August 20, 2015

Exemption No. 12538

Regulatory Docket No. FAA−2015−1523

Mr. Rocky Babcock

1506 Providence Cove Court

Byron Center, MI 49315

Dear Mr. Babcock:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letters posted to the public docket on May 8, July 2, and July 16, 2015, you petitioned the 

Federal Aviation Administration (FAA) for an exemption. The petitioner requested to operate 

an unmanned aircraft system (UAS) to conduct aerial photography, videography, and 

surveying.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.
2

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Rocky Babcock is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, Mr. Rocky Babcock is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

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

capability. The VO 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 VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
4

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 or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
5

operated under this exemption, including evasive and emergency maneuvers and 

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

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

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

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
7

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Rocky Babcock - Exemption/Rulemaking

This Other document was issued by the Federal Aviation Administration

(FAA)

For related information, Open Docket Folder 

Content

I am filing this submission for exemption from CFR part 21. I would like 

to petition for the use of a DJI Inspire 1 UAS for aerial photography, 

videography and surveying for personal and commercial use. All such 

operations during which time the UAS is used will include willing 

participants or where barriers are present to protect bystanders in the 

event of a crash or debri from the UAS. These operations seek to be 

suitable as safe alternatives to manned aircraft operations which are 

exponentially larger and carry fuel as well as operators and will be 

conducted as safely as possible. If there is any inclination of damage to 

the aircraft, property or individuals there will be no use of the UAS. 

Operations of the UAS will include a standard pre-flight checklist and 

inspection of surroundings. These steps will include 

1 - Make Sure Batteries Are Fully Charged Both in transmitter and 

aircraft batteries 

2 - Power On Transmitter 

3 - Power On aircraft 

4 - Load DJI App 

5 - Exit Storage Mode 

6 - Power Off A/C 

7 - Attach Camera 

8 - Install Aircraft Props & Prop locks 

9 - Allow Aircraft To Accumulate Itself to Outside Temperature If 

Necessary 

10 - Power On Aircraft 

11 - Calibrate Compass 

12 - Calibrate IMU 

13 - Set Fail Safe Height 

14 - Set Return To Home 

15 - Power up motors and allow to warm up 

16 - Verify GPS lock via Pilot App 

17 - Verify Transmitter and Aircraft Connection 

17- Verify surroundings are clear 

The specifications for the DJI Inspire 1 are as follows: 

**Aircraft** 

Model T600 

Weight (Battery Included) 

2935 g 

Hovering Accuracy (GPS mode) 

Vertical: 0.5 m 

 

Comment Now!

ID: FAA-2015-1523-0001

Document Informatio

Date Posted:

May 8, 2015

Show More Details 

Submitter Informatio

Submitter Name:

Rocky Babcock

Mailing Address:

1506 Providence Cove Court

City:

Byron Center

Country:

United States

State or Province:

MI

ZIP/Postal Code:

49315

Comments

0

Docket Information

This document is contained in

FAA-2015-1523

Related Dockets:

None

Related RINs:

None

Comments Received

Regulations.gov - Other Document Page 1 of 6

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Horizontal: 2.5 m 

Max Angular Velocity 

Pitch: 300/s 

Yaw: 150/s 

Max Tilt Angle 

35 

Max Ascent Speed 

5 m/s 

Max Descent Speed 

4 m/s 

Max Speed 

22 m/s (ATTI mode, no wind) 

Max Flight Altitude 

4500 m 

Max Wind Speed Resistance 

10 m/s 

Max Flight Time 

Approximately 18 minutes 

Motor Model 

DJI 3510 

Propeller Model 

DJI 1345 

Operating Temperature Range 

-10 to 40 C 

Diagonal Distance 

559 to 581 mm 

Dimensions 

438x451x301 mm 

**Gimbal** 

Model 

ZENMUSE X3 

Output Power (with camera) 

