UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

ABS AERIAL IMAGING SERVICE 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF THE DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on June 18, 2015 

ABS Aerial Imaging Service 

Peter Scott Myers (Owner) 

4322 Long Lane 

Franklin, TN 37064 

(615) 504-7676 Cell/Office 

scottm@abssite.com 
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TABLE OF CONTENTS

Page 

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

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

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

BACKGROUND....................................................................................................................5 

BASIS FOR PETITION.........................................................................................................5 

NAME AND ADDRESS OF PETITIONER.........................................................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ABS AERIAL IMAGING 

SERVICE SEEKS EMPTION...............................................................................................8 

THE EXTENT OF RELIEF ABS AERIAL IMAGING SERVICE SEEKS AND THE 

REASON ABS AERIAL IMAGING SERVICE SEEKS THE RELIEF..........................12 

THE REASONS WHY GRANTING ABS AERIAL IMAGING SERVICE’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .....................................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY...............................................................................................................18 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..................32 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT ABS AERIAL IMAGING SERVICE’S REQUEST ..............................33 

CONCLUSION....................................................................................................................33 

APPENDICES........................................................................................35
3

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
4

SUMMARY

ABS Aerial Imaging Service seeks exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit ABS Aerial Imaging Service to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography within the National 

Airspace System (NAS). 

INTRODUCTION AND INTERESTS OF THE PETITIONER

 Peter Scott Myers, owner of ABS Aerial Imaging Service, is a private pilot with a 

glider rating - certificate number 3147544, with over 700 hours of flight experience and 

470 flights. He has over 10 years recreational/hobby experience with radio controlled 

model airplanes and video/photography. The objective of ABS Aerial Imaging Service is 

to provide high quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting, but not limited to: 

• Construction sites before and after 

• Appraisals 

• Real-estate marketing 

• Weddings and Special Events 

• Aerial acquisitions used for inspections of public and private structures. 

• Search and Rescue operations 

• Marine/Maritime inspections and photography 

BACKGROUND
5

Unmanned Aircraft System: DJI Inspire 1 

ABS Aerial Imaging Service seeks an exemption to operate DJI Inspire 1 system 

for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and 

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

integrated touchscreen control, electronic tablet or smart phone systems. This aircraft has 

four rotors and four motors in a quadcopter configuration (X4). It is only capable of 

vertical takeoff and landing. This UAS weighs less than 55 lbs. including payload. Can fly, 

under normal conditions at a speed of no more than 42.8 knots and has the capability to 

hover, and move in the vertical and horizontal plane simultaneously. This UAS is equipped 

with GPS and auto-return function to the predetermined safe landing area as well as 

allowing reading of magnetic interference that can cause loss of GPS signal. The UAS will 

operate only in visual line of sight and will operate only within a sterile closed-set area of a 

residential or commercial listing, open desolate areas near rural farms or a closed-set 

special event. Such operations will insure that the UAS will “not create a hazard to users of 

the national airspace system or the public.” (Reform Act Section 333 (b)). 

The DJI Inspire 1 will be operated by ABS Aerial Imaging Service and 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, ABS Aerial Imaging Service, 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 
6

petitions the Administrator to commercially operate the DJI Inspire 1 in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

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

with the unmanned aircraft and its operation, ABS Aerial Imaging Service’s operation of 

DJI Inspire 1 meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, ABS Aerial Imaging Service 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. 

ABS Aerial Imaging Service submits that the requested relief is proper since an 

equivalent level of safety will be ensured. ABS Aerial Imaging Service will perform 

maintenance, alterations, and/or preventive maintenance on the DJI Inspire 1 using the 

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

Maintenance Log and DJI Inspire 1 Instruction Manuals). Furthermore, ABS Aerial 

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

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

privileges and limitations: Pilot in command, is requested by ABS Aerial Imaging Service 

to the extent necessary to allow the proposed UAS flight operations to be conducted by a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, and who has 

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

is able to safely operate the DJI Inspire 1 in a manner consistent with this exemption, 
7

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

ABS Aerial Imaging Service seeks relief from Section 91.7(a), entitled Civil 

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

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, ABS Aerial Imaging 

Service submits that we will ensure that the DJI Inspire 1 is in an airworthy condition, 

prior to every flight, by determining that it is in compliance with the operating documents 

(i.e., Aircraft Maintenance Log and DJI Inspire 1 Instruction Manuals), and that the aircraft 

is in a condition for safe flight. 

