July 31, 2015 

Attn: 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: DRONE ZONE VIDS LLC

REQUEST EXEMPTION FROM THE REQUIREMENTS OF 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.1139(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 Inspire 1 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 PUBLIC LAW 112-95 

Richard Rollins 

Chief Executive Officer 

Drone Zone Vids LLC 

17716 Fruited Plain Ln 

Edmond, Ok 73012 

dronezonevids.com

Tim Fannin 

Chief Operations Officer 

Drone Zone Vids LLC 

17717 Fruited Plain Ln 

Edmond, Ok 73012 

dronezonevids.com

Page 1 of 22
TABLE OF CONTENTS

PAGE 

GLOSSARY OF ABREVIATIONS..................................................................................................................3

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

INTRODUCTION & INTREST OF PETITIONER........................................................................................4 

CAPABILITIES............................................................................................................................................4

.

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

NAME AND ADDRESS OF PETITIONER....................................................................................................6

SPECIFIC SECTIONS OF TITLE 14 CFR FROM WHICH DRONE ZONE VIDS SEEKS EXEMPTION.....6

THE EXTENT AND REASON DRONE ZONE VIDS SEEKS RELIEF..........................................................9 

THE REASON WHY GRANTING DRONE ZONE VIDS LLC REQUEST WOULD BE IN THE PUBLIC 

INTEREST.................................................................................................................................................10 

WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.............................12

SUMMARY ...............................................................................................................................................21 

APPENDECIES..........................................................................................................................................22 

Page 2 of 22
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground level 

AMA Aeronautical Modelers Association 

AOI Area of Interest 

ATC Air Traffic Control 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulations 

GCS Ground Control Station 

GPS Global Positioning System 

IAW In Accordance With 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot in Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meterological Conditions 

VTOL Vertical Takeoff and Landing 

Page 3 of 22
SUMMARY 

Drone Zone Vids seeks exemption for the requirements of 14 CFR 61.113(a)(b), 91.7(a), 

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

operate a UAS (DJI Inspire 1) pursuant to Section 333 of the FAA Modernization and Reform Act 

of 2012 (FMRA). The exemption will permit Drone Zone Vids to operate its UAS for the 

commercial purpose of conduction aerial video and photography of residential and 

commercial real-estate, insurance investigation/survey of property, construction sites, 

inspection of roofs after damage, UAS Safety and Flight Training, and special events over 

certain areas of the United States. 

INTRODUCTION & INTEREST OF THE PETITIONER 

Drone Zone Vids is a start up company but, with over 45 years in the Aerospace Industry, 

Drone Zone Vids plans to capitalize on new technology in order to provide a new and unique 

service to its customers. 

Drone Zone Vids objective is to provide a safe and affordable alternative to high cost 

production and data collection. Utilizing the DJI’s Inspire 1 UAS we will target commercial, 

public, and residential uses such as: 

 Appraisals 

 Marketing 

 Development 

 Before and after 

 Sales 

 Special Events 

 UAS Safety and Flight Training 

My partner and I have a cumulative 45 years experience in aircraft flight, safety, and 

maintenance. We also have over 12 years experience in RC Aircraft operations and flight 

without incident and are a member of the Aeronautical Modelers Association (AMA). 

 

CAPABILITIES 

DJI’s UAS Inspire 1 will be utilized as a for hire high quality video platform providing a unique 

and cost effective service within the NAS as granted by the exemption. The Inspire 1 is a 

quad copter vertical takeoff and landing (VTOL) unmanned aircraft (UA) with a ground control 

station (GCS) utilizing electronic tablet or smart phone systems. The Inspire 1 Model T600 

specifications are: 

 Dimensions................................438x451x301mm 

 Weight .......................................6.47lbs 

 Speed.........................................25 Mph 

 Altitude.....................................500 Feet 

 Flight Time...............................25 min. 