Static: 9 W 

In Motion: 11 W 

Operating Current 

Station: 750 mA 

Motion: 900 mA 

Angular Vibration Range 

0.03 

Mounting 

Detachable 

Controllable Range 

Pitch: -90 to +30 

Related Documents:

None

 This count refers to the total 

comment/submissions received

this document, as of 11:59 PM 

yesterday. Note: Agencies revie

submissions, however some 

agencies may choose to redact

withhold, certain submissions (o

portions thereof) such as those 

containing private or proprietary

information, inappropriate langu

or duplicate/near duplicate 

examples of a mass-mail campa

This can result in discrepancies

between this count and those 

displayed when conducting 

searches on the Public Submiss

document type. For specific 

information about an agency’s p

submission policy, refer to its 

website or the Federal Register

document. 

*

Regulations.gov - Other Document Page 2 of 6

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Pan: 320 

Mechanical Range 

Pitch: -125 to +45 

Pan: 330 

Max Controllable Speed 

Pitch: 120/s 

Pan: 180/s 

**Camera** 

Name 

X3 

Model 

FC350 

Total Pixels 

12.76M 

Effective Pixels 

12.4M 

Image Max Size 

4000x3000 

ISO Range 

100-3200 (video) 

100-1600 (photo) 

Electronic Shutter Speed 

8s 1/8000s 

FOV (Field of View) 

94 

CMOS 

Sony EXMOR 1/2.3 

Lens 

20mm (35mm format equivalent)f/2.8 focus at 

9 Elements in 9 groups 

Anti-distortion 

Still Photography Modes 

Single shoot 

Burst shooting: 3/5/7 frames 

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias 

Time-lapse 

Video Recording Modes 

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 

FHD: 1920x1080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

Max Bitrate of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Regulations.gov - Other Document Page 3 of 6

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Supported SD Card Types 

Micro SD 

Max capacity: 64 GB. Class 10 or UHS-1 rating required. 

Operating Temperature Range 

0 to 40 C 

**Remote Controller** 

Name 

C1 

Operating Frequency 

922.7~927.7 MHz (Japan Only) 

5.725~5.825 GHz 

2.400~2.483 GHz 

Transmitting Distance (outdoor and unobstructed) 

2 km 

EIRP 

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G 

Video Output Port 

USB, mini-HDMI 

Power Supply 

Built-in battery 

Charging 

DJI charger 

Dual User Capability 

Host-and-Slave connection 

Mobile Device Holder 

Tablet or Phone 

Max Mobile Device Width 

170mm 

Output Power 

9 W 

Operating Temperature Range 

-10 to 40 C 

Storage Temperature Range 

Less than 3 months: -20 to 45 C 

More than 3 months: 22 to 28 C 

Charging Temperature Range 

0-40 C 

Battery 

6000 mAh LiPo 2S 

**Charger** 

Model 

A14-100P1A 

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Voltage 

26.3 V 

Rated Power 

100 W 

**Battery (Standard)** 

Name 

Intelligent Flight Battery 

Model 

TB47 

Capacity 

4500 mAh 

Voltage 

22.2 V 

Battery Type 

LiPo 6S High voltage battery 

Energy 

99.9 Wh 

Net Weight 

570 g 

Operating Temperature Range 

-10 to 40 C 

Storage Temperature Range 

Less than 3 months: -20 to 45 C 

More than 3 months: 22 C to 28 C 

Charging Temperature Range 

0 to 40 C 

Max Charging Power 

180 W 

**Battery (Additional)** 

Name 

Intelligent Flight Battery 

Model 

TB48 

Capacity 

5700 mAh 

Voltage 

22.8 V 

Battery Type 

LiPo 6S 

Energy 

129.96 Wh 

Net Weight 

Regulations.gov - Other Document Page 5 of 6

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670 g 

Operating Temperature Range 

-10 to 40 C 

Storage Temperature Range 

Less than 3 months: -20 to 45 C 

More than 3 months: 22 to 28 C 

Charging Temperature Range 

0 to 40 C 

Max Charging Power 

180 W 

**Vision Positioning** 

Velocity Range 

Below 8 m/s (2 m above ground) 

