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FROM:

RYAN RUSH

SKY VIEW U.A.S., L.L.C.

3545 RED PONTIAC DRIVE

PORT ORANGE, FL 32129

Tel: 860-977-3181

Email: rush.ryan.c@gmail.com

TO:

DOCKET OPERATIONS

ROOM W12-140 OF THE WEST BUILDING

GROUND FLOOR

1200 NEW JERSEY AVENUE, SE.

WASHINGTON, DC, 20590

REGULATORY DOCKET NO: _____________________________

PETITION FOR EXEMPTION OF:

SKY VIEW U.A.S., LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS

§§ 61.113(a) & (b), 91.109, 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 DJI INSPIRE 1 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

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

SUBMITTED ON JUNE 15, 2015
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS.............................................................................................3 

SUMMARY.....................................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER.............................................................4 

BACKGROUND.............................................................................................................................4 

BASIS FOR PETITION..................................................................................................................6

NAME AND ADDRESS OF PETITIONER...................................................................................9

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SKY VIEW UAS, LLC SEEKS 

EXEMPTION..................................................................................................................................9

THE EXTENT OF RELIEF SKY VIEW UAS, LLC SEEKS AND THE 

REASON SKY VIEW UAS, LLC SEEKS THE RELIEF......................................................14

THE REASONS WHY GRANTING SKY VIEW UAS, LLC REQUEST 

WOULD BE IN THE PUBLIC INTEREST ..............................................................................18

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY................................................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...........................38

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

CONCLUSION..............................................................................................................................39
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GLOSSARY OF ABBREVIATIONS

AGL - Above Ground Level 

AOI - Area of Interest 

ATC - Air Traffic Control 

ATO - Air Traffic Organization 

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 

NAS - National Airspace System 

NOTAM - Notice to Airman 

PIC - Pilot In Command 

Section 333 - FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO - Safety Observer 

SOP - Standard Operating Procedures 

UA - Unmanned Aircraft 

UAS - Unmanned Aircraft System 

VFR - Visual Flight Rules 

VLOS - Visual Line of Site 

VMC - Visual Meteorological Conditions 

VTOL - Vertical Takeoff and Landing
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SUMMARY 

Sky View U.A.S., LLC (Ryan Rush) seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.109, 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 Sky View 

U.A.S., LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video, photography and data collection of Real Estate Properties (for 

homeowners, realtors, home builders, home contractors and/ or home inspectors for real estate 

marketing and inspection of home exteriors) as well as filming of special events, film sets, 

scripted and unscripted television sets and landscape, conducting water, electrical and oil utility

structure inspections, aerial mapping, surveying and search and rescue and similar 

operations throughout the United States of America.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Sky View UAS, LLC is a data collection company based in Florida looking to conduct UAV 

operations for real estate videography, photography, music video production, special event 

production and film and television production for the purpose of industrial, agricultural and 

entertainment purposes. The owner (Ryan Rush) of Sky View UAS has extensive fixed-wing 

aeronautical experience, having been in the aviation industry for over ten years. The primary

concerns of Sky View UAS is safety as well as complete cooperation with the FAA and other 

controlling agencies. The intentions of Sky View UAS, LLC is to establish and maintain a 

mutually beneficial relationship with the FAA and operate UA’s within the NAS. The primary

objective of Sky View UAS is to conduct aerial photography, videography and data collection in 
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order to provide high quality digital imaging and video content to its clients, in particular to 

homeowners, real estate agents, realtors, home builders, home contractors, and/or home 

inspectors for real estate marketing and inspections of home exteriors, various agricultural 

applications as well as filming of special events, film sets, scripted and unscripted television sets 

and landscape, conducting power line inspection, aerial mapping, surveying and search and 

rescue utilizing DJI Inspire1 UAS platforms. More specifically, Sky View UAS, LLC operations 

will serve in the following areas: 

 Aerial photography of houses / residential and commercial buildings, power lines and other 

infrastructure

 Aerial videography of houses / residential and commercial buildings, power lines and other 

infrastructure

 Aerial event photography 

 Aerial event filming 

 Aerial Film & Television production

 Aerial data collection for construction and agricultural applications

 Aerial search and rescue operations

 Aerial safety inspections of houses / residential and commercial buildings, power lines and 

other infrastructure

 Increase public knowledge of UAS and promote safe UAS operations.

