UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

Aerial Image Logistics, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERALREGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1, DJI 

S900, and DJI F450 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on August 11, 2015

Aerial Image Logistics, LLC

Richard F. Davis

969 Tamarind Way

Boca Raton, Florida 33486

Email: rdthree@bellsouth.net

Ph: 561-702-4733
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS ..................................................................................................... 3

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

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

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

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

A. Name And Address Of The Petitioner ............................................................................... 7

B. The Specific Sections Of 14 C.F.R. From Which Aerial Image Logistics, LLC Seeks

Exemption........................................................................................................................... 7

C. The Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image 

Logistics, LLC Seeks The Relief.......................................................................................... 10

D. The Reasons Why Granting Aerial Image Logistics, LLC Request Would Be In The Public

Interest ............................................................................................................................. 12

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety.......... 14

F. The Rules From Which Aerial Image Logistics, LLC Seeks Exemption ............................ 22

G. Any Additional Information, Views, Or Arguments Available To Support Request...... 22

CONCLUSION ................................................................................................................................ 23

APPENDICES......................................................................................................................................................................... 24

APPENDIX - A: DJI Inspire 1 Technical Specifications.................................................................................................... 24

APPENDIX - B: DJI Inspire 1 Manufacturer’s User Manual............................................................................................ 24

APPENDIX - C: DJI Inspire 1 Manufacturer’s Maintenance Manual.............................................................................. 24

APPENDIX - D: DJI Inspire 1 Manufacturer’s Safety Guidelines.................................................................................... 24

APPENDIX - E: DJI S900 Release Notes.....................................................................................................................25

APPENDIX -.F: DJI S900 User Manual.......................................................................................................................25

APPENDIX - G: DJI Futaba 14SG RC System User Manual .........................................................................................25

APPENDIX - H: DJI HK-M Quick Start Guide..............................................................................................................25

APPENDIX - I: DJI A2 Quick Start Guide....................................................................................................................25

APPENDIX - J: DJI IOSD Mark II User Manual ...........................................................................................................25

APPENDIX - K: DJI F450 User Manual.......................................................................................................................26

APPENDIX - L: DJI E300 Propulsion System User Manual ............................................................................................. 26

APPENDIX - M: DJI DT7 & DR16 RC System User Manual .........................................................................................26

APPENDIX - N: DJI NAZA-M V2 Quick Start Manual .................................................................................................26

APPENDIX - O: DJI iOSD mini User Manual ..............................................................................................................26

APPENDIX - P: Flysight Black Pearl Video Monitor...................................................................................................26
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Aerial Image Logistics, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a)

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA). This exemption will permit Aerial Image Logistics, LLC to operate an Unmanned 

Aircraft System(UAS) for the commercial purpose of:

1. Aerial photography/video for public and/or private use including residential and commercial

real estate marketing, appraisal, architecture, land surveying, construction, engineering, 

bridge inspection, roof inspection, and other related professional activities.

2. Aerial video/photography for public and/or private use including television, public events, 

cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines, and cell towers.

4. Aerial inspection/photography/monitoring of agricultural crops.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the Civil Air Patrol, local 

authorities or government have requested it by contract or donation.

INTRODUCTION AND INTERESTS OF THEPETITIONER

Aerial Image Logistics, LLC, is being formed to provide safe, reliable, high quality, and cost effective 

airborne imaging and data collection that meet the needs of our customers. The principle of the 

company; Richard F. Davis, has been a Florida Licensed Real Estate Broker (#BK 444841) since 1986 with 

over 25 years of experience marketing and appraising both residential and commercial properties. He is 

also a Florida Licensed Appraiser Trainee (#R123469).

Richard F. Davis has been a FAA licensed pilot since 1989 and possesses a Commercial Pilot certificate 

(#2784324), a Certified Flight Instructor certificate (#2784324CFI), and Advanced Ground Instructor 

certificate (#2784324).

Richard F. Davis also is a Civil Air Patrol (United States Air Force Auxiliary) Mission Pilot, Instructor Pilot, 

and Check Pilot Examiner, and has been an active member of the CAP organization for 12 years. The 

Civil Air Patrol is best known for its search-and-rescue efforts, CAP flies more than 85 percent of all 

federal inland search-and-rescue missions directed by the Air Force Rescue Coordination Center at 

Tyndall Air Force Base, Florida.

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1, DJI S900

and DJI F450 UAS

Aerial Image Logistics, LLC seeks an exemption to operate DJI UA systems for compensation or hire 

within the NAS. 

