Naim Hasan Photography, LLC 

6405 NE Cleveland Ave

Portland, OR 97211

503-421-7493

naim@n2htec.com

Date: July 25, 2015

Submitted To:

US Department of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington, D.C.20591

RE: Petition for Exemption 14 CFR 11.81

Dear Sir or Madam:

Company Overview

Naim Hasan Photography, LLC, located at 6405 NE Cleveland Ave., Portland, OR 

97211, has been providing digital photographic services to a diverse group of Local, 

National, Private and Public organizations, since 2002. With the introduction of aerial 

photography/video services, those same organizations will be provided cost effective 

options that will improve the quality and type of visual information which in many cases 

will help to reduce cost and increase the accuracy in their decision making processes. 

NHP is State of Oregon certified as a Minority Business Enterprise (MBE), Emerging 

Small Business (ESB) and Disadvantaged Business Enterprise (DBE) # 7242, expiring 

March 2018. In January 2015, I received the Trusted Traveler Global Entry number# 

984960548 provided by the Transportation Security Administration (TSA).

NHP’s wishes to deploy for commercial operations the DJI Inspire 1, T600 Quad-rotor 

Unmanned Aircraft System (UAS): (See below for the overview of the DJI Inspire 1, 

T600 Quad-rotor Unmanned Aircraft System)

Proposed uses for the UAS

*Aerial photography and/or video for public and/or private use including:

real estate, real estate inspection, architecture, engineering and other related 

professional activities.

*Land development/ surveying documentation and commercial construction

*Documentation of natural fish and wildlife habitats (Logjams)
*Inspection of cellular towers, utility poles and other structures accessible by aerial 

views. 

*Aerial photography for marketing and advertising used in print and Web based 

mediums.

DJI Inspire 1 Overview

The DJI Inspire 1, T600 is a quad-rotor Unmanned Aircraft System (UAS), fully self 

contained unit including onboard battery power, and weighs less than seven (7) pounds. 

This UAS come equipped with an on-board camera which supports 4K video capture up 

to 4096 x 2160p24 and 12M pixel photos captured by using the 1/2.3 in CMOS sensor. 

The 3-axis Gimbal technology provides a steady platform for the attached camera, 

allowing for the capture of stabilized images and video. The Gimbal can tilt the camera 

up 120 degrees and rotate 360 degrees.

This unit is not designed to carry additional payload making it environmentally safe and 

economically advantageous to share the NAS. The Inspire 1 is controlled by a mobile 

ground station (Controller) which connects to a smart phone or smart tablet. The DJI 

Inspire 1 has a special pilot app that must be downloaded to the phone or tablet which 

fully integrates with the UAS providing visual control and access to the features of the 

UAS. This user interface offers valuable GPS information transmitted from the UAS 

back to the controller, which is displayed on the smart device offering 720p HD view of 

everything the camera sees. With this detailed information at the operators disposal, 

flying becomes extremely safe and reduces the potential danger to people and the 

environment. The UAS come equipped with a programmable Safety Return To Home 

function that can be activated due to low battery power, or loss of radio connection 

between the UAS and the controller. Manual Return To Home can be activated anytime 

based on the operators preference.

Exemption Request

This petition is based, in part on prior exemptions granted by the FAA who’s exemption 

numbers are as follow: 11410, 12042, 12097, 12115, 12116.

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (the “Reform Act”) and Title 14 of the Code of Federal Regulations 

(CFR) , Naim Hasan Photography, LLC, referred to as (NHP) owner and operator of the 

above mentioned DJI Inspire 1, Model T600, Unmanned Aircraft System (UAS), request 

exemption from the Federal Aviation Regulations (FAR) listed below which would allow 

NHP the privilege of operating the above mentioned UAS commercially in the airspace 

regulated by the FAA., so long as, operation of the aforementioned UAS is conducted 

within and under the conditions and safety guidelines outlined herein or as maybe 

established by the FAA as required by Section 333.
NHP request exemption from Title 14 of The Code of Federal Regulations (CFR) 

Sections: Part 21 Subpart H; ( Certification); 45.23 (b) (N number identification); 61.31 

(a); 61.113 (a) and (b) (Flying for Hire); 91.7 (a); 91.9 (b) and (2) (Airworthiness); 91.103 

(Preflight, Airport); 91.119; 91:121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a) 

(1) and (2); 91.409 (a) (1) and (2); 91.417 (a) and (b).

The extent of relief NHP is seeking and the reasons we seek such 

relief

CFR part 21 Subpart H: prescribing the procedural requirements for issuing and 

changing design approvals, production approvals, airworthiness certificates, and 

airworthiness approvals. NHP believes that relief from this section is not necessary 

under the statutory criteria set forth in Section 333 of Public Law 112-95 (P.L. 112-95) in 

reference to 49 USC Section 44794 given the size, weight, speed, and limited operating 

area associated with the proposed UAS.

As of March 23, 2015 the FAA has stated that a “blanket” COA will be automatically 

granted with a Section 333 exemption when the UAS maintains flights at or under 200 

AGL.