ABS Aerial Imaging Service also seeks an exemption from the requirements of 

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

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

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

communications telemetry data link, which downlinks from the DJI Inspire 1 to the GCS 

for active monitoring of the flight path. The maximum altitude of the DJI Inspire 1 is 

factory limited to 400 feet AGL by onboard software. This altitude information, combined 

with ABS Aerial Imaging Service’s operation of the DJI Inspire 1 will be within visual line 

of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, ABS Aerial Imaging Service seeks an exemption from the 

requirements of Section 91.151(a), entitled Fuel requirements for flight in VFR conditions. 

ABS Aerial Imaging Service submits that safety will not be affected by operation of the 

DJI Inspire 1 during daylight hours in visual meteorological conditions (VMC) under 
8

visual flight rules (VFR), with enough battery power to fly for a total duration of 13 

minutes to the first point of intended landing and, assuming a normal cruising speed, to fly 

after that for at least 5 minutes (i.e. 20 percent battery power remaining). 

In accordance with 14 C.F.R. § 11.81, ABS Aerial Imaging Service 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: 

Peter Scott Myers, Owner 

ABS Aerial Imaging Service 

4322 Long Lane 

Franklin, TN 37064 

(615) 504-7676 Cell/Office 

Email:scottm@abssite.com 

B. The Specific Sections Of 14 C.F.R. From Which ABS Aerial Imaging Service Seeks 

Exemption. 

1. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

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

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

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

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

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

connection with any business or employment if— 

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

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

2. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of 

Section 91.7(a).
9

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. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of 

Section 91.121. 

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

part: 

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

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

when operating-- 

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

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of 

Section 91.151(b).

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

 (b), states the following: 

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

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

5. ABS Aerial Imaging Service Seeks Exemption From The Requirement Of 

Section 91.405(a).
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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. ABS Aerial Imaging Service 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. ABS Aerial Imaging Service Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. ABS Aerial Imaging Service 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: 
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(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include-- 

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 
12

(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 ABS Aerial Imaging Service Seeks And The Reason ABS 

Aerial Imaging Service Seeks The Relief. 

1. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS 

Aerial Imaging Service Seeks Relief From Section 61.113(a) And (b). 

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

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

private pilot or higher level certificate, as well as a current and valid drivers license, and 

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

flight operations for compensation or hire. 

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

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

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

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

compensation or hire. 

As set forth more fully below, ABS Aerial Imaging Service submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the 

DJI Inspire 1 unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate DJI Inspire 1 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. 
13

2. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS 

Aerial Imaging Service Welsh 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 ABS Aerial Imaging Service to determine that the DJI Inspire 1 is 

in airworthy condition prior to every flight by ensuring that the DJI Inspire 1 is in 

compliance with the operating documents (i.e., Aircraft Maintenance Log and DJI Inspire 

1 Instruction Manual). 

ABS Aerial Imaging Service seeks the requested relief because the DJI Inspire 1 

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

H. Therefore, ABS Aerial Imaging Service will ensure that the DJI Inspire 1 is in 

airworthy condition based upon its compliance with the operating documents (i.e., Aircraft 

Maintenance Log and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

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

limitations below.

3. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS 

Aerial Imaging Service 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, 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), ABS Aerial Imaging Service seeks the 

requested relief because the DJI Inspire 1 altimeter may be set on the ground to zero feet 

AGL, rather than the local barometric pressure or field altitude, before each flight. 
14

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 is equipped with a barometric pressure sensor and 

GPS equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA 

on the touchscreen of the GCS or is limited by onboard software. 

4. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS 

Aerial Imaging Service 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 during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 13 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 5 minutes. ABS Aerial 

Imaging Service seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Inspire 1 will severely 

constrain the practicality of any aerial video or still photo flight operations ABS Aerial 

Imaging Service proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 

operating documents, and ABS Aerial Imaging Service’s proposed operating limitations, 

ensure that ABS Aerial Imaging Service will safely operate the battery powered DJI 

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

flight rules (VFR), with enough battery power to fly for a total duration of 13 minutes to 
15

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

at least 5 minutes.

5. Extent Of Relief ABS Aerial Imaging Service Seeks And The Reason ABS 

Aerial Imaging Service Seeks Relief From Sections 91.405(a), 91.407(a)(1),

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

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, ABS Aerial Imaging Service 

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

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

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Peter Scott Myers, owner of ABS Aerial Imaging Service, will use his 

experience working on operating model aircraft to perform maintenance, alterations, or 

preventive maintenance on the DJI Inspire 1 using the methods, techniques, and practices 

prescribed in the operating documents (i.e Aircraft Maintenance Log and DJI Inspire 1 

Instruction Manuals). Furthermore, ABS Aerial Imaging Service will document and 

maintain all maintenance records for the DJI Inspire 1. 

D. The Reasons Why Granting ABS Aerial Imaging Service 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 ABS

Aerial Imaging Service to safely, efficiently, and economically perform aerial video and 

photography within the National Airspace System. 

Additionally, use of DJI Inspire 1 will decrease congestion of the NAS, reduce 

pollution through use of electric propulsion, and provide significant benefits to the 

economy. Notably, the benefits of ABS Aerial Imaging Service’s proposed operation of 

the DJI Inspire 1 will be realized without implicating any privacy issues. 
16

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

The DJI Inspire 1 is 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 the DJI Inspire 1 would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and 

property in the air and on the ground. 

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

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

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

manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The 

DJI Inspire 1. 

Conducting aerial acquisitions with the DJI Inspire 1 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 produces no air pollution, and is the 

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

combustion engine aircraft that are typically utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI 

Inspire 1 while reducing the carbon footprint of aerial acquisitions, also eliminates noise 
17

pollution, as the UAs are propelled by battery powered electric motors, rather than an 

internal combustion engine. 

By using the DJI Inspire 1 to perform aerial video and photo acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of flight crew members located onboard the 

aircraft, the DJI Inspire 1 (weighing approximately 6.25lbs at maximum gross weight, with 

length of 29 inches and width of 29 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared 

to the manned aircraft that typically conduct similar operations (weighing approximately 

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

capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Inspire 1 Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Inspire 1 is also an economical 

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

of the DJI Inspire 1 will allow United States based companies or individuals, like ABS 

Aerial Imaging Service, 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 is one such technology 

that not only allows companies or individuals greater operational flexibility compared to 
18

manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the DJI Inspire 1, companies such as ABS Aerial Imaging Service 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, 

provides a stable workforce that increases consumer spending; improves local, state, and 

federal tax revenues; and allows companies to invest in research and development in order 

to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

decades, ABS Aerial Imaging Service’s proposed operation of the DJI Inspire 1 will not 

implicate any privacy issues. Specifically, the DJI Inspire 1 will be operated only in 

compliance with operating documents including the DJI Inspire 1 Instruction Manual, 

Limitations imposed by the Grant of Exemption and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119 

(sections as applicable). 

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 ABS Aerial Imaging Service Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 Meets The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, ABS Aerial Imaging Service’s operation of 
19

the DJI Inspire 1 meets the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, ABS Aerial Imaging Service submits that DJI Inspire 1 

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

characteristics of the DJI Inspire 1 (b) the pilot certification requirement by the owner, 

Peter Scott Myers; and (c) the specific operating limitations. 
20

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

Characteristics. 

The DJI Inspire 1 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 DJI Inspire 1. 

The technical specifications of the DJI Inspire 1 is set forth by the DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Appendix A.

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

The UASs To Remain Within A Defined Operational Area. 

