CITY OF CORAL SPRINGS, FLORIDA • COMMUNICATIONS AND MARKETING DEPARTMENT

9551 W. Sample Road • Coral Springs, FL 33065 • CoralSprings.org

Phone 954-344-1175 • Fax 954-344-1171

BASIS FOR PETITION

Petitioner, THE CITY OF CORAL SPRINGS, pursuant to the provisions of the Federal Aviation Regulations 

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

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI 

INSPIRE 1, in the National Airspace System (NAS), and for an exemption from the requirements of : 

14 C.F.R §§ 61.113(a) & (b) 14 CFR 45.23(b)

91.7(a),

91.121, 

91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91 

Name and Address of the Petitioner

The name and address of the Petitioner and point of contact is: 

RYAN HIMMEL

SENIOR VIDEOGRAPHER / VIDEO EDITOR

CITY OF CORAL SPRINGS

9551 W. SAMPLE ROAD

CORAL SPRINGS, FLORIDA 33065

OFFICE: 954-344-1175

EMAIL: RHIMMEL@CORALSPRINGS.ORG

PREFACE: 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that 

includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any sections 44702 - 44716 of this title if the Administrator finds the exemption in the 

public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 
The CITY OF CORAL SPRINGS proposes to use one or more Unmanned Aerial Drones (DJI INSPIRE 1), for the 

following uses: 

 Inspections of city-owned storm water canal system 

 Inspections of city-owned road rights of way 

 Periodic inspections of city-funded infrastructure improvement projects 

• Videography and Photography for Marketing

 Assist with damage assessments or situational status reports during emergency response operations 

 Support to law enforcement and fire departments during response operations. 

 Assist with site security during city-sponsored events (ie. 4th of July, New Years, parades, etc.) 

This aircraft has four rotors and four motors in a quadcopter configuration (X4). It is only capable of 

vertical takeoff and landings. This UAS weighs less than 55 lbs. including payload, can fly, under normal 

conditions at a speed of no more than 30 knots and has the capability to hover, and move in the vertical and 

horizontal plane simultaneously. This UAS is equipped with GPS and auto-return function to the predetermined 

safe landing area as well as allowing reading of magnetic interference that can cause loss off GPS signal. The 

UAS will operate only in line of sight and will operate only within the limits of public rights of way or 

easements. Such operations will be conducted to insure that the UAS will “not create a hazard to users of the 

national airspace system or the public.” (Reform Act Section 333 (b)). 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the 

rule making required under Section 333 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following:

• The UAS’s size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. §333(c). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that 

includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. 
The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702 - 44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1). 

RELIEF OVERVIEW 

Given the small size of the UAS involved and the restricted environment within which they will operate, 

the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. 

Also due to the size of the UASs and the restricted areas in which the relevant UAS will operate, approval of the 

application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing UASs for aerial inspections, surveying, photography and videography, the 

grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that 

the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

THE CITY OF CORAL SPRINGS proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory structure because 

the proposed operations represent a safety enhancement to the already safe aerial inspections, surveying and 

photography and videography operations conducted with conventional aircraft. 

These limitations and conditions to which THE CITY OF CORAL SPRINGS agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a Pilot-In Command (PIC) and a Safety Observer (SO). 

3. Maximum total flight time for each operational flight will be 30 minutes or less. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform for which filming is planned. 

5. Minimum crew for each operation will consist of the UAS Pilot and one Visual Observer. 

6. The UAS will only operate within the defined project area, the boundaries of which will be determined 

by the UAS Pilot-In-Command (PIC) based on the site-specific activities and speed of the UAS required 

for the operation, and coordinated with the jurisdictional FAA FSDO and local government officials as 

applicable. 

7. A briefing will be conducted in regards to the planned UAS operations prior to each day’s operation. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the project 

be present for this briefing. 
8. The UAS Pilot and Safety Observer will be able to communicate by voice and/or two way radio 

communication system at all times. 

9. The operations of the UAS will be limited to daylight-only operations. 

10. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a 

pre-determined location within the Project Perimeter and land safely. 

11. The UAS will have the capability to abort flight in case of unpredicted obstacles or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft 

from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

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

aircraft and its operation, THE CITY OF CORAL SPRINGS’s operation of DJI INSPIRE 1, UAS meets the conditions 

of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. 

Accordingly, THE CITY OF CORAL SPRINGS 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. THE CITY OF CORAL SPRINGS submits that the requested 

relief is proper since an equivalent level of safety will be ensured. THE CITY OF CORAL SPRINGS will use 

experienced personnel or technicians as needed to perform maintenance, alterations, or preventive 

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

(i.e., Monthly Maintenance Log, and DJI INSPIRE 1 Instruction Manual). Furthermore, THE CITY OF CORAL 

SPRINGS will document and maintain all maintenance records for the DJI INSPIRE 1 UAS. 