TheDJI Inspire 1 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control

Station (GCS) utilizes electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross

weight of 6 pounds 8 ounces, a length of 17 inches, width of 17 inches, height of 12 inches, and a 
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maximum speed of approximately 22 m/s or 42 knots. The DJI Inspire 1 UA is equipped with four main

rotors; driven by Lithium Polymer battery powered electric motors.

The DJI S900 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA), has a maximum gross weight 

of 8.2 kg, or 18 pounds. The dimensions are 900mm x 900mm (motor to motor) or 35 inches x 35 inches

(motor to motor). Under still air the maximum speed is no more than 19m/s or 37 knots. The DJI S900

has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI S900 has 

six kV-400 rpm/V electric motors, powered by a 6 cell Lithium Polymer battery. There are six 15 x 5.2 

inch propellers. The DJI S900 will be controlled with the Futaba 24SG twenty four channel remote 

controller (GCU) and the FutubaR7008SB eight+ channel receiver with an operating frequency of 

2.404GHz – 2.476GHz. The live video feed will have an operating frequency of 5.74GHz – 5.86GHz. The 

DJI S900 is to be equipped with either the DJI mini iOSD (On Screen Display) unit or the DJI Mark II OSD 

which provides real time data including power voltage, flight velocity, height, distance from the home 

point, horizontal attitude, pitch, roll, number of GPS satellites and more. The flight data information is 

visible to the operator on the LCD monitor attached to the remote control unit (GCU)

The DJI F450 vertical takeoff and landing (VTOL) Unmanned Aircraft (UA), with extended motor arms 

(extends frame arms 5cm), has a maximum gross weight of 1600g or 3.53lbs. The dimensions are 500mm 

x 500mm x 280mm (including GPS mast) or 20 inches x 20 inches x 12 inches (including GPS mast). Under 

still air the maximum speed is no more than 18m/s or 35 knots. The DJI F450 has the ability to hover and 

move along a vertical and horizontal plane simultaneously. The DJI F450 has four motors, Motor Model 

DJI 2212/920KV E300 tuned propulsion system, powered by a 3 or 4 cell Lithium Polymer battery. There 

are four propellers, Propeller Model DJI 9443, or 9450, 1038 are in use. The DJI F450 will be controlled 

with the DJI DT7 seven channel remote controller (GCU) and the DJI DR16 sixteen channel receiver with an 

operating frequency of 2.404GHz – 2.476GHz. The live video feed will have an operating frequency of 

5.74GHz – 5.86GHz. The DJI F450 is equipped with the DJI mini iOSD (On Screen Display) unit which 

provides real time data including power voltage, flight velocity, height, distance from the home point, 

horizontal attitude, pitch, roll, number of GPS satellites and more. The flight data information is visible to 

the operator on the LCD monitor attached to the remote control unit (GCU).

The DJI UA that will be operated by Aerial Image Logistics, LLC will all be registered in accordance with 

49U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and markedin 

accordance with 14 C.F.R. Part 45, Identification and RegistrationMarking.

BASIS FOR PETITION

Petitioner, Aerial Image Logistics, LLC, 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, DJI S900, and DJI F450 UAS in the National Airspace System (NAS), and for an exemption

from the requirements of 14 C.F.R§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

aircraft and its operation, Aerial Image Logistics, LLC operation of the DJI Inspire 1, DJI S900 and DJI F450
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UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part21, Subpart H.

Accordingly, Aerial Image Logistics, LLC 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 

aircraftwith an airworthiness certificate.

Aerial Image Logistics, LLC submits that the requested relief is proper since an equivalent level of safety 

will beensured. Aerial Image Logistics, LLC will perform maintenance, alterations, or preventive 

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

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1, DJI S900, and DJI F450 Instruction

Manual). Furthermore, Aerial Image Logistics, LLC will document and maintain all maintenance records 

for the DJI Inspire 1, DJI S900, and DJI F450 UAS.

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

limitations: Pilot in command, is requested by Aerial Image Logistics, LLC to the extent necessary to 

allow a Pilotin Command (PIC) holding a private pilot or higher level certificate, as well as an airman 

medicalcertificate, and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PICis able to safely operate the DJI Inspire 1, DJI S900, and DJI F450 UAS in a 

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

appropriate distances from people, vessels,vehicles and structures.

Aerial Image Logistics, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because

the DJI Inspire 1, DJI S900, and DJI F450 UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Assuch, Aerial Image Logistics, LLC submits that it will ensure that the 

DJI Inspire 1, DJI S900, and DJI F450 UAS are in a safe condition, priorto every flight, by determining 

that the UAS are in compliance with the operating documents (i.e.,Monthly Maintenance Log, and DJI 

Inspire 1, DJI S900, and DJI F450 Instruction Manual).