The DJI Inspire 1 may be operated in both manual and autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI is provided in the 

instruction manual – Appendix B 

iii. The DJI Inspire 1 is Designed For Automatic Return To Home Point 

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

Navigation. 

When the Control Link is lost, the DJI Inspire 1 will remain stable in flight and 

initiate a controlled return flight to the point of original departure. This is known as the 

“Return to Home” feature. Upon arrival at the “Home Point” the UA(s) will begin a 

controlled descent and landing. Additional protections are integrated into this safety 

feature to help mitigate any potential contingencies that may happen during this automated 

flight. Furthermore, the “Return to Home” safety feature may be activated at any time the 

PIC becomes disoriented or loses visual contact with the UA. This serves as an additional 

feature to assure safe and controlled operation of the UA at all times. A complete 

description of the “Return to Home” Function of the DJI Inspire 1 is in the instruction 

manual, Appendix B.
21

iv. The DJI Inspire 1 GCSs and its operation. 

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

contained in the Instruction Manual, attached hereto as Appendix B. The DJI Inspire 1 is 

compliant with all Federal Communications Commission (FCC) requirements, and the 

radio frequency spectrum used for operation and control of the DJI Inspire 1 is in the 

Instruction manual, attached hereto as Appendix B. 

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

Certificated Pilot in Command With A Safety Observer. 

ABS Aerial Imaging Service will only utilize certificated pilots, who possess a 

current and valid driver’s license, to act as a pilot in command (PIC) of the DJI Inspire 1. 

Additionally, a Safety Observer will assist the PIC during flight time. 

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

Operating Limitations. 

In seeking this exemption, ABS Aerial Imaging Service proposes to commercially 

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

photography within the National Airspace System, pursuant to the following specific 

operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft 

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

a petition to amend this grant. 

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

for the purpose of aerial video and photography. 

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

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

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

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

reported to ATC must be in feet AGL. 
22

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. 

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

permitted for navigation. 

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

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

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

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

designated before the flight and cannot transfer his or her designation for the 

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

functions prescribed in the operating documents. 

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

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

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

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

discrepancy exists between the conditions and limitations contained in the grant 

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

conditions and limitations contained in the grant of exemption take precedence 

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

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

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

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

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

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

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

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

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

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

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

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

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

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

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

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

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

functional test flight must make an entry in the aircraft records. 
23

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

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

relevant sections of the operating documents. 

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

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

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

requirements, in accordance with the operating documents. Maintenance, 

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

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

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

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

driver’s license. 

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

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

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

exemption, including evasive and emergency maneuvers and maintaining 

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

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

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

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

only be conducted during dedicated training sessions. During training, 

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

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

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

91.119. 

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

1.1. All operations must be conducted under visual meteorological conditions 

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

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

rules (SVFR) are not authorized. 

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

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

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

conducted in accordance with a NOTAM as required by the operator’s COA. 
24

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

the Administrator upon request. 

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

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

PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising 

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

remaining. 

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

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

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

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

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

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

altitude level and potential transponder requirements. 

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

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

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

Subpart C. Markings must be as large as practicable. 

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

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

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

operations and activities at all times. 

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

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

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

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

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

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

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

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

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

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

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

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

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

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

hours. Accidents must be reported to the National Transportation Safety Board 

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

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

And (b) Would Not Adversely Affect Safety. 

ABS Aerial Imaging Service submits that the equivalent level of safety established 

by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

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

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

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 
26

Considering ABS Aerial Imaging Service’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the DJI Inspire 1, ABS Aerial 

Imaging Service submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

ABS Aerial Imaging Service’s specific proposed flight operations. 

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

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

ABS Aerial Imaging Service will not allow any PIC to operate the DJI Inspire 1 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements of the 

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

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

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

structures. 

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

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

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

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

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

purposes). 
27

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

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

equivalent level of safety during ABS Aerial Imaging Service’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

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

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

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

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

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

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

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

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

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

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

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

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, ABS Aerial Imaging Service will ensure safe operations by not 

allowing any PIC to operate the DJI Inspire 1 unless that PIC has demonstrated, by 

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

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

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 
28

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, ABS Aerial Imaging Service will ensure that the DJI Inspire 

1 is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

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

Would Not Adversely Affect Safety. 