 Work to help integrate unmanned aerial systems into FAA governed NAS
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Unmanned Aircraft Systems: DJI Inspire 1 UAS

Sky View UAS, LLC (Ryan Rush) seeks an exemption to operate DJI systems DRONES for 

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

Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or 

smart phone systems. The DJI Inspire 1 UA have a maximum gross weight of approximately 6.5 

pounds, while having a length of 17 inches width of 18 inches, height of 12 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 Sky View UAS, LLC (trained professional), 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.

BASIS FOR PETITION

Petitioner, Sky View UAS, LLC, 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 UA in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.119(b) & 

(c), 91.121, 91.151(b), 91.203(2)(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, Sky View UAS, LLC operation of DJI Inspire 1 UA meets 
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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, Sky View UAS, LLC 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. Sky View UAS, LLC 

submits that the requested relief is proper since an equivalent level of safety will be ensured and 

complied with. Sky View UAS, LLC will use experienced and trained personnel or technicians 

to perform maintenance, alterations, or preventive maintenance on the UA using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, 

and DJI Inspire 1 Instruction Manual). Furthermore, Sky View UAS, LLC will document and 

maintain all maintenance and modification records for the DJI Inspire 1 UA.

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

and limitations: Pilot In Command, is requested by Sky View UAS, LLC to the extent necessary

to allow a Pilot in Command (PIC) to be any personnel listed under the company’s list of 

authorized operators, and that have demonstrated proficiency, and that the PIC is able to safely

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

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

structures not subject to inspections. Sky View UAS, LLC will maintain training records and 

proficiency records of all authorized operators. 

Sky View UAS, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 UA do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Sky View UAS, LLC submits that it will ensure that the DJI 
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Inspire 1 UA are in an airworthy condition, prior to every flight, by determining that the UAS’s 

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 in accordance with 

the manufacturer's’ operations manuals. 

Sky View UAS, LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UA will not have a conventional barometric altimeter 

installed onboard. However, altitude information of the DJI Inspire 1 UA 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 Sky View UAS, LLC’s operation of the DJI Inspire 1 UA 

within visual line of sight (VLOS), as well as at or below 400 feet AGL or as required in the 

vicinity of structural inspection operations, not to exceed 100 feet above structure or 500 feet 

laterally from base of structure, will ensure a level of safety equivalent to Section 91.121. Sky 

View UAS, LLC believes additional exemption for altitudes in excess of 400 feet AGL is 

acceptable in the vicinity of structures subject to inspection due to the negligible effects that it 

will have on NAS operations. Aircraft operating in the NAS are required to maintain a minimum 

vertical and lateral separation of 500 to 1,000 feet vertically and 1,000 to 2,000 feet horizontally 

from all structures depending on the congestion of the area. 

Additionally, Sky View UAS, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Sky View UAS, LLC submits 

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

maintaining visual contact with the UAS, with enough battery power to fly for a total duration of 
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approximately 10 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, Sky View UAS, LLC provides the following information 

in support of its petition for exemption:

A. Name and Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Ryan Rush

Sky View UAS, LLC

3545 Red Pontiac Drive

Port Orange, FL 32129 

Tel: 860-977-3181

Email: rush.ryan.c@gmail.com

B. The Specific Sections of 14 C.F.R. From Which Sky View UAS, LLC Seeks Exemption. 

1. Sky View UAS, LLC 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. 
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2. Sky View UAS, LLC 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. Sky View UAS, LLC 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. Sky View UAS, LLC for Exemption 

Page 10 

4. Sky View UAS, LLC 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. 
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5. Sky View UAS, LLC 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. Sky View UAS, LLC 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. Sky View UAS, LLC 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.
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8. Sky View UAS, LLC 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. 
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(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 Sky View UAS, LLC Seeks And The Reason Sky View UAS, LLC Seeks 

The Relief.