Aerial Image Logistics, LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Inspire 1, DJI S900, and DJI F450 UA will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1, DJI S900, and DJI F450 UA 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 Aerial Image Logistics, LLC’s operation ofthe DJI Inspire 1, DJI S900, and DJI 

F450 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level ofsafety equivalent to 

Section 91.121.

Additionally, Aerial Image Logistics, LLC seeks an exemption from the requirements of Section 

91.151(b), entitledFuel requirements for flight in VFR conditions. Aerial Image Logistics, LLC submits that 

safety will not be affected by operation of the DJI Inspire 1, DJI S900, and DJI F450 UA during daylight 

hours in visual meteorological conditions (VMC) under visualflight rules (VFR), all three DJI UA have 

enough battery power to fly for a maximum duration of approximately 7 to15 minutes tothe first point 
7

of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes (or land 

with 25% remaining battery power, whichever occurs first).

In accordance with 14 C.F.R. § 11.81, Aerial Image Logistics, LLC provides the following information in 

support ofits petition for exemption:

A. Name And Address Of The Petitioner.

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

Aerial Image Logistics, LLC

Richard F. Davis

969 Tamarind Way

Boca Raton, Florida 33486

Phone: 561-702-4733

Email:rdthree@bellsouth.net

B. The Specific Sections Of 14 C.F.R. From Which Aerial Image Logistics, LLC Seeks Exemption.

1. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot incommand, 

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

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

an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act as PIC of an aircraft.

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

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Aerial Image Logistics, 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 unless it is in an airworthy condition.

3. Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, inpart:

(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 
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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 ofthe 

departure airport or an appropriate altimeter setting available before 

departure.

4.Aerial Image Logistics, 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 and forecast weather conditions) there is enough fuel to fly to the first pointof

intended landing and, assuming normal cruising speed, to fly after that for at least20 

minutes.

5.Aerial Image Logistics, LLC Seeks Exemption From The Requirement Of Section 91.405(a).

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

owner or operator of an aircraft—

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

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

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

6.Aerial Image Logistics, 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 § 43.7of this 

chapter[.]

7.Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Sections 

91.409(a) (1)And 91.409(a) (2).

Section 91.409, entitled Inspections, subsection (a), states thefollowing:

(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 accordancewith 

part 21 of this chapter.

8.Aerial Image Logistics, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) 
9

And91.417(b).

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

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

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section:

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

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, 

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

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

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 orsafety 

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

recurring action the time and date when the next action isrequired.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for eachmajor 

alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances.

(b) The owner or operator shall retain the following records for the periodsprescribed:

(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 issold.

(3) A list of defects furnished to a registered owner or operator under § 43.11of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

C. The Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image Logistics, LLC

Seeks The Relief.
10

1. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image 

Logistics, LLC Seeks Relief FromSection 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilotin 

command, is requested to the extent necessary to allow a PIC holding a private pilotor 

higher level certificate, as well as a current and valid airman medical certificate, and who 

has met certain flight-hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business oremployment; 

and (2) The aircraft does not carry passengers or property for compensation orhire.

Aerial Image Logistics, LLC submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the DJI Inspire 1, DJI S900, and DJI F450 UAS 

unless that PIC has met certain flight-hour and currency requirements, demonstrating that 

the PIC is able to safely operate any of the DJI 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, Aerial Image Logistics, LLC submits that all flights of the DJI Inspire 1, DJI S900, and 

DJI F450 UAS, conducted by thePIC pursuant to the grant of this Petition: (1) will be 

incidental to Aerial Image Logistics, LLC business; and (2)will not carry passengers or 

property for compensation or hire.

2. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image 

Logistics, LLC Seeks Relief FromSection 91.7(a).

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

required to allow Aerial Image Logistics, LLC to determine that the DJI Inspire 1, DJI S900, and 

DJI F450 are in good operating condition prior to every flight by ensuring that the UAS is in 

compliance with the operatingdocuments (i.e., Monthly Maintenance Log, and DJI Inspire 1, 

DJI S900, and DJI F450 Instruction Manual).

Aerial Image Logistics, LLC seeks the requested relief because the DJI Inspire 1, DJI S900, and 

DJI F450 UAS do not requirean airworthiness certificate in accordance with 14 C.F.R. Part 21, 

SubpartH.