 Battery......................................Intelligent Flight Battery 22Volts 

 Motor x 4....................................Electric Model DJI 3510 

 

The DJI Inspire 1 will be operated by Drone Zone Vids and will be registered in accordance 

with 49 USC 44103, Registration of Aircraft, and 14 CFR Part 45, Identification and 

Registration Marking. 

Page 4 of 22
BASIS FOR PETITION 

Drone Zone Vids (Petitioner) pursuant to the provisions of the Federal Aviation Regulations 

(14CFR 11.61) and FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, herby petition the Administrator to 

commercially operate the DJI Inspire1 UAS in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 CFR 61.113(a)(b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), 91.417(a)(b). 

Due to the size, weight, speed, and limited operating area of the DJI Inspire 1 and its 

associated operations, Drone Zone Vids Inspire 1 meets the condition of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 CFR Part 21, 

Subpart H. 

Drone Zone Vids request relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) 

and 91.417(a)(b), due to the fact that these regulations set forth the requirements for 

maintenance that only apply to aircraft having airworthiness certificate. 

The requested relief is proper since an equivalent level of safety will be ensured. Drone Zone 

Vids operators and maintenance personnel are highly experienced aircraft professionals 

holding commercial rating and Airframe and Power Plant ratings with 45 years of experience 

in aviation safety. Furthermore the DJI Inspire 1 will be maintained, inspected, and flown in 

accordance with (IAW) methods and practices prescribed in the operating documents and 

Inspire 1 Instruction Manual. Drone Zone Vids will maintain a flight log and maintenance log 

for the Inspire 1 UAS. 

Drone Zone Vids request relief from certain requirements of Section 61.113(a) and (b), 

entitled Private Pilot Privileges and Limitations: Pilot in Command, 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 UAS in a 

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

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

Relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, is also requested by Drone 

Zone Vids because, the Inspire 1 UAS does not require an airworthiness certificate in 

accordance with 14CFR Part 21, Subpart H. However Drone Zone Vids will ensure that the DJI 

Inspire 1 UAS is maintained and operated in an airworthy condition. This will be accomplished 

by determining that the UAS is in compliance and conforms to operating documents, (i.e., 

Flight logs, Maintenance logs, and DJI Inspire 1 Instruction Manual) thus ensuring the UAS is in 

a safe for flight condition. 

Drone Zone Vids seeks exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter on board. 

However, altitude information 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 altitude and path. This information, combined 

with Drone Zone’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 

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

Drone Zone Vids also seeks exemption from the requirements of Section 91.151(b), entitled 

Fuel Requirements for Flight in VFR Conditions. Drone Zone Vids submits that safety will not 

be affected by operation of the UAS during daylight hours in visual meteorological conditions 

Page 5 of 22
(VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 25 minutes. Battery power is actively monitored by PIC via data link and a low 

battery warning sound and illumination on tablet or smart phones provides additional level of 

safety. 

IAW 14 CFR 11.81, Drone Zone Vids 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: 

Richard Rollins 

Chief Executive Officer 

Drone Zone Vids LLC 

17716 Fruited Plain Ln 

Edmond, Ok 73012 

dronezonevids.com

B. The Specific Sections Of 14 CFR From Which Drone Zone Vids LLC Seeks Exemption 

1. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 61.113(a) 

and (b). 

Section 61.113, entitled Private Pilot Privileges and Limitations: Pilot In Command, 

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

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

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

compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft. 

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

connection with any business 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. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.7(a). 

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft less it is in an airworthy condition.

3. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.121. 

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

part: 

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

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

operating— 

(1) Below 18,000 feet MSL, to—

Page 6 of 22
(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. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.151(b). 

Section 91.151, entitled Fuel Requirements for Flight in VFR Conditions, subsection 

(b) states the following: 

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

(considering wind an 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. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.405(a). 

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

Each owner or operator of an aircraft— 

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

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

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

6. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.407(a)(1) 

Section 91.407, entitled Operation After Maintenance, Preventive Maintenance, 

Rebuilding, or Alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless— 

(1) It has been approved for return to service by a person authorized under 

43.7 of this chapter. 

