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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PIXAIR PRODUCTIONS LLC

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(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF 

INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on 23 January 2016

Brian Bills

Pixair Productions LLC

542 W 1700 S

Orem, Utah 84058

Phone: (801) 810-7876

brian@pixairpro.com
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TABLE OF CONTENTS

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

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

INTRODUCTION AND INTERESTS OF THE PETITIONER.................................................... 5

BACKGROUND ............................................................................................................................ 6

BASIS FOR PETITION ................................................................................................................. 7

A. Name And Address Of The Petitioner...................................................................................... 8

B. The Specific Sections Of 14 C.F.R. From Which Pixair Productions Seeks Exemption......... 8

C. The Extent Of Relief Pixair Productions Seeks And The Reason Pixair Productions Seeks 

The Relief................................................................................................................................ 13

D. The Reasons Why Granting Pixair Productions Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole........................................................ 16

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 Pixair Productions Seeks Exemption. ....................................................... 18

CONCLUSION............................................................................................................................. 33
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UA Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Pixair Productions 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 Pixair Productions to operate an Unmanned Aircraft System (UA) for the commercial purpose of conducting aerial video and photography over certain areas of the United States.
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INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Brian Bills. I am the owner of Pixair Productions. I manage the aerial video 

services for Pixair Productions and lead a team of creative people who excel in providing various 

video services for customers all over the world. We have been providing aerial video services 

since 2010. Over the last several years the technology has rapidly evolved allowing many entrants into the market. We maintain the position that our dozens of years of combined experience will allow us to not only operate in a safe manner but also give us a competitive advantage 

in the market space.

To provide efficient and cost effective solutions as well as unique ideas for products, events, 

etc... we have transitioned from a custom piece of hardware to one that is commercially available (DJI Inspire).

The objective for my petition is to provide high quality video and images for the following:

 Tourism

 Commercial Real Estate

 Cinematic Productions

 Sports

 Events

 Survey/mapping
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BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UA

Pixair Productions seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) 

with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI 

Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 

17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI 

Inspire 1 UA is equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors. The DJI Inspire 1 UA that will be operated by Pixair Productions, 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.
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BASIS FOR PETITION

Petitioner, Pixair Productions, pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Inspire 1 UA in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(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, Pixair Productions will show that operation of the DJI Inspire 1 UA 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, Pixair Productions 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.

Pixair Productions submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Pixair Productions will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UA using the methods, techniques, and practices prescribed in the operating documents (i.e., DJI Inspire 1 Instruction and 

Maintenance Manuals). 

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

and limitations: Pilot in command, is requested by Pixair Productions to the extent necessary to 

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an 

airman medical 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 UA in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Pixair Productions seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1 UA do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Pixair Productions submits that they will ensure that the DJI 
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Inspire 1 UA is in an airworthy condition, prior to every flight, by determining that the UA are in 

compliance with the operating documents (i.e., DJI Inspire 1 Instruction Manuals), and that the 

aircraft are in a condition safe for flight.

Pixair Productions also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1 UA will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Inspire 1 UA will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Pixair Productions operation of the DJI Inspire 1 UA within visual line of 

sight, at or below 500 feet AGL, will ensure an appropriate level of safety equivalent to Section 

91.121.

Additionally, Pixair Productions seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Pixair Productions submits 

that safety will not be affected by operation of the DJI Inspire 1 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power 

to fly for a total duration of approximately 13.5 minutes to the first point of intended landing 

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

In accordance with 14 C.F.R. § 11.81, Pixair Productions 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: 

Pixair Productions

542 W 1700 S

Orem, Utah 84058

Attn: Brian Bills

Phone: (801) 310-6176

Email: brian@pixairpro.com

B. The Specific Sections Of 14 C.F.R. From Which Pixair Productions Seeks Exemption.
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1. Pixair Productions 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. Pixair Productions Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

a. No person may operate a civil aircraft unless it is in an airworthy condition.
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3. Pixair Productions 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. Pixair Productions Seeks Exemption From The Requirements Of Section 91.151(b).