Therefore, Aerial Image Logistics, LLC will ensure that the DJI Inspire 1, DJI S900, and DJI F450 

UAS is in airworthy conditionbased upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, andDJI Inspire 1, DJI S900, and DJI F450 Instruction Manual) prior to 
11

every flight, and further, determine that the aircraft are in condition for safe flight.

3.Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image Logistics, LLC

Seeks Relief From Section91.121.

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

operations of the DJI Inspire 1, DJI S900, and DJI F450 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 theFAA requires 

that any altitude information concerning UAS operations be reported to airtraffic control 

(ATC) in feet above ground level (AGL), Aerial Image Logistics, LLC seeks the requested relief

because the DJI Inspire 1, DJI S900, and DJI F450 UAs’ altimeter may be set on the ground to 

zero feet AGL, rather than the local barometric pressure or field altitude, before eachflight.

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 bemaintained since the DJI 

Inspire 1, DJI S900, and DJI F450 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 UAon the display of 

the GCS.

4.Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image 

Logistics, LLC Seeks Relief FromSection 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, DJI S900, 

and DJI F450 UA during daylight hours in visual meteorological conditions (VMC), under visual 

flightrules (VFR), for a total duration of 7 to 13 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 5 minutes (or land with 25% 

battery power remaining, whichever occurs first). Aerial Image Logistics, LLC seeksthe 

requested relief because without an exemption from Section 91.151(b), the flighttime duration 

of the battery powered DJI Inspire 1, DJI S900, and DJI F450 UA will severely constrain the 

practicalityof any aerial video or still photo flight operations that Aerial Image Logistics, LLC

proposes to conductpursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspire 1, DJI S900, 

and DJI F450 UAS, theDJI Inspire 1 and DJI F50 operating documents, and Aerial Image 

Logistics, LLCs proposed operating limitations, ensure that Aerial Image Logistics, LLC will 

safely operate the battery powered DJI Inspire, DJI S900, and DJI F450 1 UA during daylight 

hoursin visual meteorological conditions (VMC), under visual flight rules (VFR), with enough

battery power to fly for a total duration of 7 to 13 minutes to the first point of intended 

landingand, assuming normal cruising speed, to fly after that for at least 5minutes(or land 

with 25% battery power remaining, whichever occurs first) .
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5. Extent Of Relief Aerial Image Logistics, LLC Seeks And The Reason Aerial Image 

Logistics, LLC Seeks Relief FromSections 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, Aerial Image Logistics, LLC requests relief from 

these Sections because the DJI Inspire 1, DJI S900, and DJI F450 UAS do not require 

airworthiness certificates. As set forthmore fully below, the DJI Inspire 1, DJI S900, and DJI 

F450 UAS meet the conditions of FMRA Section 333 foroperation without an airworthiness 

certificate. Accordingly, Aerial Image Logistics, LLC will perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e.,Monthly Maintenance Log, and DJI Inspire 1, 

DJI S900, and DJI F450 Instruction Manual). Furthermore, Aerial Image Logistics, LLC will 

document and maintain all maintenance records forthe DJI Inspire 1, DJI S900, and DJI F450 

UAS.

D. The Reasons Why Granting Aerial Image Logistics, LLC 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 Aerial Image Logistics, LLC

too safely, efficiently, and economically perform aerial video and photography and for other 

purposes as described in the Summary on Page 4 within this petition for exemption over certain 

areas of the UnitedStates.

Additionally, use of the DJI Inspire 1, DJI S900, and DJI F450 UAS will decrease congestion of the 

NAS, reducepollution, and provide significant benefits to the economy.

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

The DJI Inspire 1, DJI S900, and DJI F450 UA are battery powered and serve as a safe, efficient, 

andeconomical 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, DJI S900, and DJI F450 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 inthe 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, DJI 

S900, and DJI F450 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, andlanding phases of flight operations.
13

E. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1, DJI S900, and DJI 

F450 UAS.

Conducting aerial acquisitions with the DJI Inspire 1, DJI S900, and DJI F450 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, DJI S900, and DJI F450 UAS produce 

no air pollution, and arethe most viable environmentally conscious alternative to the cabin 

class, six cylinderinternal 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, DJI S900, and DJI F450 UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric 

motors, rather than an internal combustion engine.