7. Drone Zone Vids LLC Seeks Exemption from The Requirements of Section 91.409(a)(1) 

and 91.409(a)(2) 

Section 91.409, entitled Inspection, 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. 

Page 7 of 22
8. Drone Zone Vids LLC Seeks Exemption from The Requirements of Sections 91.417(a) 

and 91.417(b). 

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

following: 

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

owner of 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 

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

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

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

work performed; and 

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

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

for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

rotor, and appliance. 

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

required to be overhauled on a specified time basis. 

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

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

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

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

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

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by 43.9(b) of this chapter for each major 

alteration to the airframe and currently installed engines, propellers, 

propellers, and appliances. 

(b) The owner of 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. 

Page 8 of 22
C. The Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids Seeks 

Relief. 

1. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Vids 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) sate 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, Drone Zone Vids submits that an equivalent level of safety will 

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

has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate the 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, Drone Zone Vids submits that all flight of the DJI Inspire 1 UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Drone Zone Vids business; and 

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

2. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids 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 Drone Zone Vids to determine that the DJI Inspire 1 UAS are in airworthy 

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

documents (i.e., Drone Zone Vids Aerial Operations Manual, Maintenance and Flight Logs, and 

DJI Inspire 1 Instruction Manual). 

Drone Zone Vids seeks the requested relief because the DJI Inspire 1 UAS does not require an 

airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. Therefore, Drone 

Zone Vids will ensure that the DJI Inspire 1 UAS are maintained and operated in airworthy 

conditions based upon its compliance with eh operating documents (i.e., Maintenance log, 

flight log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine 

that the aircraft are in condition for safe flight, as sad in the conditions and limitations 

below. 

3. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids 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 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any 

altitude information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), Drone Zone Vids seeks relief because the DJI Inspire 1 UA’s 

Page 9 of 22
altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure offend altitude, before each flight. 

Considering the limited altitude of the proposed operation, 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, and equivalent level of safety will be 

maintained since the 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 Drone Zone Vids Seeks and The Reason Drone Zone Vids 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 flight of the battery powered DJI Inspire 1 UAS 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 23 minutes. Drone Zone Vids seeks relief because without an 

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

1 UAS will severely constrain the practicality of aerial video or still photo flight operations 

that Drone Zone Vids proposes to conduct pursuant to this Petition. 

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

Inspire 1 operating documents, and Drone Zone Vids proposed operating limitation, ensure 

that Drone Zone Vids will safely operate the battery powered 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 23 minutes. 

5. Extent Of Relief Drone Zone Vids Seeks and The Reason Drone Zone Vids Seeks Relief 

from Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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, Drone Zone Vids request relief from these Sections 

because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more 

fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Drone Zone Vids will use trained 

technicians to prom maintenance, alteration, or preventive maintenance on the UAS using the 

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

Zone Aerial Operations Manual, Maintenance Log, and DJI Inspire Instruction Manual). 

Furthermore, Drone Zone Vids will document and maintain all maintenance records for the 

DJI Inspire 1 UAS. 

D. The Reasons Why Granting Drone Zone Vids 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 Drone Zone to safely, 

efficiently, and economically perform aerial video and photography of real estate, 

landscapes, construction sites over certain areas of the United Sates. 

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

pollution, and provide significant benefits to the economy. Notably, the benefits of Drone 

Zone Vids proposed operation of the DJI Inspire 1 UAS will be realized without implicating any 

privacy issues. 

Page 10 of 22
1. The Public Will Benefit From Decreased Congestion of The NAS. 

The 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 of manned aircraft needed to perform aerial acquisitions, and exemption allowing the use 

of 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. 

Utilizing DJI’s Inspire 1 will reduce the amount of areal photography aircraft departing and 

arriving at congested airports. This will also reduce the workload of areal vehicles handled by 

air traffic control personnel. 