1. Extent Of Relief Sky View UAS, LLC Seeks And The Reason Sky View UAS, LLC 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 Pilot in Command (PIC) to mean any

operator listed under the company’s list of authorized operators, and has demonstrated 

proficiency and currency requirements, and that the PIC is able to safely operate the DJI Inspire 
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1 UA in a manner consistent with this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures not subject to 

inspections. PIC shall maintain, at a minimum, a current and valid third-class airman medical 

certificate, 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, Sky View UAS, LLC submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the DJI Inspire 1 UA unless that PIC has met certain 

proficiency requirements, demonstrating that the PIC is able to safely operate the DJI Inspire 1 

UA 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, Sky View UAS, LLC submits that all flights of 

the DJI Inspire 1 UA conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to Sky View UAS, LLC business; and (2) will not carry passengers or property for 

compensation or hire. Sky View UAS, LLC believes that though UAS are not traditional 

aircrafts, a PIC operating the UA must have adequate knowledge of airman rules, basic airspace

knowledge and be able to comply with all the rules proposed by the FAA. However, considering 

the fact that a UA is similar in nature to a toy, weighing very little and risks associated with their 

operations are drastically less, the PIC may be exempt from obtaining a Private Pilot Certificate, 

a Sports Certificate, or a Recreational Certificate, considering these certificates require extensive 
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flight training in aircraft that far exceed complexity of operations and grossly outweigh that of a 

UA.

Lastly, Sky View UAS, LLC PICs will operate the UAS no higher than 400 feet unless in the 

vicinity of structures under inspection, not to exceed 100 feet above the highest point of the 

structure and not exceeding a lateral limitation of 500 feet from the base of the structure, 

consequently causing no danger to any other aircraft in the NAS. However, Sky View UAS, LLC 

Proposes that all authorized operators acting as PIC must demonstrate proficiency and a 

minimum requirement of successfully completed private pilot knowledge examination within 24 

calendar months. Sky View UAS, LLC will maintain training records and proficiency records of 

all named operators.

2. Extent of Relief Sky View UAS, LLC Seeks and the Reason Sky View UAS, LLC 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 Sky View UAS, LLC to determine that the DJI Inspire 1 UA are in airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., the Sky View UAS, LLC Aerial Operations Manual, Monthly maintenance Log, 

and DJI Inspire 1 UA Instruction Manual). Sky View UAS, LLC seeks the requested relief 

because the DJI Inspire 1 UA do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Sky View UAS, LLC will ensure that the DJI Inspire 1 

UA are in airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Inspire 1 UA Instruction Manual) prior to every flight, and 
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further, determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

3. Extent Of Relief Sky View UAS, LLC Seeks And The Reason Sky View UAS, LLC 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 UA 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), Sky View UAS, LLC 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 are not equipped with a barometric pressure sensor rather 

GPS equipment, and provides the PIC with altitude information of the UA on the heads-up 

display of the GCS. 
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4. Extent Of Relief Sky View UAS, LLC Seeks And The Reason Sky View UAS, LLC 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), for a total duration of 10 minutes to 

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

least 4.5 minutes. Sky View UAS, LLC 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 Sky 

View UAS, LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, 

the technical specifications of the DJI Inspire 1 UA operating documents, and Sky View UAS, 

LLC proposed operating limitations, ensure that Sky View UAS, LLC will safely operate the 

battery powered DJI Inspire 1 UA , during daylight hours in visual meteorological conditions 

(VMC), with enough battery power to fly for a total duration of no less than 10 minutes to the 

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

4.5 minutes.

5. Extent Of Relief Sky View UAS, LLC Seeks And The Reason Sky View UAS, LLC Seeks 

Relief From Section 91.405(a), 91.407(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, Sky View UAS, LLC requests relief from these 

Sections because the DJI Inspire 1 UA does not require airworthiness certificates. As set forth 
18

more fully below, the DJI Inspire 1 UA meets the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Sky View UAS, LLC will use trained 

technicians to perform maintenance, alterations, or preventative maintenance on the UAS using 

the methods, techniques, and practices prescribed in the UAS operating documents (i.e. the Sky

View UAS, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 UA 

Instruction Manual). Furthermore, Sky View UAS, LLC will document and maintain all 

maintenance records for the DJI Inspire 1 UA. 

D. The Reasons Why Granting Sky View UAS, LLC Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Sky View UAS, LLC to 

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

real estate, special events, film sets, and landscape throughout the United States. Additionally, 

use of the DJI Inspire 1 UA will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Sky View UAS, LLC’s proposed 

operation of the DJI Inspire 1 UA will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Inspire 1 UA 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 UA 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. 
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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 UA 

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. 