By using the DJI Inspire 1, DJI S900, and DJI F450 UAS to perform aerial data acquisitions, the 

substantial risk to lifeand property in the air and on the ground, which is usually associated with 

traditionalmanned aircraft flight operations, will be substantially reduced or completely 

eliminated. Asidefrom the lack of flight crew members located onboard the DJI F450, DJI S900, 

and DJI Inspire 1 UA(range in weight from approximately 6 pounds 7.5 ounces for the DJI Inspire 

1 to 3 pounds 8 ounces for the DJI F450, and approximately 18 pounds for the DJI S900, at 

maximum gross weights, 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 approximately3,100 pounds with a wingspan of 

approximately 36 feet, a length of 34 feet, and a fuel capacity of 87gallons).

1.Performing Aerial Video and Photography Operations With The DJI Inspire 1, DJI S900,

and DJI F450 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1, DJI S900, and DJI F450 UAS are also an

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

operation of the DJI Inspire 1, DJI S900, and DJI F450 UAS will allow United States based 

companies, like Aerial Image Logistics, LLC, to remain competitive and contribute to growth of 

the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actionsphasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt newand alternative technology in order to remain 

competitive. Operating the battery poweredDJI Inspire 1, DJI S900, and DJI F450 UAS is one such 

technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without thehigh operational cost of a traditional manned

aircraft.

By operating the DJI Inspire 1, DJI S900, and DJI F450 UAS, companies such as Aerial Image 

Logistics, LLC, can remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute to growth of the 

U.S. economy. Improved financial performance of U.S. companies, through commercial use 
14

of the DJI Inspire 1, DJI S900, and DJI F450 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.

2. There Are No Privacy Issues.

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

Aerial Image Logistics, LLC proposed operation of the DJI Inspire 1, DJI S900, and DJI F450 UAS. 

Specifically, the DJI UAS will be operated only in compliance with operating documents (i.e., 

Monthly Maintenance Log, and DJI UAS Operating Manuals) 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 C.F.R.§ 91.119.

F. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or HowThe 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which Aerial Image Logistics, LLC Seeks Exemption.

1. Reasons Why The DJI Inspire 1, DJI S900, and DJI F450 UAS Meet The Conditions Of 

The FAA Modernizationand Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, Aerial Image Logistics, LLC operation of the DJI Inspire 

1, DJI S900, and DJI F450 UAS meetthe conditions of FMRA Section 333, and will not require 

an airworthiness certificatein accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and 

sets forth requirements for considering whether a UAS will create a hazard to users ofthe 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRASection 

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not laterthan 

180 days after the date of enactment of this Act, the Secretary of Transportationshall 

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

airspace system before completion of the plan and rulemaking required by section332 

of this Act or the 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 aminimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populatedareas, and 

operation within visual line of sight do not create a hazard to users ofthe national 

airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 
15

operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this sectionthat 

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, Aerial Image Logistics, LLC submits that the DJI Inspire 1, DJI S900, and DJI 

F450 UAS can operate safely inthe NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Inspire 1, DJI S900, and DJI F450 UAS; (b) the pilot certification requirement; 

and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1, DJI S900, and DJI F450 UAS Demonstrate Its 

Safe Characteristics.

The DJI Inspire 1, DJI S900, and DJI F450 UAS do not create a hazard to users of the 

NAS or the public,or otherwise pose a threat to national security considering their size, 

weight, speed,and operational capability.

i. Technical Specifications Of The DJI Inspire 1, DJI S900, and DJI F450 UAS.

The technical specifications of the DJI Inspire 1, DJI S900, and DJI F450 UAS are set 

forth by theDJI Inspire 1, DJI S900, and DJI F450 Technical Specifications, attached 

hereto as AppendixA through Appendix P.

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 ofthe DJI 

Inspire 1 UAS is provided at pages 45-50 of the DJI Inspire 1 UserManuals, attached 

hereto as Appendix B.

iii. The DJI Inspire 1, DJI S900 and DJI F450 UAS Are Designed For Automatic 

Return To Home PointOr Hover In The Event Of Loss Of The Control Link Or

Navigation.

When the Control Link is lost, the DJI Inspire 1, DJI S900, and DJI F450 UA will 

remain stationary, in flight, if the DJI UA do not reacquire control link data from 

the GCS, the UAs will assume that the Control Link is lost and the UAs will return to 

the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown.

iv. The DJI Inspire 1, DJI S900, and DJI F450 GCS And Their Operation.
16

A complete description of the operation and specifications of the DJI Inspire1 GCS is 

described in the Inspire 1 User Manual. DJI Inspire 1 User Manual is attached hereto

as Appendix B. A description of the DJI S900 GCS is attached hereto as Appendix G, 

and a description of the DJI F450 GCU is attached hereto as Appendix M.

b. Flight Operations Of The DJI Inspire 1, DJI S900, and DJI F450 UAS Are Limited To 

The Line Of Sight OfA Certificated Pilot in Command With A Safety Observer.