Section 45.23 (b) prescribing that when marks include only the Roman capital letter 

“N” and the registration number is displayed on limited, restricted or light-sport category 

aircraft or experimental or provisionally certified aircraft, the operator must also display 

on the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less 

than 2 inches nor more than 6 inches high, the words “limited”, “restricted”, “light-sport”, 

“experimental”, or “Provisional”, as applicable. NHP believes that relief from the section 

is not necessary as the proposed UAS is not certified under Section 21.191 and this 

petition is submitted in connection with proposed operation as a Civil UAS.

Section 61.31 (a) prescribing that a person who acts as a pilot in command of any of 

the following aircraft must hold a type rating for that aircraft for other aircraft specified by 

the Administrator through aircraft type certificate procedures: Large aircraft (except 

lighter-than-air), Turbojet-powered airplanes, and other aircraft specified by the 

Administrator through aircraft type certificate procedures. NHP believes relief from this 

section is not warranted under the statutory criteria outlined in Section 333 of P.L. 

112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited 

operating area associated with the proposed UAS. NHP, however, respectfully requests 

exemption of 61.113 (a) and (b), and if granted the UAS will fully comply with the 

qualifications of PIC noted herein.

Section 91.7 (a) prescribing that no person may operate a civil aircraft unless it 

meets airworthiness requirements. NHP requests relief from this section because the 

airworthiness of the UAS will be determined by the operator based on the operational 
documents provided by the manufacture of the DJI Inspire 1 UAS. NHP will adhere to 

the following prior to each flight of the UAS mentioned above: 

a. NHP will inspect the UAS and Ground control unit to insure both are functioning 

properly based on the manufacturers operational requirements. 

b. NHP will follow DJI’s aircraft/component, maintenance schedule, overhaul, 

replacement, inspection and life limit requirements.

c. NHP will comply with all DJI’s manufacturer safety bulletins.

Section 91.9 (b)(2) prohibits the operation of a civil aircraft unless there is a aircraft 

flight manual in the aircraft. Given the size of the UAS and the fact that there is no pilot 

or passengers onboard the UAS, this regulation does not apply and NHP request that 

relief be granted.

The FAA has previously issued exemptions to this regulation in Exemption No’s: 8607, 

8737, 8738, 9299, 9565, 10167, 10602, and 32827

Section 91.119 establishes minimum safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at lower altitudes under certain 

conditions. NHP is requesting relief from this section because flights made by the DJI 

Inspire 1 UAS will not exceed 400’ AGL. When flying over private property or people, the 

proper consent documentation and approvals will be obtained prior to the flight. In 

addition, the low-altitude operation of the UAS will ensure adequate separation between 

the UAS operations and the operations if conventional aircraft that must comply with 

Section 91.119.

Section 91:121 requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure airport 

or an appropriate altimeter setting available before departure. NHP request relief from 

this section because the UAS mentioned in the document does not have a barometric 

altimeter but instead provides a GPS altitude information that is displayed through the 

pilot app to the smart phone or tablet. If the UAS exceed an altitude that is outside the 

limits of the controller and UAS the communications signal weakens and a notification is 

displayed on the smart device indicating that a lower altitude must be reached in order 

to maintain control of the UAS or Automatic Return to Home is activated. NHP intends 

to stay within the flight limits to avoid any potential consequences that would prevent the 

UAS from landing successfully.

91.151 (a) prohibits an individual from beginning 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. NHP is requesting relief from this section due to the fact that the 

UAS is a battery powered unit with flight times ranging from eighteen (18) minutes of 

flying time when the TB47 4500m0Ah smart battery is in use and up to twenty-two (22) 
minutes of flying time when the TB48 smart battery is in use. The Low power indication 

displays on the smart device notifying the PIC that it is time to return to home.

NHP is requesting exemption from the following sections because they are all 

associated with airworthiness and the is no airworthiness certification establish for small 

UAS’s. 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1) and (2); 91.409 (a) (1) 

and (2);91.417 (a) and (b). The operator will take every precaution, through 

preflight planning, to insure that the UAS is functioning to the highest standards 

possible as outlined by the manufacturer and will fly within the limits outlined in this 

petition. 

Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should publication of this petition be needed: NHP request exemption 

from Title 14 of The Code of Federal Regulations (CFR) Sections: Part 21 Subpart H; 

( Certification); 45.23 (b) (N number identification); 61.31 (a); 61.113 (a) and (b) (Flying 

for Hire); 91.7 (a); 91.9 (b) and (2) (Airworthiness); 91.119; 91:121; 91.151 (a); 91.203 

(a) and (b); 91.405 (a); 91.407 (a) (1) and (2); 91.409 (a) (1) and (2); 91.417 (a) and (b) 

with the sole purpose of operating commercially a DJI Inspire 1, T600 Unmanned 

Aircraft System (UAS). Through the granting of this petition the FAA administrator will be 

helping to creature and foster small business development and economic opportunities 

for individuals and businesses. The deployment of UAS’s can provide cost effective 

alternatives for businesses engaged in research, land use planning and documentation, 

search and rescue, surveying, inspections of various types including power poles, 

natural habitats, wind turbines, bridges and other applications. Due to the limited size 

and operational area, limited speeds, limited battery power, and return to home 

features, the UAS does not pose a threat to the NAS. NHP once again respectfully 

request the FAA request exemption to the above mentioned sections without delay. 

Thank you very much for your time and consideration.

Sincerely,

Naim Hasan, Owner/Photographer

Naim Hasan Photography, LLC

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