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

because the altitude information of the DJI Inspire 1 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 software limiting of maximum altitude (400’ AGL) and ABS Aerial 

Imaging Service’s operation of the DJI Inspire 1 within visual line of sight, at or below 400 

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed onboard the aircraft. Prior to 

each flight, a zero altitude initiation point is automatically established by the UASs 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 
29

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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

Would Not Adversely Affect Safety. 

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

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

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

flight operations. Accordingly, ABS Aerial Imaging Service will ensure that it will safely 

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

enough battery power to fly for a total duration of 13 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

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

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 will provide audible, 

tactile and visual warnings to the PIC at the GCS when the UAs experiences low battery 

voltage, the first warning occurring at approximately 20% remaining battery power, and 

again at approximately 10% remaining battery power. At the critically low battery level, 

the DJI Inspire 1 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 
30

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, ABS Aerial Imaging Service 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 Peter Scott Myers, owner of ABS Aerial Imaging Service, will use his 

experience operating model aircraft to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Aircraft Maintenance Log and DJI Inspire 1 Instruction 

Manual). Furthermore, ABS Aerial Imaging Service will document and maintain all 

maintenance records for the DJI Inspire 1. 

Since the DJI Inspire 1 will be inspected as prescribed by the operating documents, 

ABS Aerial Imaging Service will maintain the equivalent level of safety established by 

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

Manual is attached hereto as Appendix B; a copy of the DJI Inspire 1 aircraft Maintenance 

log is attached hereto as Appendix C. 

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 will be performed by ABS Aerial Imaging Service. Maintenance will be 

documented and maintained utilizing the Aircraft Maintenance log. 
31

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of ABS Aerial Imaging Service’s proposed operating limitations, 

the operating documents, and the technical aspects of the DJI Inspire 1, ABS Aerial 

Imaging Service 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, ABS Aerial Imaging Service 

requests that the FAA prescribe special conditions for the intended operation of the DJI 

Inspire 1, 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 

within the National Airspace System for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 
32

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the DJI Inspire 1, since the airworthiness regulations of 14 C.F.R. 

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

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

propeller, he prescribes special conditions and amendments thereto for the product. 

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

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

FAA finds necessary 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 ABS Aerial Imaging Service’s intended operation of 

the DJI Inspire 1, 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). 

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

From Which ABS Aerial Imaging Service Seeks Exemption: 
33

ABS Aerial Imaging Service 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 ABS Aerial Imaging 

Service Seeks: 

This exemption will permit ABS Aerial Imaging Service to commercially operate an 

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

photography within the National Airspace System (NAS). 

 

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

Aerial Imaging Service’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, ABS Aerial Imaging Service’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, ABS Aerial Imaging Service will operate the DJI 

Inspire 1 safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, ABS Aerial Imaging Service 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 commercially, without an 

35

Appendices: 

A – DJI Inspire 1, Specifications Data Sheet 

B – DJI Inspire 1, Manufacturer’s Instruction Manual 

C – Aircraft (UA) Maintenance Log 

 
36

APPENDIX – A 

DJI Inspire 1 TECHNICAL SPECIFICATIONS 

ABS Aerial Imaging Service only utilizes safe and reliable UASs. DJI is an industry leader 

in small UAS production. The DJI Inspire 1 is loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set altitude 

as well as limit flight to a predetermined and set distance. In addition, DJI software 

provides real-time altitude and location information to the PIC via the integrated touch 

screen monitor. 

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model – T600 

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

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

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

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

RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

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

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

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X3 

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

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

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable 

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

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

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 

2.2.3.1 Name – X3 

2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 
37

2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

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

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

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

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

2.2.4 Transmitter 

2.2.4.1 Name – C1 

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

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

2.2.4.6 Battery – 600mAh LiPo 2S