Aerial Image Logistics, LLC will only utilize certificated operators to act as a pilot in 

command (PIC) ofthe DJI UAS. Additionally, when required a safety observer will assist all 

pilots during flighttime.

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

Limitations.

In seeking this exemption, Aerial Image Logistics, LLC proposes to commercially operate 

the DJI Inspire 1, DJI S900, and DJI F450 UAS for the special purpose of conducting aerial 

video and photography as further described in the Summary section of this petition for 

exemption 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 UAS weighing lessthan 55 

pounds maximum gross weight: DJI Inspire 1, DJI S900, and DJI F450 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 and as further described in the 

Summary section on Page 4 of this petition for exemption.

3. The UA may not be flown at an indicated airspeed exceeding 50 knots.

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

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 (FPV) by the PIC or safety observer (SO) isnot 

permitted.

7. All operations will utilize a safety observer (SO) if deemed necessary. The SO may 

be used tosatisfy the VLOS requirement as long as the PIC always maintains VLOS 
17

capability. The SO and PIC must maintain effective communications at all times. The 

PIC must be designated before the flight and cannot transfer his or her designation 

forthe duration of the flight. The PIC must ensure that the SO can performthe 

functions prescribed in the operating documents.

8. The SO will assist the PIC withseeing and avoiding other air traffic and other 

ground based obstacles/obstructions and may also operate the camera or other

instruments when requested by the PIC.

9. 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 affectsthe 

safe operation of the UAS, the aircraft is prohibited from operating untilthe 

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 inthe 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

10. 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 conductsthe 

functional test flight must make an entry in the aircraft records.

11. The pre-flight inspection must account for discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant 

sections of the operating documents.

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

maintenance, overhaul, replacement, inspection, and life limitrequirements.

13. Each UAS operated under this exemption must comply with allmanufacturer

Safety Bulletins.

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

action taken against discrepancies discovered betweeninspections.

15. The PIC must possess at least a Private pilot certificate and at least acurrent 

third- class medical certificate.

16. 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 visualflight rules (SVFR) are not

authorized.

17. 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.
18

18. 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 fromthe 

PIC.

19. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land.

20. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies.

21. 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.

22. 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.

23. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

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

25. The Operator will obtain verbal/written consent of all non-participating persons 

for the planned operation and ensure that only consenting persons will be allowed 

within 100 feet of flight operations, and the radius may be reduced to 30 feet 

based on an equivalent level of safety determination

26. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless, barriers or structures are present that 

sufficiently protect nonparticipating persons from the UA and/or debris in the 

event of an accident, the aircraft is operated near vessels, vehicles or structures 

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

permission( and the PIC has made a safety assessment of the risk), and operations 

nearer to the PIC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a)

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

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any accident that results in injury or property damage will be reported to the FAA 

within 10 days of the accident.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)Would 
19

Not Adversely Affect Safety.

Aerial Image Logistics, LLC 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, 

DJI S900, or DJI F450 UAS unless that PIC has demonstrated that the PIC is able to safely 

operate the DJI Inspire 1, DJI S900, and DJI F450 UAS in a manner consistent withthe 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles andstructures.

Considering Aerial Image Logistics, LLC’s proposed area of operations, and the operating 

limitations setforth- above; the parallel nature of private pilot aeronautical knowledge 

requirements to thoseof commercial pilot requirements (See Exemption No. 11062); and the 

airmanshipskills necessary to safely operate the DJI Inspire 1, DJI S900, and DJI F450 UAS, Aerial 

Image Logistics, LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for Aerial 

Image Logistics, LLC’s specific proposed flightoperations.

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).

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) WouldNot 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Aerial Image Logistics, LLC will ensure that the DJI Inspire 1, DJI S900, and DJI F450 

UAS are in a safe condition to operate based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein.

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

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

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

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 WouldNot 

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, DJI S900, and DJI F450 UA will be provided to the PIC via 

GPSequipment and a radio communications telemetry data link, which downlinks from the UA 

to theGCS for active monitoring of the flight path and altitude. This altitude information,

combined with Aerial Image Logistics, LLC’s operation of the DJI Inspire 1, DJI S900, and DJI F450 

UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 
20

Section 91.121. The altitudeinformation 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, 11112, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11159, 11160,11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) WouldNot 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14C.F.R. 