Altitude Range 

5-500 cm 

Operating Environment 

Brightly lit (lux > 15) patterned surfaces 

Operating Range 

0-250 cm 

Regulations.gov - Other Document Page 6 of 6

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US Department of Transportation

Federal Aviation Administration

800 Independece Ave, SW

Washington, DC 20591

Dear Exemption Manager,

In reference to docket number FAA-2015-1523. It has been brought to my attention that there has bene 

a request for additional information posted under ID FAA-2015-1523-0002. This letter requested the 

following additional information:

- The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

- The reasons why 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 form which you seek 

exemption.

- Any additional information, views, or arguments available to support your request.

Section 1: The reasons why granting the request would be in the public interest and how it would 

benefit the public as a whole.

Granting this request for exemption would further communicate the importance of UAS safety 

throughout the general public. While many hobbyists do not have plans for safety nor do they know the 

rules of airspace governed by the FAA there is a need to grant exemptions to individuals, such as myself, 

who plan to strictly adhere to all rulemaking procedures set forth by the FAA and follow these rules. I 

plan to understand any and all rules as it pertains to the hobby and my particular aircraft. 

For example, an amateur photographer or videographer may be approached to take video or 

pictures for events such as sporting events, races, or simply for a new vantage point a business would 

like to show to the public without knowing the rulings for this procedures necessary for safe operation. I 

intend to operate my UAS in a safe manner as previously described in the original docket and promote 

the safe flying of a UAS for commercial use as I plan to use the UAS for monetary compensation for 

individuals or businesses looking to get pictures which include but are not limited to; pictures of their 

business, pictures of land, or pictures of any operations being performed. 

This operation also includes any videography that will be performed for compensation in order 

to promote a brand or survey operations such as a work zone or construction project with new products 

which companies seek to promote. This may also include aerial videography, which companies choose 

to promote action sports with the strict consideration of using my particular UAS and how it will 

operate.
Section 2: The reasons why 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 form which you seek 

exemption.

Granting exemption would not adversely affect safety of individuals, wildlife or other structures. 

The UAS will remain clear of all objects and structures as well as persons by obtaining a minimum range 

of safety from the FAA or otherwise specifically requesting written consent for a person or structure to 

be within the safe operating range of the UAS. Additionally any necessary barriers or buffers will be in 

place in order to ensure safe operating distances are met by the UAS operator (Rocky Babcock). This 

does not include closed set filming or photography but will pertain to recreational areas or private land 

or public areas as requested by an individual or business.

As previously stated, recreational hobbyists that attempt to provide services like this may not 

have required documentation or the necessary pre-flight checklist as well as knowledge of the rules set 

forth by the FAA. In order to maximize safety all FAA rules will pertain to any and all UAS operations 

performed by myself via the DJI Inspire 1 aircraft. I seek to find the right rules and guidelines to safely 

operate the Inspire 1 in a manner appropriate for any weather conditions or terrain in order to provide

the safety of any standing structures or people in the surrounding area. 

Section 3: Any additional information, views, or arguments available to support your request.

As a recreational hobbyist of 5 years in the radio controlled industry, I have a working 

knowledge of various parts, systems, and necessary safety knowledge for the operation of the Inspire 1 

for commercial use. I began flying small helicopters and progressed to larger, acrobatic helicopters that 

I continue to use to this day. This began my interest in these hobbies and much of my personal life 

involves repairing, operating and troubleshooting various small to mid-size helicopters strictly for 

recreational use.

Upon receiving the gift of the DJI Inspire 1 I have been approached by various individuals 

interested in any services I may provide with the UAS but I have turned down all inquiries as they would 

not be considered recreational and would fall under the commercial use category.

