UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

INTERIOR PIXELS, INC.

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 DJI PHANTOM 2 AND 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 May 26, 2015

Brendan Carlisle

Interior Pixels, Inc.

5640 Via Bonita

Newbury Park, CA 91320

Tel: (818) 427-9863

TABLE OF CONTENTS
GLOSSARY OF ABBREVIATIONS...................................................................................3

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

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

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

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

NAME AND ADDRESS OF PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH INTERIOR PIXELS SEEKS 

EXEMPTION.................................................................8

THE EXTENT OF RELIEF INTERIOR PIXELS SEEKS AND THE

REASON INTERIOR PIXELS SEEKS THE RELIEF.........................11

THE REASONS WHY GRANTING INTERIOR PIXEL’S REQUEST

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT INTERIOR PIXEL’S REQUEST.........34

CONCLUSION....................................................................................................................35

APPENDICES........................................................................................37

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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle
CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

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SUMMARY

Interior Pixels 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
Interior Pixels to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial real estate and landscape video and photography for the 

purpose of producing real estate videos and commercials.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Interior Pixels provides its clients with expertise and knowledge in various aspects of aerial video and 

photography. The objective of Interior Pixel’s aerial video and photography operations is to

provide low cost, high quality imaging for a variety of commercial and residential

customers.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, DJI Inspire 1 UASs

Interior Pixels seeks an exemption to operate DJI systems for

compensation or hire within the NAS. The DJI Phantom 2 and DJI Inspire 1 are

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2

has a maximum gross weight of approximately 2 pounds 11 ounces, while having

a length of 16 inches, width of 16 inches, height of 8 inches, and a maximum speed of

5

approximately 29 knots. 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 Phantom 2 and DJI Inspire

1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered

electric motors.

The DJI Phantom 2 and DJI Inspire 1 UAs that will be operated by

Interior Pixels 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, Interior Pixels, 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 Phantom 2, DJI

Inspire 1 UASs 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, Interior Pixels’s operation of DJI

Phantom 2 and DJI Inspire 1 UASs 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.

6

Accordingly, Interior Pixels 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.

Interior Pixels submits that the requested relief is proper since an

equivalent level of safety will be ensured. Interior Pixels will use experienced

personnel or technicians to perform maintenance, alterations, or preventive maintenance on

the UASs using the methods, techniques, and practices prescribed in the operating

documents (i.e., the Interior Pixels Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual).

Furthermore, Interior Pixels will document and maintain all maintenance records
for the DJI Phantom 2 and DJI Inspire 1 UASs.

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

privileges and limitations: Pilot in command, is requested by Interior Pixels 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 Phantom 2 and DJI Inspire 1 UASs in a manner consistent with

this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Interior Pixels seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 2 and DJI Inspire 1 UASs do not require

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

Interior Pixels submits that it will ensure that the DJI Phantom 2 and

7

DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that

the UASs are in compliance with the operating documents (i.e., the Interior Pixels Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual), 

and that the aircraft are in a condition for safe flight.

Interior Pixels also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 2 and DJI Inspire 1 UAs

will not have a typical barometric altimeter onboard. However, altitude information of the

DJI Phantom 2 and DJI Inspire 1UAs 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 Interior Pixel’s operation of the DJI Phantom 2
and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will

ensure a level of safety equivalent to Section 91.121.

Additionally, Interior Pixels seeks an exemption from the requirements

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions Interior Pixels

submits that safety will not be affected by operation of the DJI Phantom 2

and DJI Inspire 1 UAs 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.

8

In accordance with 14 C.F.R. § 11.81, Interior Pixels 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:

Brendan Carlisle

Interior Pixels, Inc.

5640 Via Bonita

Newbury Park CA 91320

Tel: (818) 427-9863

Email: bcarlisle@interiorpixels.com

B. The Specific Sections Of 14 C.F.R. From Which Interior Pixels Seeks

Exemption.

 1. Interior Pixels 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. Interior Pixels 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.

9

 3. Interior Pixels 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. Interior Pixels 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. Interior Pixels Seeks Exemption From The Requirement Of

Section 91.405(a).

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

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

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 6. Interior Pixels 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. Interior Pixels 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. Interior Pixels Seeks Exemption From The Requirements Of

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

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

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

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

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

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(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.