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

Conducting aerial acquisitions with the DJI Inspire 1 UA 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 UA produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, internal combustion engine aircraft that 

are typically utilized for aerial video and photography, while burning approximately 10-30 

gallons per hour of leaded 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 UA to perform aerial data collection, 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 6.5 

pounds, at their maximum gross weights with lengths of 17 inches, widths of 18 inches, and with 

no combustible fuel on board), has less physical potential for collateral damage to life and 
20

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

similar operations (weighing approximately 4,000 pounds and a significantly higher fuel 

capacity). Additionally, expressed public concern over the safety and stability of lithium ion/ 

LIPO batteries is negligible in comparison to the risk associated with the same battery types 

being present and allowable onboard commercial airliners. 

3. Performing Aerial Video, Photography and Data Collection Operations With The DJI Inspire 

1 UA Will Benefit The Economy.

In addition to the increase safety to the public and efficiency of the operations, the DJI Inspire 1 

UA is also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Inspire 1 UA will allow United States based 

companies, like Sky View UAS, LLC, 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 UA 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 UA companies such as Sky View UAS, LLC, 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 UA provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 
21

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, 

Sky View UAS, LLC proposed operation of the DJI Inspire 1 UA will not implicate any privacy

issues. Specifically, the DJI Inspire 1 UA will be operated only in compliance with operating 

documents (i.e., the Sky View UAS, LLC Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Inspire 1 UA 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 Sky View UAS, LLC Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UA 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, Sky View UAS, LLC, operation of the DJI Inspire 1 UA 

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 
22

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 rule-making 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, Sky View UAS, LLC submits that the DJI Inspire 1 UA, can operate 

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

(a) the characteristics of the DJI Inspire 1 UA ; 
23

(b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Inspire 1 UA Demonstrate Its Safe Characteristics.

The DJI Inspire 1 UA 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 UA is set forth by the DJI Inspire 1 UA 

Specifications and Data Sheet, attached hereto as Exhibit A. 

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

Remain Within A Defined Operational Area based on United States governments Global 

Positioning System. 

The DJI Inspire 1 UA 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 UA is provided at 

pages 12-17 of the DJI Inspire 1 UA User Manual. Autonomous operations allow operators to 

apply forethought and plan operations more strategically to minimize potential for conflicts. 

iii. The DJI Inspire 1 UA 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 UA will remains stationary, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire control link data 

from the GCS, the UAS will assume that the Control Link is lost and the UA will return to the 
24

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 UA are set forth 

on page 15 of the DJI Inspire 1 UA User Manual. 

iv. The DJI Inspire 1 UA GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Inspire 1 UA, and flight 

control software is provided at pages 32 through 43 of the DJI Inspire 1 UA User Manual. DJI 

Inspire 1 UA User Manual is attached hereto as Exhibit B & D. 

b. Flight Operations Of DJI Inspire 1 UA Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command. 

Sky View UAS, LLC will only allow authorized operators to operate the UA by visual reference 

not to exceed line-of-sight. All authorized operators will possess, at minimum, a current and 

valid third-class airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 

1 UA. 

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

Limitations. 

In seeking this exemption, Sky View UAS, LLC proposes to commercially operate DJI Inspire 1 

UA for the special purpose of conducting aerial video, photography and data collection 

throughout the 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 
25

gross weight: DJI Inspire 1 UAS. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant of exemption.

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

of aerial video, photography and data collection for homeowners, realtors, home builders, 

contractors, home inspectors for use in real estate marketing and real estate inspections. 

Additionally, aerial video, photography and data collection may be conducted for film and 

television sets, special events and landscape photography, conducting power line and 

infrastructure inspection, aerial mapping, surveying as deemed necessary. 

3. The UAS may not be flown at an indicated airspeed exceeding 42 knots. 

4. The UAS 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 in the vicinity of 

structural inspection operations, not to exceed 100 feet above structure or 500 feet laterally from 

base of structure. If inspected structures are within a 5 nautical mile radius of an airport, Sky 

View UAS, LLC will seek issuance of a NOTAM and will maintain contact with any controlling 

facility, advising of commencement and completion of operations. All altitudes must be reported 

to ATC within a 5 nautical mile radius from center point of any controlled airport. Altitudes must 

be reported 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. 
26

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

navigation purposes. Use of FPV will only be to aid in situational awareness. 