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

f450(2) the limitations on the proposed flight operations; and (3) the location of the proposed

flight operations. Accordingly, Aerial Image Logistics, LLC will ensure that it will safely operate 

the batterypowered DJI Inspire 1, DJI S900, and DJI F450 UA during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of between 7 to 13 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 5minutes (or land with 25% battery power remaining).

Furthermore, safety will be ensured as the DJI Inspire 1, DJI S900, and DJI F450 UAS provide 

visual warnings to the PIC at the GCS when the UA experiences low battery voltage. At the 

critically low battery level, theDJI Inspire 1, DJI S900, and DJI F450 UAS will descend and land

automatically.

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

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

the UAS are considered. Relief has been granted for manned aircraftto operate at less than 

the minimums prescribed in Section 91.151, including ExemptionNos. 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 thosepresented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064,11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect

Safety.

In seeking this exemption, Aerial Image Logistics, LLC 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 Aerial 

Image Logistics, LLC will use trained technicians or experienced personnel to perform 

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

techniques, and practices prescribed in the operatingdocuments (i.e.,Monthly Maintenance 
21

Log, and the DJI Inspire 1, DJI S900, and DJI F450 Instruction Manual). Furthermore, Aerial Image 

Logistics, LLC will document and maintain allmaintenance records for the DJI Inspire 1, DJI S900, 

and DJI F450 UAS.

Since the DJI Inspire 1, DJI S900, and DJI F450 UAS will be inspected as prescribed by the 

operatingdocuments, Aerial Image Logistics, LLC will maintain the equivalent level of safety 

established by Sections91.405(a), 91.409(a)(1), and 91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because Aerial Image Logistics, 

LLC willperform maintenance, alterations or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level ofsafety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of theDJI Inspire 1, DJI S900, 

and DJI F450 UAS will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Aerial Image Logistics, LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1, DJI S900, and DJI F450 UAS, Aerial 

Image Logistics, LLC submits that safety will notbe adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material 

respects, to those presented herein(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

14 C.F.R. § 21.16 entitled Special Conditions, Aerial Image Logistics, LLC requests that the FAA

prescribe special conditions for the intended operation of the DJI Inspire 1, DJI S900, and DJI 

F450 UAS, which containsuch safety standards that the Administrator finds necessary to 

establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a)& (b), 91.7 (a), 91.109 (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 limitedpurpose of conducting aerial video and photography and as further 

described in the Summary of this petition for exemption over certain areas of the United States

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

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

to national security; and further, provides the authority for such UAS to operate without 
22

airworthiness certification in accordance with any requirements that must be established for 

the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14C.F.R.

§ 21.16, for operation of the DJI Inspire 1, DJI S900, and DJI F450 UAS, since the 

airworthiness regulations of14 C.F.R. Part 21 does not contain adequate or appropriate 

safety standards, due to the novelor unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, statesthe following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

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

propeller, he prescribes special conditions and amendments thereto for theproduct. 

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 theFAA 

finds necessary to establish a level of safety equivalent to that established inthe 

regulations.

See 14 C.F.R. § 21.16.

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

prescribe special conditions for Aerial Image Logistics, LLC intended operation of the DJI 

Inspire 1, DJI S900, and DJI F450 UAS,which contain such safety standards that the 

Administrator finds necessary to establish a levelof safety equivalent to that established by 

14 C.F.R. Part 21, Subpart H, and 14 C.F.RSections 61.113(a) & (b), 91.7(a),91.109 (a),

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b).

G. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

Aerial Image Logistics, LLC Seeks Exemption:

Aerial Image Logistics, LLC seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a),91.109 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Aerial Image Logistics, LLCSeeks:

This exemption will permit Aerial Image Logistics, LLC to commercially operate an Unmanned 

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

operations as described within the Summary on page 4 of this petition for exemption over certain 

areas of the United States.

H. Any Additional Information, Views, Or Arguments Available To Support Aerial Image Logistics, 

LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, Aerial Image Logistics, LLC’s request for exemption may 
23

be grantedpursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth

above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create ahazard 

to users of the NAS or the public, or otherwise pose a threat to national security; andfurther, 

provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Aerial Image Logistics, LLC will operate the DJI Inspire 1, DJI S900, 

and DJI F450 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, Aerial Image Logistics, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and

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

of the DJI Inspire 1, DJI S900, and DJI F450 UAS commercially, without an airworthiness certificate, for 

the limited purposes of conducting aerial video and photography and other operations as described in 

the Summary on page 4 of this petition for exemption over certain areas of the United States. By

granting this Petition, theFAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing 

Aerial Image Logistics, LLC to safely, efficiently, and economically operate the DJI Inspire 1, DJI S900, and 

DJI F450 UAS commercially within theNAS.

