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Pure Art Productions LLC

July 23, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform 

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization & Reform Act and 14 C.F.R. Part 11, 

Pure Art Productions LLC (Pure Art Productions) hereby applies for the grant of exemption 

from certain Federal Aviation Regulations for Inspire 1 (Inspire) Unmanned Aircraft 

manufactured by DJI Co.,Ltd. of China. 

The requested exemption would support an application for a commercial Certificate of 

Authorization (COA) to use the Inspire to support real estate photography, videography, and 

aerial surveying for other commercial industries. 

The Inspire Unmanned Aircraft System (UAS) consists of a lightweight (6.5 lb) battery 

operated quadcopter unmanned aircraft, onboard cameras, and associated communications 

equipment. 

The Inspire Unmanned Aircraft (UA) has previously demonstrated to have successfully met 

the safety and operational requirements resulting in previous grants of section 333 

exemption requests by other commercial UAS operators. 

 

The Inspire UA carries an onboard camera system that allows it to perform aerial 

photography, videography, and surveying. 

By approving the exemption, the Pure Art Productions’ UAS operations will create benefits 

to both the economy and the environment which are ultimately in the public interest. 

The aircraft will be operated with both a Pilot in Command and a Visual Observer in 

accordance with the following additional restrictions: 
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- All operations will occur at no more than 400' AGL 

- The aircraft will be operated with the permission of the property owner 

- When necessary, applicable permits will be acquired from local authorities 

- The aircraft will not be operated over urban or populated areas 

- The aircraft will not be operated at air shows or over an open-air assembly of people 

- The aircraft will not be operated over heavily trafficked roads 

- Operations will be limited to day, visual meteorological conditions 

- Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at all 

time 

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC 

- When necessary and applicable, Pure Art Productions will file a NOTAM providing 

radial/DME, radius, and a date/time group for each operation 

For certain complex operations, Pure Art Productions may assign one or two 

sensor/software operators to assist the operations. 

We submit that the combination of; 

- Inspire UAV’s light weight and historically demonstrated safe operation and receiving 

approvals of multiple section 333 petitions 

- Fully qualified flight crew 

- Restricted operations under the guidelines established within the grant, the FAA can have 

confidence that Pure Art Productions’ UAS the operations will have an equivalent or greater 

level of safety of manned aircraft performing the same mission. 

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Additional documents supporting this petition will be submitted 

following this request. 

We look forward to working with your office. 

Please contact us at any time if you require additional information or clarification. 

Respectfully, 

Thomas Chang

Pure Art Productions LLC

5156 Woodfield Drive

Centreville, Virginia 20120

Tel: 571-330-1786

Email: thomassungchang@gmail.com
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TABLE OF CONTENTS 

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .......................Page 4 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PURE ART 

PRODUCTIONS SEEKS EXEMPTION.......................................................................Page 4 

THE EXTENT OF RELIEF PURE ART PRODUCTIONS SEEKS AND THE 

REASONS PURE ART PRODUCTIONS SEEKS THE RELIEF ...............................Pages 4 to 6 

THE REASONS WHY GRANTING PURE ART PRODUCTIONS’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ..................................................................Page 7 

THE REASONS WHY GRANTING PURE ART PRODUCTIONS THE 

EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY................................Page 8 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............Page 9 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT PURE ART PRODUCTIONS’S REQUEST..........................................Page 10 

ACRONYMS.......................................................................................Pages 11 & 12 
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NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER 

Thomas Chang

Pure Art Productions LLC

5156 Woodfield Drive

Centreville, Virginia 20120

Tel: 571-330-1786

Email: thomassungchang@gmail.com

THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF PURE ART PRODUCTIONS SEEKS AND THE REASONS 

PURE ART PRODUCTIONS SEEKS THE RELIEF 

14 CFR 61.113 Private pilot privileges and limitations: 

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 

act as pilot in command of an aircraft in connection with any business or employment if; 

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

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

Since the aircraft cannot carry passengers or property, we request to be relieved from this 

regulation if our pilots at minimum, 

(1) hold at least a current private pilot certificate and, 

(2) hold a current third class medical certificate. 

By meeting conditions (1) and (2), we believe that equivalent level of safety can be 

achieved by complying with 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness. 

14CFR 91.7 (a) states, 

“No person may operate a civil aircraft unless it is in an airworthy condition.” 

This rule prohibits the operation of an aircraft without an airworthiness certificate. 

Since there is no such existing certificate that is applicable for the Inspire UAS to properly 

comply with the FARs, we request that Pure Art Productions to be relieved from this 

regulation. 