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

a. 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. Pixair Productions Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—
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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. Pixair Productions 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. Pixair Productions 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. Pixair Productions 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:
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a. Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

1) Records of the maintenance, preventive maintenance, and alteration and records 

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

as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include--

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

work performed; and

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

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

return to service.

2) Records containing the following information:

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

rotor.

ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

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

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

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.
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vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances.

b. The owner or operator shall retain the following records for the periods prescribed:

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

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

2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved 

for return to service.

C. The Extent Of Relief Pixair Productions Seeks And The Reason Pixair Productions 

Seeks The Relief.

1. Extent Of Relief Pixair Productions Seeks And The Reason Pixair Productions 

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 airman medical certificate, 

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

UA 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, Pixair Productions submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UA unless that 

PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 
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safely operate either the DJI Inspire 1 UA in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as 

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

Further, Pixair Productions submits that all flights of the DJI Inspire 1 UA, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to Pixair Productions business; 

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Pixair Productions Seeks And The Reason Pixair Productions 

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 Pixair Productions to determine that the DJI Inspire 1 UA are in airworthy condition prior to every flight by ensuring that the UA is in compliance with the operating documents 

(i.e., DJI Inspire 1 Instruction Manuals).

Pixair Productions seeks the requested relief because the DJI Inspire 1 UA do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Pixair Productions will ensure that the DJI Inspire 1 UA are in airworthy condition based upon its compliance with the operating documents (i.e., DJI Inspire 1 Instruction Manuals) 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 Pixair Productions Seeks And The Reason Pixair Productions 

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 UA, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UA operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Pixair Productions seeks the requested relief because the DJI Inspire 1 UA’s altimeter 

may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.
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Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Pixair Productions Seeks And The Reason Pixair Productions 

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 UA during 

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

total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Pixair Productions seeks the requested relief 

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

powered DJI Inspire 1 UA will severely constrain the practicality of any aerial video or still photo flight operations that Pixair Productions proposes to conduct pursuant to this Petition.

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

Inspire 1 operating documents, and Pixair Productions’ proposed operating limitations, ensure 

that Pixair Productions will safely operate the battery powered DJI Inspire 1 UA during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough 

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

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

5. Extent Of Relief Pixair Productions Seeks And The Reason Pixair Productions 

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, Pixair Productions requests relief from these Sections because the DJI Inspire 1 UA do not require airworthiness certificates. As set forth more 

fully below, the DJI Inspire 1 UA meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Pixair Productions will use trained technicians to 
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perform maintenance, alterations, or preventive maintenance on the UA using the methods, techniques, and practices prescribed in the UA operating documents (i.e., DJI Inspire 1 Instruction 

and Maintenance Manuals). Furthermore, Pixair Productions will document and maintain all

maintenance records for the DJI Inspire 1 UA.

D. The Reasons Why Granting Pixair Productions 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 Pixair Productions to 

safely, efficiently, and economically perform aerial video and photography for tourism, commercial real estate, mapping/surveying, sports, and events over certain areas of the United States.

Additionally, use of the DJI Inspire 1 UA will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Pixair Productions’ proposed operation of the DJI Inspire 1 UA will be realized without implicating any privacy issues.

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

The DJI Inspire 1 UA are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of a DJI Inspire 1 UA would reduce the amount of manned aircraft in the NAS, reduce noise and 

air pollution, as well as increase the safety of life and property in the air and on the ground.

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA

do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting 

aerial video and photography missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

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

Conducting aerial acquisitions with the DJI Inspire 1 UA, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power 
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and electric motors, the DJI Inspire 1 UA produce 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 UA, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UA to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing approximately

2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with 

lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, 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 UA

Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UA are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI 

Inspire 1 UA will allow United States based companies, like Pixair Productions, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UA is 

one such technology that not only allows companies greater operational flexibility compared to 

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

manned aircraft.

