Lacey Szekely

Vertical Vantage, Inc.

5600 Caleb Dr.

Fallon, NV 89406

(541)727-1286

Docket No. FAA-2015-1256

*Note: After submitting my original petition on April 2, 2015 for exemption with respect 

to the DJI Phantom 2, DJI released a more sophisticated UAS; the Inspire 1. I have 

purchased the DJI Inspire 1 and am seeking an exemption for that UAS. All 

specifications, manuals and pertinent information are attached. All requests for 

exemption using the Phantom 2 have been removed from this docket.

Additional Information: 

I. Regulations from which Exemption is Requested

Relief is requested from the following FAR’s:

A. 14 CFR Part 21, Subpart H: Airworthiness Certificates and 14 CFR 

91.203(a) (1)

B. 14 CFR 61.56: Flight Review

C.14 CFR 61.113 (a) & (b): Private pilot privileges and limitations

D. 14 CF R 91.119: Minimum safe altitudes

E. 14 CFR 91.121: Altimeter settings

F. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions 

G. 14 CFR 91.405 (a):Maintenance required; 91.407 (a) (1): Operation after 

maintenance, preventive maintenance, rebuilding, or alteration; 91.409 (a) 

(2): Inspections; 91.417 (a) & (b): Maintenance records

A. 14 CFR Part 21; Subpart H: Airworthiness Certificates and 14 CFR 91.203(a)(1)

Vertical Vantage requests exemption from attaining airworthiness certificates required 

by 14 CFR 91.203(a)(1). Section 333 of the Reform Act allows the FAA to exempt 
aircraft from the requirement of an airworthiness certificate in consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of 

the UAS.

Equivalent of Safety

The DJI Inspire 1 weighs 6.4 lbs to include payload, no persons on board, and no 

flammable fuels. The operational location can be preloaded using GPS way points to 

include route altitude and speed. The DJI Inspire 1 also has a return to home button 

which safely brings the drone back to its starting point. The PIC and VO will do a 

thorough preflight to determine the airworthiness of the Inspire 1 prior to each flight on 

location. The safety guidelines will be followed from the Inspire 1 User Manual, Flight 

Operations Manual, and preflight checklist.

B. 14 CFR 61.56: Flight Review

Vertical Vantage requests exemption from 14 CFR 61.56 which requires the PIC to 

conduct a flight review consisting of a minimum of 1 hour of flight training and 1 hour of 

ground training. This requirement is not pertinent to the safe operations of the Inspire 1. 

Equivalent of Safety

The equivalent level of safety will be achieved by following the procedures of the 

manufacturer in the Inspire 1 User Manual and Flight Operations manual. Maintaining 

currency and proficiency are a top priority for Vertical Vantage Inc. Bi-monthly flights 

will be the minimum requirement for operation of the Inspire 1. These flights, if not for 

business purposes will consist of at least 18 minutes (battery life limit) of flight time with 

Inspire 1, and 10 manual (no GPS) take off and landings. 

C. 14 CFR 61.113: Private pilot privileges and limitations: Pilot in Command

Vertical Vantage requests exemption from 14 CFR 61.113(a) which states that Except 

as provided in paragraphs (b) through (h) of this section, no person who holds a private 

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or 

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

pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command 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.

The UAS will only carry a camera onboard for hire. No living thing at anytime will be 

carried, therefor an exemption from the above requirement is requested.
Equivalent of Safety

While being used for commercial and private use, the UAS will never carry live people, 

animals, or creatures, and therefore has a much lower operational safety requirement 

than a passenger craft. 

D. 14 CFR 91.119(c): Minimum safe altitudes

Vertical Vantage request exemption from 14 CFR 91.119(c), which states that except 

when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or 

over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Equivalent of Safety

Due to the small size, weight, limited speed and absence of flammable liquids on board, 

the Inspire 1 is safer than an airplane. Flying will only occur with the proper consent of 

the property owners and/or local officials. This permission will give ample time for all 

owners and neighbors to be aware of the times of operation. Multiple signs will be 

posted to ensure people are aware when drone operations are being conducted. At no 

time will the UAS be operated at or near any airport, exceed 400ft AGL, and or be flown 

over any person, vessel, vehicle or structure without prior coordination and permission 

of the concerned parties (i.e. base operations, FBO, marina operations manager, etc.).

E. 14 CFR 91.121: altimeter setting

Vertical Vantage requests exemption from 14 CFR 91.121 which states that:

(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. 
The UAS needs an exemption because there is not a configurable barometric altimeter 

on board.