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

Reform Act of 2012, Section 333, Aerial Image Logistics, LLC respectfully requests that the 

Administrator grantthis Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a)

& (b), 91.7(a), , 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b),

and permit Aerial Image Logistics, LLC to operate the DJI Inspire 1, DJI S900, and DJI F450 UAS 

commercially for the purpose of conducting aerial video andphotography and other operations as 

described in the Summary on page 4 of this petition for exemption over certain areas of the United

States.

Dated: August 11, 2015

Respectfully submitted,

Richard F. Davis

Richard F. Davis

AERIAL IMAGE LOGISTICS, LLC

969 Tamarind Way

Boca Raton, FL 33486

561-702-4733
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APPENDICES

APPENDIX – A through D: DJI Inspire 1 Documents and Manuals

The following documents and manuals are found at the link below:

1. Appendix A: Quick Start Guide (EN) v1.2

2. Appendix B: DJI Inspire 1 User Manual (EN) v1.4

3. Appendix C: DJI Inspire 1 Safety Guidelines v1.0

4. Appendix D: DJI Inspire 1 Maintenance Manual v1.0

http://www.dji.com/product/inspire-1/download

DJI Inspire 1 Specifications

Model: T600

Weight (Battery Included): 6.5 pounds

Hovering Accuracy (GPS Mode): Vertical 0.5m/Horizontal 2.5m 

Max Ascent Speed: 5 m/s

Max Descent Speed: 4 m/s

Max Speed: 22 m/s (ATTI mode)

Motor Model: DJI 3510

Propeller Model: DJI 1345

Dimensions: 438 x 451 x 301 mm

Approximate Flight Time: 18 minutes
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APPENDIX – E through J DJI S900 Documents and Manuals:

The following documents and manuals are found at the links below:

1. Appendix E: DJI S900 Release Notes

2. Appendix F: DJI S900 User Manual v1.2

http://www.dji.com/product/spreading-wings-s900/download

3. Appendix G: Futaba SG14 2.4 GHz RC control system

http://www.futaba-rc.com/systems/futk9410-14sg/index.html

4. Appendix H: WK-M Quick Start Guide v1.14

http://www.dji.com/product/wookong-m/download

5. Appendix I: A2 Quick Start Guide v1.22

http://www.dji.com/product/a2/download

6. Appendix J: IOSD User Manual v2.10

http://www.dji.com/product/iosd-mark-ii/download

DJI S900 Specifications:

Model: Spreading Wings S900

Weight: 7.3 to 18 (including battery) pounds

Flight Controller: DJI WK-M or DJI A2

Max Ascent Speed: 6 m/s

Max Descent Speed: 2 m/s

Max Speed: 19 m/s

Motor: kV-400 rpm/V

Propeller: 15 x 5.2 inch

Diagonal Wheelbase: 900mm

Approximate Flight Time: 18 minutes

Flight Data/Telemetry: DJI Mark II

RC Controller: Futaba 14SG

Camera/Gimbal: To Be Determined
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APPENDIX – K through P DJI F450 Documents and Manuals:

The following documents and manuals are found at the links below:

1. Appendix K: F450 User Manual v2.0

http://www.dji.com/product/flame-wheel-arf/download

2. Appendix L: E300 Propulsion System User Manual v1.0

http://www.dji.com/product/e300/download

3. Appendix M: DJI DT7 and DR 16 User Manual

http://www.dji.com/product/dt7-dr16-rc-system/download

4. Appendix N: Naza-M V2 Quick Start Manual v1.28

http://www.dji.com/product/naza-m-v2/download

5. Appendix O: iOSD Mini User Manual v1.06

http://www.dji.com/product/iosd-mark-ii/download

6. Appendix P: Flysight Black Pearl Rc801 LCD Monitor

http://3drobotics.com/wp-content/uploads/2014/07/FPV-Black-PearlMonitor.pdf

DJI F450 Specifications:

Model: Flame Wheel 450 (F450)

Takeoff Weight: 1.8 to 3.5 pounds

Diagonal Wheelbase: 500 mm with AIMDROIX extended motor arms

Battery: 3s or 4s LIPO

Motor: DJI E300 Propulsion System/2212-920kV

RC Controller: DJI DT7 and DR 16 RC system

Flight Controller: Naza-M V2

Propeller: DJI 9443 or DJI 9450

Camera/Gimbal: To Be Determined

Flight Data/Telemetry: DJI iOSD

Approximate Fight Time: 12 minutes