(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.

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C. The Extent Of Relief Interior Pixels Seeks And The Reason Interior Pixels

Seeks The Relief.

1. Extent Of Relief Interior Pixels Seeks And The Reason Interior Pixels

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 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, Interior Pixels submits that an equivalent

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

Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight-hour

and currency requirements, demonstrating that the PIC is able to safely operate either the

DJI Phantom 2 or DJI Inspire 1 UAS 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, Interior Pixels submits that all flights of the DJI Phantom 2

and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this

13

Petition: (1) will be incidental to Interior Pixel’s business; and (2) will not carry

passengers or property for compensation or hire.

2. Extent Of Relief Interior Pixels Seeks And The Reason Interior Pixels

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 Interior Pixels to determine that the DJI Phantom 2

and DJI Inspire 1 UASs are in airworthy condition prior to every flight by

ensuring that the UAS is in compliance with the operating documents (i.e., the Interior Pixels 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2

and DJI Inspire 1 Instruction Manual).

Interior Pixels seeks the requested relief because the DJI Phantom 2

and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. Therefore, Interior Pixels will ensure that the

DJI Phantom 2 and DJI Inspire 1 UASs are in airworthy condition based upon its

compliance with the operating documents (i.e., the Interior Pixels Aerial
Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 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 Interior Pixels Seeks And The Reason Interior

Pixels Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the DJI Phantom 2 and DJI Inspire 1 UASs, 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

14

be reported to air traffic control (ATC) in feet above ground level (AGL), Interior

Pixels seeks the requested relief because the DJI Phantom 2 and DJI Inspire

1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local

barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are 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 Interior Pixels Seeks And The Reason Interior

Pixels 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

Phantom 2 and DJI Inspire 1 UAs 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. Interior Pixels seeks the requested relief because without an

exemption from Section 91.151(b), the flight time duration of the battery powered DJI

Phantom 2 and DJI Inspire 1 UAs will severely constrain the practicality of any

aerial video or still photo flight operations that Interior Pixels proposes to

conduct pursuant to this Petition.

15

Significantly, as set forth below, the technical specifications of the DJI Phantom 2

and DJI Inspire 1 UASs, the DJI Phantom 2 and DJI Inspire 1 operating

documents, and Interior Pixel’s proposed operating limitations, ensure that

Interior Pixels will safely operate the battery powered DJI Phantom 2

and DJI Inspire 1 UAs 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 Interior Pixels Seeks And The Reason Interior

Pixels 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, Interior Pixels requests

relief from these Sections because the DJI Phantom 2 and DJI Inspire 1 UASs do

not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2

and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation
without an airworthiness certificate. Accordingly, Interior Pixels will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UASs

using the methods, techniques, and practices prescribed in the UAS operating documents

(i.e., the Interior Pixels Aerial Operations Manual, Monthly Maintenance Log,

and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore,

Interior Pixels will document and maintain all maintenance records for the DJI

Phantom 2 and DJI Inspire 1 UASs.

D. The Reasons Why Granting Interior Pixel’s Request Would Be In The

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

16

Granting the present Petition will further the public interest by allowing Interior

Pixels to safely, efficiently, and economically perform aerial video and photography

of real estate and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 and DJI Inspire 1 UASs will

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the

economy. Notably, the benefits of Interior Pixel’s proposed operation of the DJI

Phantom 2 and DJI Inspire 1 UASs will be realized without implicating any

privacy issues.

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

The DJI Phantom 2 and DJI Inspire 1 UAs 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 Phantom 2 or DJI

Inspire 1 UAS 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 Phantom 2 and DJI Inspire 1 UAs do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography

operations 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

Phantom 2 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 2 and DJI Inspire 1

UASs, 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

Phantom 2 and DJI Inspire 1 UASs produce no air pollution, and is the most

viably 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

Phantom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial

operations, also eliminates noise pollution, as the UAs are propelled by battery powered

electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 and DJI Inspire 1 UASs to perform aerial

operations, 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 Phantom 2 and DJI Inspire 1 UAs (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).