To provide equivalent level of safety, we will ensure that the Inspire UAS is in
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airworthy condition prior to every flight by following safety procedures described in our 

operating documents. 

14 CFR 91.119 Minimum safe altitudes: General 

This regulation provides that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be 

operating at a maximum of 400 feet AGL, we cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over private property with the 

permission of the land owner. The land owner will be briefed of the expected route of flight 

and the associated risks to persons and property on the ground. We maintain that due to 

the small size of the Inspire, the hazard to persons, vessels, vehicles, and structures is not 

comparable to manned aircraft and should be considered in granting the exemption. 

14 CFR 91.121 Altimeter Settings 

This regulation provides that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 nautical miles of the aircraft. 

The Inspire aircraft will fly below 400 feet AGL and will not need to maintain hemispherical 

cruising altitudes in order to de-conflict with other aircraft. 

 

To provide an equivalent level of safety, the PIC will check and confirm the Inspire’s GPS 

altitude read out before each flight. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly 

after that for at least 30 minutes. We believe the intention of this rule is to provide a reserve 

of energy as a safety buffer for go-arounds and other delays to landing. 

The Inspire UAS is battery operated and the maximum duration of flight with full payload 

from a single battery charge is approximately 18 minutes. 

We believe that equivalent level of safety can be achieved by limiting our flight time to 14

minutes with reserve energy 20% (4 minutes) on the battery. 
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14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 ) Maintenance, Preventive 

Maintenance, and Alterations

 

The regulation provides that the operator is primarily responsible for maintaining the aircraft 

in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized 

under 43.7 "after maintenance and inspection. It is our intention that the PIC, VO or 

authorized personnel to perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." 

Pure Art Productions requests that exemptions to the regulations under conditions below; 

(1) Pure Art Productions will follow Inspire’s manufacturer maintenance instructions, 

techniques and procedures 

(2) Pure Art Productions will designate, train, and document the personnel who will be 

authorized to perform Inspection, Maintenance and Alterations by means of above stated 

maintenance instructions. Such designated personnel may include PIC, VO or other 

equivalent trained persons 

(3) To ensure equivalent level of safety, PIC will inspect the UA before each flight looking 

for any structural or mechanical malfunctions 

Due to the small size, light weight and simplicity of the Inspire UAS, we believe that the 

equivalent safety will be achieved by permitting any of the PIC, VO or equivalent trained 

personnel, to perform maintenance, inspection and alterations of the aircraft and "be 

authorized to approve the aircraft for return to service." 
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THE REASONS WHY GRANTING PURE ART PRODUCTIONS’S REQUEST WOULD BE 

IN THE PUBLIC INTEREST 

We believe that granting our exemption request from, 

14 CFR Part 21.191 

14 CFR Part 45.23, 45.29 

14 CFR 61.113, 61.133 

14 CFR 91.9, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the public’s interest and will 

benefit the public as a whole for the following reasons. 

1- Inspire is battery operated and free from the harmful emissions associated with the 

manned aircraft that are currently used for aerial photography and videography. 

As recently proven by several grants of section 333 petitions, UASs offer equivalent level of 

safety while reducing environmental impacts, which is in the public interest. 

2- Pure Art Productions’ UAS operations will contribute to a positive aggregate economic 

impact resulting in creation of jobs both direct and indirectly. Economic Research 

estimates that the UAS market will grow from $6 billion to $94 billion over the next decade 

resulting in a new workforce development. 

Because Pure Art Productions’ operations will create new jobs such as pilots, flight 

operation staff, and administrative supporting staff, it will directly cause positive economic 

impact, hence granting Pure Art Productions’ petition will benefit the public as a whole. 

3- Congress has already proclaimed that it is in the public’s interest to integrate 

Commercially flown UAS(s) into the national airspace system, hence the passing of the FAA 

Modernization and Reform Act of 2012. 

Granting Pure Art Productions’ petition furthers the public’s interest as a demonstrated 

progression of integrating Unmanned Aircraft Systems into National Air Space, thus it will 

benefit public as a whole.
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THE REASONS WHY GRANTING PURE ART PRODUCTIONS THE EXEMPTION 

WOULD NOT ADVERSELY AFFECT SAFETY 

Pure Art Productions believes that the grant of exemption from, 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), 

will not adversely affect safety by a combination of the reasons listed below. 

(a) We have stated in the above section “THE EXTENT OF RELIEF PURE ART 

PRODUCTIONS SEEKS AND THE REASONS PURE ART PRODUCTIONS SEEKS THE 

RELIEF” by describing how we intend to mitigate risk and accomplish FAA equivalent and 

acceptable level of safety for each 14 CFR part. 

