitz	Industrial	Design 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).	

8.	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,	Spitz	Industrial	Design

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	
Spitz	Industrial	Design	- Petition	for	Exemption	 26

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

or	propeller,	he	prescribes	special	conditions	and	amendments	thereto	for	the	

product.	The	special	conditions	are	issued	in	accordance	with	Part	11	of	this	chapter	

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

FAA	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	established	in	the	

regulations.	

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

§	21.16,	the	FAA	may	prescribe	special	conditions	for	Spitz	Industrial	Design

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).	
Spitz	Industrial	Design	- Petition	for	Exemption	 27

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

Rules	From	Which	Spitz	Industrial	Design Seeks	Exemption:	__	

Spitz	Industrial	Design seeks	exemption	from	the	requirements	of	14	C.F.R	Sections	21	

Subpart	H,	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	Exemptions	Spitz	Industrial	Design

Seeks:	

This	exemption	will	permit	Spitz	Industrial	Design 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	Spitz	

Industrial	Design	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,	Spitz	Industrial	Design’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,	Spitz	Industrial	Design 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.	
Spitz	Industrial	Design	- Petition	for	Exemption	 28

CONCLUSION	

As	set	forth	herein,	Spitz	Industrial	Design 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	Spitz	Industrial	Design to	safely,	efficiently,	and	economically	

operate	the	DJI	Inspire	1	UASs	commercially	within	the	NAS.	

In	accordance	with	the	Federal	Aviation	Regulations	and	the	FAA	Modernization	

and	Reform	Act	of	2012,	Section	333, Spitz	Industrial	Design respectfully	requests	

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

of	14	C.F.R	Sections	21	Subpart	H,	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	

Spitz	Industrial	Design to	operate	the	DJI	Inspire	1	UASs	commercially	for	the	

purpose	of	conducting	aerial	video	and	photography	over	certain	areas	of	the	United	

States.	

Dated:	June	3,	2015	

Respectfully,	Robert	Spitz

Spitz	Industrial	Design,	31	Edgewood	Run,	Amherst,	NH	03031
Spitz	Industrial	Design	- Petition	for	Exemption	 29

APPENDIX	– A	 DJI	Inspire	1	Specifications	Data	Sheet	

DJI	INSPIRE	1	TECHNICAL	SPECIFICATIONS	

Spitz	Industrial	Design	only	utilizes	safe	and	reliable	UASs for	professional	use.	DJI	

is	an	industry	leader	in small	UAS	production.	DJI	UASs	utilize leadership	control	

software	enabling	the	operator	to	configure parameters,	which will	not	allow	flight	

into	controlled	airspace.	Parameters	can	also	be	set	to	limit	flight	to	no	higher	than	a	

predetermined	and	set	altitude	as	well	as	limit	flight	to	a	predetermined	and	set	

distance.	In	addition,	DJI	software	provides	real-time	altitude	and	location	

information	to	the	PIC	via	a linked	monitor	(HDMI	video	screen,	smart	phone,	or	

tablet	devices)	

2.2	DJI	Inspire	1	Specifications

2.2.1	Aircraft

2.2.1.1	Model	– T600	

2.2.1.2	Weight	(Battery	Included)	– 6lbs	7.5291oz	(2935g)	

2.2.1.3	Hovering	Accuracy	(GPS	Mode)	– Vertical:	0.5m;	Horizontal:	2.5m	

2.2.1.4	Max	Angular	Velocity	– Pitch:	3000/s;	Yaw:	1500/s	2.2.1.5	Max	Tilt	Angle	-

350	

2.2.1.6	Max	Ascent	Speed	– 5m/s	

2.2.1.7	Max	Descent	Speed	– 4m/s	

2.2.1.8	Max	Speed	– 22m/s	(ATTI	mode,	no wind	– NOT	RECOMMENDED)	

2.2.1.9	Max	Flight	Altitude	– 4500m	

2.2.1.10	Max	Wind	Resistance	– 10m/s	

2.2.1.11	Max	Flight	Time	– Approximately	18	minutes	

2.2.1.12	Motor	Model	– DJI	3510	

2.2.1.13	Propeller	Model	– DJI	1345	

2.2.1.14	Operating	Temperature	Range	– 140F	to	1040F	(-100C	to	400C)	

2.2.1.15	Dimensions	– 17	1⁄4”	x	17	3⁄4”	x	12”	

Camera	Positioning	System	

2.2.2	Gimbal	

2.2.2.1	Model	– ZENMUSE	X3	

2.2.2.2	Output	Power	(with	camera)	– Static:	9W;	In	Motion:	11W	

2.2.2.3	Operating	Current	– Static:	750mA;	In	Motion:	900mA	

2.2.2.4	Angular	Vibration	Range	- ±0.030	

2.2.2.5	Mounting	– Detachable	

2.2.2.6	Controllable	Range	– Pitch:	-900to	+300;	Pan:	±3200	

2.2.2.7	Mechanical	Range	– Pitch:	-1250to	450;	Pan:	±3300	

2.2.2.8	Max	Controllable	Speed	– Pitch:	1200/s;	Pan:	1800/s	
Spitz	Industrial	Design	- Petition	for	Exemption	 30

2.2.3	Camera

2.2.3.1	Name	– X3	

2.2.3.2	Model	– FC350	

2.2.3.3	Total	Pixels	– 12.76M	

2.2.3.4	Effective	Pixels	– 12.4M	

2.2.3.5	Image	Max	Size	– 4000x3000	

2.2.3.6	ISO	Range	– 100-3200	

2.2.3.7	Field	of	View	- 940	

2.2.3.8	CMOS	– Sony	EXMOR	1/2.3”	

2.2.3.9	HD	Video	Recording	– UHD(4K):	4096x2160p24/25,	3840x2160p24/25/30;	

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

2.2.3.10	Operating	Temperature	Range	- 320F	- 1040F	(00C	- 400C)	

2.2.4	Radio	Control	Transmitter

2.2.4.1	Name	– C1	

2.2.4.2	Operating	Frequency	– 5.728-5.850GHz;	2.400-2.483GHz	

2.2.4.3	Communicating	Distance	(unobstructed)	– 2000m	

2.2.4.4	Output	Power	– 9W	

2.2.4.5	Operating	Temperature	Range	- 140F	to	1040F	(-100C	to	400C)	

2.2.4.6	Battery	– 600mAh	LiPo	2S	
Spitz	Industrial	Design	- Petition	for	Exemption	 31

APPENDIX	– B	 DJI	Inspire	1 User,	Maintenance,	Safety	Manuals

DJI	INSPIRE	1	USER	MANUAL	

(see	referenced	external	document)

http://sidrones.com/drones/downloads/inspire/Inspire_1_User_Manual_v1-2.pdf

DJI	INSPIRE	1	MAINTENANCE MANUAL	

(see	referenced	external	document)

http://sidrones.com/drones/downloads/inspire/Inspire_Maintenance_Manual.pdf

DJI	INSPIRE	1	SAFETY MANUAL	

(see	referenced	external	document)

http://sidrones.com/drones/downloads/inspire/Inspire_1_Safety_Guidelines.pdf
Spitz	Industrial	Design	- Petition	for	Exemption	 32

APPENDIX	– C				DJI	INSPIRE	1	Maintenance	Log