7. All operations may utilize a safety observer (SO) if deemed appropriate to meet the needs of 

the operation and ensure safety. 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 a copy of the grant of exemption must be accessible during UAS 

operations and made available to the Administrator or law enforcement 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 
27

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 
28

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 be listed on the company record as an authorized operator and must have ontheir-person at least a current third- class medical certificate while operating a UAS. Authorized 

operators must have, at a minimum, successfully completed private pilot ground school. 

Additionally, authorized operators not holding, at a minimum, a current FAA private pilot 

certificate must have successfully passed the private pilot, commercial pilot, or airline transport 

pilot knowledge test within the past 24 calendar months.

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 and currency 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 
29

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 time, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual conditions. If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of operations. 

20. The UA may not operate within 3 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. 
30

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. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UAS must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

27. The documents required in accordance with 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. 

28. The UAS must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

29. 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 
31

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). 

30. 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. 

31. 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. 

Sky View UAS, LLC submits that the equivalent level of safety established by Section 61.113(a) 
32

and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UA 

unless that PIC has demonstrated, by meeting proficiency and currency requirements, that the 

PIC is able to safely operate the DJI Inspire 1 UA in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering Sky View UAS, LLC 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 UA , Sky View UAS, LLC submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for Sky View UAS, LLC 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). 

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, Sky View UAS, LLC 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 
33

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 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 Sky View 

UAS, LLC’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet 

AGL, excluding structures subject to inspections, 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). 
34

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, Sky View UAS, LLC will ensure that it will safely operate the battery 

powered DJI Inspire 1 UA during daylight hours in visual conditions, with enough battery power 

to fly for a total duration of 10 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 UA ; 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 UA 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, 
35

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, Sky View UAS, LLC 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 Sky 

View UAS, LLC 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., the Sky View UAS, LLC Aerial Operations Manual, Monthly

Maintenance Log, and DJI Inspire 1 UA Instruction Manual). Furthermore, Sky View UAS, LLC 

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

Inspire 1 UA will be inspected as prescribed by the operating documents, Sky View UAS, LLC 

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because Sky View UAS, LLC, 

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 UA will 

be performed by trained technicians. Maintenance will be documented and maintained utilizing 

the monthly maintenance log. Significantly, previous exemptions granted by the FAA 
36

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 Sky View UAS, LLC proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, Sky View UAS, LLC 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, Sky View UAS, LLC 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 and data collection throughout 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 
37

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 UA , 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, the FAA may prescribe 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 Sky View UAS, LLC’s intended operation of the DJI Inspire 1 

UA , 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). 
38

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

Which Sky View UAS, LLC Seeks Exemption: 

Sky View UAS, LLC 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 Sky View UAS, LLC Seeks: 

This exemption will permit Sky View UAS, LLC to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial video and photography and data collection 

throughout the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support Sky View 

UAS, LLC 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, Sky View UAS, LLC, 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, Sky View UAS, LLC 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. 
39

CONCLUSION 

As set forth herein, Sky View UAS, LLC 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 and data collection 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 Sky View UAS, LLC, to safely, efficiently, 

and economically operate the DJI Inspire 1 UA commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Sky View UAS, LLC 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 Sky View UAS, LLC to operate the DJI Inspire 1 UAS 

commercially for the purpose of conducting aerial video and photography of Real Estate 

Properties (for homeowners, realtors, home builders, home contractors and / or home inspectors 

for real estate marketing and inspection of home exteriors) as well as filming of special events, 

film sets, scripted and unscripted television sets and landscape as well as conducting power line 

inspection, aerial mapping, surveying and search and rescue over certain areas of the United 

States. 
40

Dated: June 15, 2015 

Respectfully submitted by, 

Ryan Rush

Sky View UAS, LLC 

3545 Red Pontiac Drive

Port Orange, FL 32129 

Tel: 860-977-3181 

Email: rush.ryan.c@gmail.com