17

 3. Performing Aerial Video and Photography Operations With The DJI

Phantom 2 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 and DJI Inspire

1 UASs are also an economical alternative to using manned aircraft to conduct similar

aerial operations. As such, operation of the DJI Phantom 2 and DJI Inspire 1

UASs will allow United States based companies, like Interior Pixels, to remain

competitive and contribute to growth of the U.S. economy. Specifically, with the

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

Phantom 2 and DJI Inspire 1 UASs is one such technology that not only allows

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 Phantom 2 and DJI Inspire 1 UASs, companies such

as Interior Pixels, 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 Phantom 2 and DJI Inspire 1 UASs, provides a stable
work force 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.

 4. There Are No Privacy Issues.

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

decades, Interior Pixel’s proposed operation of the DJI Phantom 2 and

18

DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2

and DJI Inspire 1 UASs will be operated only in compliance with operating

documents (i.e., the Interior Pixels Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual)

which require 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 Interior Pixels Seeks Exemption.

 1. Reasons Why The DJI Phantom 2 and DJI Inspire 1 UAs 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 operations. Interior Pixel’s operation of the

DJI Phantom 2 and DJI Inspire 1 UASs meet the conditions of FMRA Section

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a 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.

19

(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.

20

In seeking this exemption, Interior Pixels submits that the DJI Phantom 2

and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section

333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 and DJI

Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The DJI Phantom 2 and DJI Inspire 1

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 and DJI Inspire 1 UASs 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 Phantom 2 and DJI

Inspire 1 UASs.

The technical specifications of the DJI Phantom 2 and DJI Inspire 1 UASs

are set forth by the DJI Phantom 2 and DJI Inspire 1 Specifications and Data

Sheet, attached hereto as Exhibit A and B.

21

ii. The DJI Phantom 2 and DJI Inspire 1 UASs Autonomous

Flight And Navigation Modes Enable The UASs To Remain Within

A Defined Operational Area.

The DJI Phantom 2 and DJI Inspire 1 UASs may be operated in both

manual and fully autonomous flight modes. A complete description of the flight and

navigational modes of the DJI Phantom 2 and DJI Inspire 1 UASs is provided at

pages 25-35 of the DJI Phantom 2 and pages 12-16 and 45-50 of the DJI Inspire 1
User Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 2 and DJI Inspire 1 UASs 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 Phantom 2 and DJI Inspire 1 UAs

will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom

2 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs

will assume that the Control Link is lost and the UAs will return to the home position (i.e.,

fail safe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2

UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15

of the DJI Phantom 2 and DJI Inspire 1 User Manuals, attached hereto as Exhibit

C and D.

iv. The DJI Phantom 2 and DJI Inspire 1 GCS And Its

Operation.

A complete description of the operation and specifications of the DJI Phantom 2

and DJI Inspire 1 GCS and flight control software is provided at pages 32 through

43 of the DJI Phantom 2 User Manual and pages 40 through 47 of the DJI Inspire

22

1 User Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached

hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 and DJI Inspire 1 UASs

Are Limited To The Line Of Sight Of A Certificated Pilot in Command

With A Safety Observer.

Interior Pixels 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 Phantom

2 and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots

during flight time.

c. Flights Of DJI Phantom 2 and DJI Inspire 1 UASs Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Interior Pixels proposes to commercially

operate DJI Phantom 2 and DJI Inspire 1 UASs 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 UASs weighing less

than 55 pounds maximum gross weight: DJI Phantom 2 and 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 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 UAs must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued airman

medical certificate.
23

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

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.

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.

24

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

third- class 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 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.

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

the Administrator upon request.

25

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.

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:

26

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 aircraft is operated near vessels, vehicles or structures where the

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

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

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

an undue hazard, and;

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

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

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.

Interior Pixels 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 Phantom 2 and DJI Inspire 1 UASs unless that PIC has demonstrated, by

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

operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the

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

Considering Interior Pixel’s proposed area of operations, and the

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

27

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

11062); and the airmanship skills necessary to safely operate the DJI Phantom 2

or DJI Inspire 1 UAS, Interior Pixels submits that the additional manned

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

airmanship skills necessary for Interior Pixel’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).

Interior Pixels will not allow any PIC to operate the DJI Phantom 2

or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum

flight-hour requirements or the DJI Phantom 2 or DJI Inspire 1 UAS training and

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or

DJI Inspire 1 UAS 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).