Equivalent of Safety

Precise altitude control is accomplished easily by two methods. The first is done by preloading the precise GPS waypoints for the intended route of flight, to include altitude 

and airspeed. The second is done while operating in a manual flight mode by inputing a 

maximum allowable altitude into the flight control system on the controller. This limit 

prevents the Inspire 1 from ever exceeding that altitude. At no time will this limit exceed 

400ft AGL in either pre-planned or manual mode. The Inspire 1 will also remain within 

visual line of sight at all times. 

F. 14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Vertical Vantage requests exemption from 14 CFR 91.151(a), which states that: (a) No 

person may begin a flight in an airplane 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—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The Inspire 1 uses an 18 minute battery therefore cannot meet the criteria for this 

requirement.

Equivalent of Safety

Planning all flights to land after 15 minutes or 25% battery power remaining, whichever 

comes first, would provide equal safety conditions. The Inspire 1 has a safety feature 

which automatically returns it directly to the point of origin or planned destination, 

whichever is closer, upon reaching 25% battery power remaining. This prevents power 

loss in flight. Additionally if the remote controller is low on batteries the pilot can 

manually command the Inspire 1 to return to the point of origin with the push of a button. 

This prevents any case where airborne control of the drone may be lost due to a dead 

remote control. This function can be activated at distances greater than visual range, 

however Vertical Vantage will only operate the UAS in visual line of sight and day VFR 

conditions.

G. 14 CFR 91.405(a) Maintenance required;91.407(a)(1) Operation after 

maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a) 

Inspections; 91.417(a)&(b) Maintenance records

Vertical Vantage request exemption from maintenance and inspection requirements 

from 14 CFR 91.405(a), 91.407(a)(1), 91.409(a), and 91.417(a)&(b). An exemption is 
required for aircraft holding an airworthiness certificate. Presuming an approval for 

waiver of 14 CFR Part 21, subpart H and 14 CFR 91.203(a)(1) the Inspire 1 will not 

require an airworthiness certificate. The Inspire 1 does not hold this certificate.

Equivalent of Safety

Ensuring the UAS is operational before a flight is key to maintaing an excellent safety 

record. Keeping a log book for all maintenance preformed and any maintenance test 

flights will be recorded. This will ensure proper user maintenance is conducted on time. 

All maintenance will be in accordance with the DJI user manual.

II. Public Interest

This exemption is in the public’s interest because it offers a more cost effective, more 

efficient way of supporting their needs with increased safety. The use of a lightweight 

UAS offers the general public something only successful companies could afford; views 

from the sky. These aerial views can benefit small and large businesses alike. 

The Inspire 1 is a safer alternative than other methods like hiring a helicopter or 

airplane. A UAS can go to places those aircraft cannot and also eliminates the human 

risk factor. For example, someone wanting to make a short real-estate clip of their 

property no longer needs to hire a helicopter which is not very cost effective or as safe. 

Also, for the purpose of inspecting infrastructure, trenches, agriculture, property lines 

etc. The UAS provides an annoyance free solution while decreasing the volume of 

aircraft in the National Airspace above 400 ft AGL. Additionally, the newest DJI UAS, 

the Inspire 1 incorporates increased safety measures such as push-button return home 

capability, low battery sensing which activates automatic return, more efficient lowimpact blades, and increased telemetry allowing greater control by the pilot.

Small drones can have the job done in a more timely manor with less manpower. This 

much safer alternative will not only mitigate unnecessary risk but provide the public an 

affordable and dependable service. Because of this it is in my opinion that Vertical 

Vantage working with the Inspire1 would be in the greatest interest of the public. 

III. Privacy
All flights will have signed permission/consent forms from the property owner. Ample 

time will be given to notify neighbors and signs will be placed in plain sight when the 

Inspire 1 is aerial. These flights will only occur in predetermined and controlled 

locations which will protect peoples privacy. Prior permission from the city, county, 

state or federal officials will be requested if flights need to occur over public 

lands/property.

IV. 14 CFR Summary

I, Lacey Szekely, Vertical Vantage Inc., request exemption from the following rules to 

commercially operate the Inspire 1 in National Airspace for Aerial photography, 

videography, inspection/survey and real estate services.

 14 CFR Part 21, Subpart H: Airworthiness Certificates and 14 CFR 

91.203(a) (1)

14 CFR 61.56: Flight Review

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations

14 CF R 91.119: Minimum safe altitudes

14 CFR 91.121: Altimeter settings

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions 

14 CFR 91.405 (a):Maintenance required; 91.407 (a) (1): Operation after 

maintenance, preventive maintenance, rebuilding, or alteration; 91.409 (a) 

(2): Inspections; 91.417 (a) & (b): Maintenance records

Re-submitted July 12, 2015 by:

Vertical Vantage Inc. 

Lacey Szekely, Owner

5600 Caleb Dr.

Fallon, NV 89406

Telephone: (541) 727-1286

verticalvantageinc@gmail.com