2. The Public Will Benefit From The Safety and Efficiency of The DJI Inspire 1 UAS 

Conducting aerial photography with the DJI Inspire 1 UAS, will greatly benefit the public y 

drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operation. By using battery power and electric motors, the 

DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious 

alternative to the general aviation aircraft utilizing noisy piston driven aircraft that typically 

are used for aerial video and photography, while burning several gallons per hour of leaded 

aviation fuel. This also helps in the efforts to reduce the amount of low lead aviation fule 

used in general aviation operations. The DJI Inspire 1 UAS utilizes electric motors that drive a 

propeller rather than a gas fueled engine. 

Utilizing the DJI Inspire 1 UAS to perform aerial work, the substantial risk to life and property 

in the air and on the ground, which is usually reserved for traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. The DJI Inspire 1’s weight 

and cross section being significantly light and small further reduce the risk of physical or 

collateral damage to life and property as compared to manned general aviation type aircraft. 

3. Performing Aerial Video and Photography Operation Utilizing the DJI Inspire 1 UAS Will 

Benefit The Economy. 

In Addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical 

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

of the DJI Inspire 1 UAS will allow United States used companies, like Drone Zone Vids to 

remain competitive and contribute to the 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 UAS in one such technology that non only allows companies greater operational 

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

manned aircraft. 

By operating the DJI Inspire 1 UAS companies such as Drone Zone Vids, can be competitive 

and profitable, and therefore, proved greater job stability to employees and contractors, 

which will ultimately contribute to the growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, 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. 

Page 11 of 22
4. No Privacy Issues 

Just like the manned aerial photography flight operations that have been conducted for 

decades, Drone Zone Vids proposed operation of the DJI Inspire 1 UAS will not implicate any 

privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with 

operating documents (i.e., Drone Zone Aerial Operations Manual, Maintenance log, and DJI 

Inspire 1 Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including 

the minimum altitude requirements of 14 CFR 91.119. 

E. The Reason 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 Drone Zone Vids Seeks Exemption. 

1. Reasons Why DJI Inspire 1 UAS Meets The Conditions of The FAA Modernization and 

Reform Act of 2012 (FMRA) section 333. 

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

the DJI Inspire 1 UAS, Drone Zone Vids operation of the UAS meets the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in accordance with 14 CFR Part 

21, Subpart H. 

Section 333 provides authority for 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 

sates the following, in part: 

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

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rule making required by section 332 

of this Act or 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 sited not crate a hazard to users of the national 

airspace system or the public or pose a treat 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, Drone Zone Vids submits that the DJI Inspire 1 UAS can operate 

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

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

limitations. 

Page 12 of 22
a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics 

The DJI Inspire 1 UAS does not pose nor create a hazard to users of the NAS or to the public, 

or to national security considering its size, wight, speed, and operational capability. 

(1) Technical Specifications Of The DJI Inspire 1 UAS. 

The technical specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 

User Manual, see attached Appendix A. 

(a) The DJI Inspire 1 UAS Global Positioning Modes Enables The UAS to Remain 

Within A defined Operational Area.

The DJI Inspire 1 UAS may be operated in both manual and global positioning 

flight modes. A complete description of the flight and navigation modes of the 

DJI Inspire 1 UAS is provided at pages 12-15 of the DJI Inspire 1 User Manual 

attached as Appendix A. 

(b) The DJI Inspire 1 UAS Is Designed For Automatic Return To Home Point Or Hover 

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

When Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, 

for approximately 3 seconds. If, after 3 seconds, the DJI Inspire UAS does not 

reacher control link data from the GCS, the UAS will assume that the Control 

Link is lost and will return to home position (fail safe mode) via GPS, and will 

descend to the takeoff position and shutdown. 

A complete description of the Failsafe Function of the DJI Inspirer 1 UAS are set 

forth at pages 12-15 of the DJI Inspire 1 User Manual, attached as Appendix A. 

(c) The DJI Inspire 1 UAS 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 24-33 of the DJI Inspire 1 

User Manual, as attached as Appendix A. 

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

Pilot in Command With A Safety Observer. 