28

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 Interior Pixel’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, Interior Pixels will ensure safe operations by not allowing

any PIC to operate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has

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

able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and

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

29

 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, Interior Pixels will ensure that the DJI Phantom 2

or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the conditions and limitations

herein.

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

to UAS, in circumstances similar, in all material respects, to those 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 Phantom 2 and DJI Inspire 1 UAs 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 Interior Pixels’s operation of

the DJI Phantom 2 and DJI Inspire 1 UAs 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 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

30

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

Phantom 2 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingly, Interior 

Pixels will ensure that it will safely operate the battery powered DJI Phantom 2

and DJI Inspire 1 UAs 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 Phantom 2

and DJI Inspire 1 UASs; 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 Phantom 2

and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the

GCS when the UAs experiences low battery voltage, the first warning occurring at

approximately 33% remaining battery power, and again at approximately 10% remaining

battery power. At the critically low battery level, the DJI Phantom and DJI Inspire

1 UASs 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

31

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief

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

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 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, Interior Pixels 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 Interior Pixels will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UASs using the methods,

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

Pixels Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2

and DJI Inspire 1 Instruction Manual). Furthermore, Interior Pixels will

document and maintain all maintenance records for the DJI Phantom 2 and DJI

Inspire 1 UASs.

Since the DJI Phantom 2 and DJI Inspire 1 UASs will be inspected as

prescribed by the operating documents, Interior Pixels 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 Phantom 2 and DJI Inspire 1 User Manuals are

attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 and DJI Inspire 1

UAS Maintenance LOG is attached hereto as Exhibit E.

32

Likewise, the exemption sought will not adversely affect safety because Interior

Pixels will use trained technicians to perform maintenance, alterations or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed by the

operating documents.

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Phantom 2 and DJI Inspire 1 UASs will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

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 Interior Pixel’s proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 2 and DJI

Inspire 1 UASs, Interior Pixels 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, Interior Pixels

33

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

Phantom 2 and DJI Inspire 1 UASs, 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 over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a

threat to national 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 Phantom 2 and DJI Inspire 1 UASs, 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.

35

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for Interior Pixel’s intended operation of the DJI

Phantom 2 and DJI Inspire 1 UASs, 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 Interior Pixels Seeks Exemption:

Interior Pixels 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 Interior

Pixels Seeks:

This exemption will permit Interior Pixels to commercially operate an

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

photography over certain areas of the United States.

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

Interior Pixel’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, Interior Pixel’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.

36

As discussed in detail above, Interior Pixels will operate the DJI Phantom

2 and DJI Inspire 1 UASs 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, Interior Pixels 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 Phantom 2 and DJI Inspire 1
UASs 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 Interior Pixels to safely, efficiently, and economically

operate the DJI Phantom 2 and DJI Inspire 1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Interior Pixels 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 Interior Pixels to operate the DJI

Phantom 2 and DJI Inspire 1 UASs commercially for the purpose of conducting

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

Dated: May 26, 2015

Respectfully submitted,

Interior Pixels, Inc.

/s/ Brendan Carlisle

_________________________

Brendan Carlisle

5640 Via Bonita

Newbury Park, CA 91320

Tel: (818) 427-9863

Appendices:

A – DJI Phantom 2 Specifications Data Sheet
B – DJI Inspire 1 Specifications Data Sheet

C – DJI Phantom 2 Manufacturer’s User Manual

D – DJI Inspire 1 Manufacturer’s User Manual

E – Monthly Maintenance Log

37

APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

Interior Pixels only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are equipped 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 to limit

flight to a predetermined and set distance. In addition, DJI software provides real-time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)

1.1 DJI Phantom 2

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal
1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

38

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

39

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Interior Pixels only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are equipped 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 to limit

flight to a predetermined and set distance. In addition, DJI software provides real-time

altitude and location information to the PIC via the linked monitor (smart phone/tablet
devices)

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

2.2.4 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

APPENDIX – C (See attachment)

DJI Phantom 2 Vision+ Manufacturer’s User Manual

42

APPENDIX – D (See attachment)

DJI Inspire 1 Manufacturer’s User Manual

43

APPENDIX – E

month:_________(year:________

UAS$#:$___________ Date(Issue(

Discovered

Date(Issue(

Addressed

Software(Updates

Airframe(
Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other:

MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted

Maintenance(Performed(By:(((

Print(&(Sign