By operating the DJI Inspire 1 UA, companies such as Pixair Productions, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, 
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which will ultimately contribute to growth of the U.S. economy. Improved financial performance 

of U.S. companies, through commercial use of the DJI Inspire 1 UA, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies to 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, Pixair Productions’s proposed operation of the DJI Inspire 1 UA will not implicate any privacy issues. Specifically, the DJI Inspire 1 UA will be operated only in compliance with operating documents (i.e., DJI Inspire 1 Instruction Manuals) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal 

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

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Pixair Productions Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, Pixair Productions’s operation of the DJI Inspire 1 UA meet 

the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UA to operate without airworthiness certification and 

sets forth requirements for considering whether a UA 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 na-
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tional 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, Pixair Productions submits that the DJI Inspire 1 UA can operate 

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

the DJI Inspire 1 UA; (b) the pilot certification requirement; and (c) the specific operating limitations.

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

The DJI Inspire 1 UA do not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering its size, weight, speed, and operational capability.

i) Technical Specifications Of The DJI Inspire 1 UA.

The technical specifications of the DJI Inspire 1 UA are set forth by the DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A.

ii) The DJI Inspire 1 UA Autonomous Flight And Navigation Modes Enable 

The UA To Remain Within A Defined Operational Area.
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The DJI Inspire 1 UA may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI Inspire 1 UA is provided at 

pages 12-18 and 44-51 of the DJI Inspire 1 User Manual, attached hereto as Exhibit C.

iii) The DJI Inspire 1 UA Are Designed For Automatic Return To Home 

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

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in flight, for 3 

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

the GCS, the UA will assume that the Control Link is lost and the UA will return to the home 

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

A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 12-17 of the 

DJI Inspire 1 User Manuals, attached hereto as Exhibit C.

iv) The DJI Inspire 1 GCS And Its Operation.

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

flight control software is provided at pages 39 through 44 of the DJI Inspire 1 User Manual. DJI 

Inspire 1 User Manual is attached hereto as Exhibits C.

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

Certificated Pilot in Command With A Safety Observer.

Pixair Productions will only utilize certificated pilots who possess a current and valid Airman 

Medical Certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UA. Additionally, a 

safety observer (SO) will assist all pilots during flight time.

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

Limitations.

In seeking this exemption, Pixair Productions proposes to commercially operate DJI Inspire 1

UA for the special purpose of conducting aerial video and photography over certain areas of 

United States, pursuant to the following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UA weighing less than 55 
21

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) UA operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography.

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

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

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

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

ATC must be in feet AGL.

5) The 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.

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

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

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

SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

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

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

not permitted to operate the camera or other instruments.

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

UA operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of 
22

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 UA 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 UA to ensure that it is in a condition 

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

of the UA, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UA 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 UA that has undergone maintenance or alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight critical component, must 

undergo a functional test flight. The PIC who conducts the functional test flight 

must make an entry in the aircraft records.

12) The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13) The operator must follow the UA 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 not-
23

ed in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UA to service.

15) Each UA 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 thirdclass medical certificate.

18) The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UA in 

a manner consistent with how the UA 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) UA 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 
24

in accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator upon request.

21) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

accordance with the operating documents.

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

in accordance with the operating documents.

24) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining.

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

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

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

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

prior to the operation. All operations shall be conducted in accordance with airspace 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 UA any time the UA is operating. 
25

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 UA may not be operated by the PIC from any moving device or vehicle.

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

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

vessels, vehicles, and structures unless:

i) 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;

ii) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and;

iii) 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 UA 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.
26

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

Would Not Adversely Affect Safety.

Pixair Productions 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

UA 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 UA in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.

Considering Pixair Productions’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 UA, Pixair Productions submits that the additional 

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

airmanship skills necessary for Pixair Productions’s specific proposed flight operations.

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

Pixair Productions will not allow any PIC to operate the DJI Inspire 1 UA unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 UA training 

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

appropriate distances from people, vessels, vehicles and structures.