Drone Zone Vids staff will be the only persons to act as a pilot in command (PIC) of the DJI 

Inspire 1 UAS. Additionally, a safety observer will assist him or her at all times during flight 

time. 

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

Limitations. 

In seeking this exemption, Drone Zone Vids proposed to commercially operate DjI Inspire 1 

UAS for the special purpose of conduction aerial video and photography over certain areas of 

the United States, pursuant to the following specific operating limitations. 

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

described in the operating documents, rotorcraft UAS weighing less than 55 pounds 

Page 13 of 22
maximum gross weight: DJI Inspire 1 UAS. Proposed operations of any other aircraft will 

require anew 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 indicted airspeed exceeding 20 knots. 

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

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

special request is made and proved 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 time. 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 o 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 

requirements 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 or delegate 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 ground based obstacles/obstructions. 

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

operations and available to the Administrator upon request. Should a discrepancy exist 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating document, 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 reversed documented if it petitions 

for extensions amendment to its grant of exemption. If the operator determines that any 

update or vision 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 questionnaires reading 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. 

Page 14 of 22
11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, 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, not already covered 

in the relevant sections of the operating documents. 

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

overhaul, replacement, inspection, and life limit requirements. 

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhauls component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

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

Bulletins. 

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

taken against discrepancies discovered between inspections. 

17. The PIC must 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 fight hours must be logged in a manner 

consistent with 14 CFR 61.51(b). Flight for the purposes of training the operator’s PIC’s 

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 flight, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from non 

participants in accordance with 14 CFR 91.119. 

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

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, special request will be made at the FAA office closest to proposed area 

of operations. Flights under special visual fight 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. 

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 predetermined 

location within the planed operating area and land or be recovered in accordance with the 

operating documents. 

Page 15 of 22
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 forecasted 

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 operations. All 

operations shall be conducted in accordance with airspace requirement 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 IAW 14 CFR Part 47, and have identification (N number) markings IAW 

14 CFR Part 45, Subpart C. Markings must be as large as practicable. 

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are whig 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 obstructers 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 near to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per 14 CFR Part 91.119(a), 

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

permission from the land owner or 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 tat transgresses the literal or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

Page 16 of 22
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. 

Drone Zone Vids 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 UAS 

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 UAS in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

Considering Drone Zone Vids 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 UAS, Drone Zone Vids submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Drone Zone Vids 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). 

Drone Zone Vids will not allow any PIC to operate the DJI Inspire 1 UAS unless the PIC has 

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

able to safely operate the 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. 

Specifically, 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 (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 purpose). 

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 Drone Zone Vids 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 other 

Page 17 of 22
than additive; i.e. 5 hours make and model time may be included in the 10 hours of 

multi rotor time and 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 appropriated 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 UAS with appropriate distances in accordance with 14 CFR 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Drone Zone Vids will ensure safe operations by not allowing any PIC to operate 

the 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 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. 

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, Drone Zone Vids will ensure that 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, 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 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 

Drone Zone Vids operation of the 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 UAS at ground level. 

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

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

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11158, 11159, 11160, 11161). 

Page 18 of 22
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 CFR 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 UAS; (2) 

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

operations. Accordingly, Drone Zone Vids will ensure that it will safely operate the battery 

powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of 23 minutes. 

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

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

will ensure an equivalent level of safety established by 14 CFR Section 91.151(b). 

Furthermore, safety will be ensured as the DJI inspire 1 UAS provide audible and visual 

warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first 

warning occurring at approximately 33% remaining battery power, and again at approximately 

10% remaining battery power. At the critically low battery level, the DJI Inspire UAS will 

descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations 

of the UAS are considered. Relief has been granted for manned aircraft to operate at less 

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

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 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, Drone Zone Vids 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 Drone 

Zone Vids will use trained technicians to perform maintenance, alterations, or preventive 

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

operating documents (i.e., Drone Zone Vids Aerial Operations Manual, Maintenance log, and 

DJI Inspire 1 Instruction Manual). Furthermore, Drone Zone Vids will document and maintain 

all maintenance records for the DJI Inspire 1 UAS. 