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

limitations: Pilot in command, is requested by THE CITY OF CORAL SPRINGS to the extent necessary to allow a 

Pilot in Command (PIC) meet or exceed the described requirements of operations set by manufacturer, and 

who has demonstrated, 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, vehicles and structures. 
THE CITY OF CORAL SPRINGS seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI INSPIRE 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, THE CITY OF CORAL SPRINGS submits that he will ensure that the DJI INSPIRE 1 UAS is in an 

airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI INSPIRE 1 Instruction Manual), and that the aircraft are in a 

condition for safe flight. 

THE CITY OF CORAL SPRINGS also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI INSPIRE 1 will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI INSPIRE 1 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 THE CITY OF CORAL SPRINGS’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.

Additionally, THE CITY OF CORAL SPRINGS seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. THE CITY OF CORAL SPRINGS submits that 

safety will not be affected by operation of the DJI INSPIRE 1 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 30 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5 minutes. 

EXTENT AND REASONING WHY THE CITY OF CORAL SPRINGS SEEKS RELIEF FROM THE LISTED SECTIONS ABOVE:

1. Section 61.113(a) & 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 meet all requirements as described in the DJI INSPIRE 1

owner’s manual 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, THE CITY OF CORAL SPRINGS 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 

demonstrated that the PIC is able to safely operate either 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, THE CITY OF CORAL SPRINGS submits that all flights of the DJI INSPIRE 1 1 UAS, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to THE CITY OF CORAL SPRINGS’s business; 

and (2) will not carry passengers or property for compensation or hire. 
2. 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow THE CITY OF CORAL SPRINGS to determine that the 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 CITY OF CORAL 

SPRINGS Operations Manual, Monthly Maintenance Log, and DJI INSPIRE 1 Instruction Manual). 

THE CITY OF CORAL SPRINGS seeks the requested relief because the DJI INSPIRE 1 UAS does not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, THE CITY OF CORAL 

SPRINGS will ensure that the DJI INSPIRE 1 UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, 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. 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), THE CITY OF CORAL SPRINGS seeks the requested relief because 

the DJI INSPIRE 1 UA 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 INSPIRE 1 UA 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. 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered DJI INSPIRE 1 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 25 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. THE CITY 

OF CORAL SPRINGS seeks the requested relief because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered DJI INSPIRE 1 UA will severely constrain the practicality of any aerial 

video or still photo flight operations that THE CITY OF CORAL SPRINGS 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 THE CITY OF CORAL SPRINGS ‘s proposed operating limitations, ensure that THE CITY 

OF CORAL SPRINGS will safely operate the battery powered DJI INSPIRE 1 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 4.5 minutes. 

14 CFR 45.23(b) 

Marking of the Aircraft; 

Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. 

UAV Field Services UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small 

aircraft. Regardless, UAV Field Services will mark its UAS in the largest possible lettering by placing the "N 

"number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working 

with the UAV will see the markings. The FAA has previously issued exemptions to this regulation throughExemption No 10167 and 10700 

5. 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, THE CITY OF CORAL SPRINGS requests 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 THE 

CITY OF CORAL SPRINGS 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 CITY OF CORAL SPRINGS aerial Operations Manual, Monthly Maintenance Log, and DJI 

INSPIRE 1 Instruction Manual). Furthermore, THE CITY OF CORAL SPRINGS will document and maintain all 

maintenance records for the DJI INSPIRE 1 UAS. 

The Reasons for granting this request are entirely beneficial to the public and community as a whole. 

Granting the present Petition will further the public interest by allowing THE CITY OF CORAL SPRINGS to 

safely, efficiently, and economically perform aerial video and photographic surveys and inspections of 

construction sites, rights of way, utility easements, and other sites within THE CITY OF CORAL SPRINGS, 

FLORIDA. 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the 

rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following: 
• The UAS’s size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, id. the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in 

the national airspace system.” Id. §333(c). 

Given the small size of the UAS involved and the restricted sterile environment within which they will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. 

Also due to the size of the UASs and the restricted areas in which the relevant UAS will operate, approval of the 

application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, including enhanced safety, reduction in 

environmental impacts, including reduced emissions associated with allowing UASs for movie and television 

operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay. 