As far as safety is concerned, I am currently a large part, in my professional career, in charge of 

the safety operations of my current company as well as my previous company. I have been in the safety 

regulation side of daily operations of various companies coming on to 4 years now, and understand the 

importance of safety as it pertains to any commercial situation. I do possess a knowledge and 

inclination to act within safety guidelines as I understand how disastrous not following any particular 

procedure may be.

The primary reason for my request for exemption doe include safety. I have been approached 

to gather information, video and pictures of a traffic control work zone. There is a style of sheeting 

called ‘Diamond Grade’ sheeting for traffic drums seen in construction zones. The Michigan Department 

of Transportation is interested in making this sheeting, which is the highest reflectivity you can get for 

this type of product, a requirement for all road construction projects. The company that wants this 

information wants to show a work area where this sheeting is being used and draw comparisons to 

show how much more visible this sheeting is to motorists than current sheeting required by the MDOT. 
This is not something that will be provided by myself until I have the required exemption to do so. 

These operations would not include any flight over any passing vehicles but would be performed any 

required distance away from people, vehicles and other structures which the Inspire 1 could cause 

harm.

Additionally I have been approached to provide videography and photography services for 

companies in order to take pictures of their inventory contained in their outdoor, enclosed yard areas. 

With these particular instances in mind I would like to gain exemption in order to offer my services for 

compensation as requested by companies or individuals.

I do seek to be as safe as possible in my operations and do understand the rules of the airspace. 

I intend to be a hobbyist (currently) that exemplifies a working knowledge of commercial use of the UAS 

and provide services in a safe and professional manner while adhering to the rules of the FAA.

I thank you for your consideration and look forward to hearing back from you.

Sincerely,

Rocky Babcock
Rocky Babcock seeks relief from the following specific sections of Title 14 of the Code of 

Federal Regulation:

61.23

Medical Certificates: Requirement and duration

61.101(e)(4) and (5)

Recreational pilot privileges and limitations

61.113(a)

Private pilot privileges and limitations: Pilot in Command

61.315(a)

What are the privileges and limitations of my sport pilot certificate?

91.7(a)

Civil aircraft airworthiness

91.119(c)

Minimum safe altitudes: General

91.121

Altimeter settings.

91.151(a)(1)

Fuel requirements for flight in VFR conditions

91.405(a)

Maintenance required.

91.407(a)(1)

Operation after maintenance, preventive maintenance, rebuilding, or alteration.

91.409(a)(1) and (2)

Inspections

91.417(a) and (b)

Maintenance records.

Rocky Babcock submits this request in accordance with the Reform Act, 112 P.L. 95 §§ 331-

334 pursuing abatement from any current applicable FARS operating before me. I do intend to 

use the UAS for compensation for areal photogrophy, videogrphay and surveying provided for 

intended individuals or groups that wish to utilize my services. 
The Inspire 1 meets the classification requirements in the Reform Act in Section 332 pertaining 

to civil unmaned aircraft in to national airspace. The Inspire 1 also meets the definition of ‘small 

unmanned aircraft’ as defined in section 331.
Public Interest

Please also consider the public interest as it pertains to fuel emissions. Additionally the UAS runs on 

battery power and does not emit fumes or run on gases are potentially harmful to the environment. 

The operation of this UAS removes human exposure to these situations as it pertains to full size 

helicopters that may be used for photography or videography. If a UAS such as the Inspire 1 does lose 

control and crashes there is no flammable gas that may explode. 

Equivalent Level of Safety

An equivalent level of safety will be obtained by the operator per the Operator Manual and User Guide. 

A data log will supplement safety along with automatic tracking of flight time and distances to gauge 

when maintenance will be required. The operator will make sure all systems are functioning properly 

prior to all flights. 

If any issues arise the UAS will immediately land where it is able to do so safely. The ability to land in 

otherwise difficult or impossible areas where a helicopter may be unable to land will create less risk 

than a traditional rotorcraft which performs the same operation.