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

Zone Vids 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 Manual is attached as 

Appendix A. 

The exemption sought will not adversely affect safety because Drone Zone Vids 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. 

Also, 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 o the DJI Inspire 1 will be 

performed buy trained technicians. Maintenance will be documented and maintained 

utilizing the monthly maintenance log. 

Page 19 of 22
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) established that safety is not 

adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. 

In consideration of Drone Zone Vids proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Inspire 1 UAS, Drone Zone Vids submits that safety will 

not be adversely affected by granting exemption from 14 CFR Sections 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (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, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

IAW Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR 21.16 

entitled Special Conditions, Drone Zone Vids request that the FAA prescribe special conditions 

for the intended operation of the DJI Inspire 1 UAS, which contain such safety standards that 

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

by 14 CFR Part 21, Subpart H, and 14 CFR 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 whereto 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. 

The Administrator may prescribe special conditions pursuant to 14 CFR 21.16, for operation of 

the DJI Inspire 1 UAS, since the airworthiness regulations of 14 CFR 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 and aircraft, aircraft engine, or propeller 

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

propeller, that prescribes special conditions and amendments thermo 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 CFR 21.16 

In accordance with FMRA Section 333 and 14 CFR 21.16, the FAA may prescribe special 

condition for Drone Zone Vids intended operation of the DJI Inspire 1 UAS, which contain such 

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

equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR Sections61.113(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). 

Page 20 of 22
Summary That Can Be Published In The Federal Register, Stating: The Rules From Which 

Drone Zone Vids Seeks Exemption: 

Drone Zone Vids seeks exemption from the requirements of 14 CFR 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). 

Brief Description Of The Nature Of The Exemption Drone Zone Vids Seeks: 

This exemption will permit Drone Zone Vids to commercially operate a Unmanned 

Aircraft System (UAS) for the purpose of conduction aerial video and photography over 

certain areas of the United States. 

Additional Information, views, Or Arguments Available To Support Drone Zone Vids 

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, Drone Zone Vids request for exemption may be granted 

pursuant tooth authority of FMRA Section 333 and 14 CFR 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. 

Drone Zone Vids will operate the DJI Inspire 1 UAS safely in the NAS, without creating a 

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

CONCLUSION 

As set forth herein, Drone Zone Vids seeks an exemption pursuant to 14 CFR 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation 

of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited 

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

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 interest of the 

public, by allowing Drone Zone Vids LLC to safely, efficiently, and economically operate the 

DJI Inspire 1 UAS commercially within the NAS. 

Wherefore, in accordance with the Federal Aviation Regulation and the FAA Modernization 

and Reform Act of 2012, Section 333, Drone Zone Vids LLC respectfully request that the 

Administrator grant this Petition for an exemption from the requirements of 14 CFR 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 Drone Zone Vids LLC to operate the DJI Inspire 1 UAS 

commercially for the purpose of conduction aerial video and photography over certain areas 

of the United States. 

Page 21 of 22
Dated: July 31, 2015 

Respectfully submitted, 

Richard Rollins 

Chief Executive Officer 

Drone Zone Vids LLC 

17716 Fruited Plain Ln 

Edmond, Ok 73012 

dronezonevids.com

Tim Fannin 

Chief Operations Officer 

Drone Zone Vids LLC 

17717 Fruited Plain Ln 

Edmond, Ok 73012 

dronezonevids.com

Appendices: 

A — Link to DJI Inspire 1 User Manual, Safety Guidelines, and Maintenance Manual: Click 

links below 

http://download.dji-innovations.com/downloads/inspire_1/en/

Inspire_1_User_Manual_v1.4_en.pdf

http://download.dji-innovations.com/downloads/inspire_1/en/

Inspire_1_Safety_Guidelines_en.pdf

http://download.dji-innovations.com/downloads/inspire_1/en/

Inspire_1_Maintenance_ManualV1.0_en.pdf

Page 22 of 22