 

(b) As a result of Inspire unmanned aircraft’s size, weight, speed, operational capability, 

proximity to airports and populated areas, operation within visual line of sight combined with

the implementation Pure Art Productions’ of safety procedures, we believe that granting 

Pure Art Productions’ exemption request will not adversely affect safety. 

(c) DJI Inspire 1 has demonstrated to satisfy necessary safety risk mitigation by FAA thus 

resulting in multiple grants of section 333 petitions. 

Because of the combination of Inspire’s proven success and the conditions and limitations 

of our operations, we believe granting Pure Art Productions’ request will not adversely affect 

safety. 
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SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 

Department of Transportation 

Federal Aviation Administration 

Petitioner: Pure Art Productions LLC 

Petition of exemption from sections of; 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Description of relief sought; 

Pure Art Productions seeks an exemption for commercial operation of the Inspire 

unmanned aircraft manufactured by DJI Co, Ltd. of China. 

The Inspire unmanned aircraft system has an onboard camera system capable of acquiring 

high resolution data. 

Proposed operations will offer real estate aerial photography, videography and aerial 

surveying services for other commercial industries. 
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ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT PURE ART PRODUCTIONS’S REQUEST 

 Inspire 1 Unmanned Aircraft System 

General Features 

 Ready to Fly, Multifunctional Quad-rotor System

 Customized H3-2D and H3-3D Gimbal Support 

 Precision Flight and Stable Hovering 

 18min Flight Time & Smart Battery 

 Auto Return-to-Home & Landing 

 Advanced Power Management 

 Intelligent Orientation Control (IOC) 

 Easy Battery Replacement 

 Self-tightening Propeller 

 Video Downlink Support 

 CAN-Bus Expansion Module 

 Control Link radio operating frequency 2.4 GHz ISM 

 Operating Distance 0.65 miles 

Aircraft Performance 

Empty Weight 5.2 lbs 

Max Take-off Weight 6.5 lbs 

Max Flight Speed 30 Knots 

Hover Accuracy (Ready to Fly) Vertical: 0.5m; Horizontal: 2.5m

Max Yaw Angular Velocity 150°/s 

Max Tilt Angle 35° 

Max Ascent / Descent Speed Ascent: 5m/s; Descent: 4m/s

Diagonal Length 559mm 

Flight Time 18 minutes 

No Privacy Issues 

Pure Art Productions’ proposed operations will create no privacy issues because the Inspire 

UAS will be operating in rural areas within the boundaries of the properties with the land 

owner’s permission. 

Pure Art Productions will also obtain any permits or authorizations from local authorities 

when necessary. 
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ACRONYMS 

AGL Above Ground Level 

ALoS Acceptable Level of Safety 

AMOC Alternative Method of Compliance 

ASI Aviation Safety Inspector 

ATC Air Traffic Control 

ATCAA Air Traffic Control Assigned Airspace 

ATS Air Traffic Service 

AVS Aviation Safety 

CFR Code of Federal Regulations 

COA Certificate of Waiver or Authorization 

CRM Crew Resource Management 

CS Control Station 

CRS Certified Repair Station 

DCP Divert/Contingency Point 

DHS Department of Homeland Security 

DME Distance Measuring Equipment 

DOD Department of Defense 

DSA Detect, Sense, and Avoid System 

FAA Federal Aviation Administration 

FCC Federal Communications Commission 

FARs Federal Aviation Regulations 

FIR Flight Information Region 

FL Flight Level 

FSIMS Flight Standards Information Management 

System 

FTP Flight Termination Point 

FTS Flight Termination System

GHz Gigahertz 

GCS

Inspire 

Inspire

Ground Control Station

Inspire Unmanned Aircraft System

Inspire Unmanned Aircraft

MHz Megahertz 

MTOW Maximum Takeoff Weight 

NAS National Airspace System 

NM Nautical Mile 

NOTAM Notice To Airman 

OPA Optionally Piloted Aircraft 

PIC Pilot in Command 

Pure Art Productions Pure Art Productions LLC

R&D Research and Development 

RF

RM

RNAV

RTB

RVSM

Radio Frequency 

Risk Management

Area Navigation

Return to Base

Reduced Vertical Separation Minimum
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TAS

TC

UA

UAS

UAV

VFR

VMC

VO

Traffic Advisory Systems

Type Certificate

Unmanned Aircraft

Unmanned Aircraft Systems(s)

Unmanned Aerial Vehicle

Visual Flight Rules

Visual Meteorological Conditions

Visual Observer