REASONS BENEFICIAL TO THE PUBLIC/COMMUNITY 

1. The Public Will Benefit from Decreased Congestion of the NAS. 

The DJI INSPIRE 1 UA are battery powered and serve as a safe, efficient, and economical alternative to 

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of a DJI INSPIRE 1 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 INSPIRE 1 UA do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI INSPIRE 1 UAS. 

Conducting aerial acquisitions with the DJI INSPIRE 1 UAS, 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 INSPIRE 1 UAS 

produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while 

burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI INSPIRE 1 UA, while reducing the 

carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine.
By using the DJI INSPIRE 1 UAS to perform aerial observation, the substantial risk to life and property in 

the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI INSPIRE 1 UA (weighing approximately 2 pounds 11 ounces, at their maximum gross 

weights with length of 16 inches, widths of 16 inches, and with no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 

42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography, Surveys and Inspections, Operations with the DJI INSPIRE 1

UAS Will Benefit the Economy. 

In addition to being safe and efficient, the DJI INSPIRE 1 UAS are also provides an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI INSPIRE 1 UAS will 

allow THE CITY OF CORAL SPRINGS, to provide quality services to the residents and businesses of the City and 

the Region at minimum costs. Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, agencies must adopt new and alternative 

technology in continue to provide required services at reasonable costs. Operating the battery powered DJI 

INSPIRE 1 UAS is one such technology that not only allows agencies & companies greater operational flexibility 

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

manned aircraft. 

By operating the DJI INSPIRE 1 UAS, THE CITY OF CORAL SPRINGS can maintain and hopefully improve 

our ability to operate and maintain critical infrastructure and at the same time collect important data for 

further development of system-wide modeling of water, water, stormwater and roadway systems as well as 

provide accurate and current data related to environmental issues such as ground cover, vegetation & wildlife 

habitats. 

4. There Are No Privacy Issues. 

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

CITY OF CORAL SPRINGS’s 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., THE CITY 

OF CORAL SPRINGS Aerial Operations Manual, Monthly 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 maximum altitude limitations as per the 

requirements of 14 C.F.R. § 91.119. 

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 THE CITY OF CORAL SPRINGS SEEKS EXEMPTION. 

1. Reasons Why The DJI INSPIRE 1 UA Meet The Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333. 
In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, THE CITY OF CORAL SPRINGS’S operation of the DJI INSPIRE 1 UAS 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. 

In seeking this exemption, THE CITY OF CORAL SPRINGS 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. 

 a. The Specifications Of The DJI INSPIRE 1 UAS Demonstrate Its Safe Characteristics. 

The DJI Phantom 2 Vision UAS do not create a hazard to users of the NAS or the public, or 

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

capability.

i. Technical Specifications of The DJI INSPIRE 1 UAS. 

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

Specifications and Data Sheet. 

ii. The DJI INSPIRE 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To 

Remain Within A Defined Operational Area. 

The DJI INSPIRE 1 UAS may be operated in both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the DJI INSPIRE 1 UAS are included in the User Manuals. 

iii. The 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 INSPIRE 1 UA will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the DJI INSPIRE 1 UA does 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., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI INSPIRE 1 UA are set forth in the DJI INSPIRE 1 User 

Manual.

iv. The DJI INSPIRE 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI INSPIRE 1 GCS and flight control software 

is provided in the DJI INSPIRE 1 User Manual. 

b. Flights Of DJI INSPIRE 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. 
In seeking this exemption, THE CITY OF CORAL SPRINGS proposes to commercially operate DJI INSPIRE 1 UAS 

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

4. The UA must be operated at an altitude of no more than 400 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. 

6. The use of first person view camera to satisfy the visual line of site 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. 

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 meet or exceed all requirements as set forth by manufacturer in order to justifiably operate 

the DJI INSPIRE 1, or hold an equivalent pilot license approved by the FAA. 

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. 

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 pre- determined 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 UA must remain clear and yield the right of way to all manned aviation operations and activities at all 

times. 

29. The UAS may not be operated by the PIC from any moving device or vehicle. 

30. All operations shall be conducted over publicly owned or controlled property. Any operation over privately 

owned property would require 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. 

31. 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 

THE CITY OF CORAL SPRINGS AFFIRMS ALL INFORMATION LISTED ABOVE TO BE TRUE AND BINDING UPON 

FAA’S FINDINGS OF EXEMPTION REGARDING COMMERCIAL OPERATIONS OF LISTED UAS, UNTIL FURTHER 

NOTICE OF LAWS OR REGULATIONS DECIDED BY THE GOVERNMENT/FAA. THANK YOU FOR YOUR 

CONSIDERATION. 

RYAN HIMMEL

SENIOR VIDEOGRAPHER / VIDEO EDITOR