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 UA rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UA pilot operating the same make and model of UA 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 Pixair Productions’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 UA rotorcraft pilot including at least 10 hours logged as a UA

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

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

operating the same make and model of UA 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 UA 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, Pixair Productions will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UA 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 UA in a manner 
28

consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

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, Pixair Productions will ensure that the DJI Inspire 1 UA is in an airworthy condition based upon the UA’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 UA, 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 UA will be provided to the PIC via GPS equipment and 

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

monitoring of the flight path and altitude. This altitude information, combined with Pixair Productions’s operation of the DJI Inspire 1 UA within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. 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 UA at ground level.

The FAA has previously granted relief from Section 91.121 specific to UA, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161).

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

Not Adversely Affect Safety.
29

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 UA; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Pixair Productions will ensure that it will safely operate the battery powered 

DJI Inspire 1 UA during daylight hours in VFR conditions, with enough battery power to fly for 

a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

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

limitations on the proposed flight operations; and the location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, 

safety will be ensured as the DJI Inspire 1 UA provide audible and visual warnings to the PIC at 

the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. 

At the critically low battery level, the DJI Inspire 1 UA 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 UA are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UA, 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, Pixair Productions 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 Pixair 

Productions will use trained technicians to perform maintenance, alterations, or preventive 
30

maintenance on the UA using the methods, techniques, and practices prescribed in the operating 

documents (i.e., DJI Inspire 1 Instruction and Maintenance Manuals).

Since the DJI Inspire 1 UA will be inspected as prescribed by the operating documents, Pixair Productions will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 User Manuals is attached hereto as 

Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Pixair Productions

will use trained technicians to perform maintenance, alterations or preventive maintenance on the 

UA using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established 

by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UA

will be performed by trained technicians. A copy of the DJI Inspire 1 Maintenance Manual is 

attached hereto as Exhibit B. 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 UA

are considered.

In consideration of Pixair Productions’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UA, Pixair Productions 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 UA 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, Pixair Productions requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UA, which contain such 

safety standards that the Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 
31

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 UA for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. 

FMRA Section 333 sets forth the requirements for considering whether a UA 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 UA to operate without airworthiness certification in accordance 

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

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, 

for operation of the DJI Inspire 1 UA, since the airworthiness regulations of 14 C.F.R. Part 21 do 

not contain adequate or appropriate safety standards, due to the novel or unusual design features 

of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or 

propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 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 Pixair Productions’s intended operation of the DJI Inspire 1 UA, 

which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

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

91.417(a) & (b).

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

From Which Pixair Productions Seeks Exemption:

Pixair Productions seeks exemption from the requirements of 14 C.F.R Sections 
32

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 Pixair Productions Seeks:

This exemption will permit Pixair Productions to commercially operate an Unmanned 

Aircraft System (UA) for the purpose of conducting aerial video and photography over 

certain areas of the United States.

1. Any Additional Information, Views, Or Arguments Available To Support Pixair 

Productions’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 UA may operate safely in the NAS. As such, Pixair Productions’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 UA 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 UA to operate without airworthiness certification.

As discussed in detail above, Pixair Productions will operate the DJI Inspire 1 UA safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat 

to national security.
33

CONCLUSION

As set forth herein, Pixair Productions 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 UA commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Pixair Productions to safely, efficiently, and economically operate the DJI Inspire 1 UA commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Pixair Productions respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

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

91.417(a) & (b), and permit Pixair Productions to operate the DJI Inspire 1 UA commercially for 

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

Dated: 23 January 2016

Thank you,

Brian Bills

Pixair Productions

542 W 1700 S

Orem, UT 84058

Phone: (801) 810-7876

brian@pixairpro.com
34

EXHIBITS

EXHIBIT A DJI Inspire 1 Specs

EXHIBIT B DJI Inspire 1 Maintenance Manual

EXHIBIT C DJI Inspire 1 User Manual

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en

_v2.0_1218.pdf