John Parisoff

New View LLc

PO Box 285

Helotes TX 78023 

(210) 396-6224 

jpdirtwork@live.com

I formally petition the Federal Aviation Administration (FAA) for an exemption from part 21, 

subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.119 (c) 91.121, 91.151(a), 

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code 

of Federal Regulations (14 CFR). 

Outlined below are the descriptions of the parts, subparts and sections in which I request 

exemptions and my reason for requesting the exemptions. 

Part 21 prescribes the procedural requirements for issuing and changing design approvals, 

productions approvals, airworthiness certificates, and airworthiness approvals. 

Section 45.23(b) prescribes that when marks include only the Roman capital letter “N” and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or 

“provisional,” as applicable. 

Section 61.113(a) and (b) prescribes that— (a) no person who holds a private pilot certificate 

may act as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of 

an aircraft. (b) a private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: 

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

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

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy

condition. 

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes: 

(c) Over other than congested areas. An altitude of 400 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 400 

feet to any person, vessel, vehicle, or structure. 
(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section. Section 91.121 requires, in pertinent part, 

each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is 

set “...to the elevation of the departure airport or an appropriate altimeter setting available before 

departure.” 

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to 

fly after that for at least 30 minutes [emphasis added]. 

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it 

has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. 

registration certificate issued to its owner or, for operation within the United States, the second 

copy of the Aircraft registration Application as provided for in § 47.31(c). Section 91.203(b) 

prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness 

certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that 

aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired 

as prescribed in part 43 of the chapter. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under § 43.7 of the same chapter. 

Section 91.409(a) (2) prescribes, in pertinent part, that no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that— (a) Each registered 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) of the work performed; 

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

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

service. 

(2) Records containing the following information: 

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

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

appliance. 

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

overhauled on a specified time basis. 

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

required by the inspection program under which the aircraft and its appliances are maintained. 

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

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

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

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

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold.

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

shall be retained until the defects are repaired and the aircraft is approved for return to service. 

New View LLC’s exemption requests from the above are detailed below: 

Unmanned Aircraft System: 

New View LLC plans to operate a DJI, Inspire 1, which is comprised of an unmanned aircraft . 

The Inspire 1 is a quad-copter with a gross weight of about 6 pounds. It is equipped with four 

rotors that are driven by electric motors which is powered by batteries. The UA has a maximum 

airspeed of 50 mph. 

New View LLC plans to use this DJI in aerial cinematography and photography on rural ranch 

sites, rural RV resorts, enhancing real-estate listings and other such tasks for businesses in the 

greater San Antonio Texas area which could benefit from an aerial view for their planning of 

future expansions and/or advertising of their products or business. For most businesses and 

realtors in the area, standard aerial photography has been very cost prohibitive. The economic 

impact of being able to assist your business using aerial photography would be substantial. 
The use of this DJI in the above named applications greatly reduces risk to the public and 

property as there is no fuel carried by the Inspire 1, aircraft noise is greatly reduced as opposed 

to a standard aircraft or rotorcraft both of which require numerous passes or extended lengths of 

hover time to accomplish the same task as the Inspire can in only a few minutes. The Inspire 

only weighs about 6 pounds and is by far a much smaller hazard to persons or property than a 

standard aircraft or helicopter in the event of a catastrophic in-flight failure. 

There is no higher priority for New View LLC other than the safety of the public and property. 

New View LLC makes the following representations of its operation in which to abide by to 

ensure these exemptions if granted, will provide a level of safety at least equal to existing rules: 

The Inspire 1 will only be operated by, at a minimum, a private pilot with at least a 3rd class 

airman medical certificate. The PIC will have completed at a minimum, 25 hours of documented 

flight time using the Inspire 1 with focus being: 

a) Collision avoidance 

b) Loss of C2 link procedures as outlined in the Operators manual for the Inspire 1

c) Identification of inflight hazards i.e. aerial wires, birds in the area, changing weather etc. 

d) Estimating distance from objects, persons, vehicles and vessels. 

e) Communication with the spotter(s) 

f) Completed the DJI Inspire 1 pilot training guide maneuvers and skills. (PDF) attached. 

g) The ability to recognize persons or objects that are not part of the intended and permitted part 

of the project that enter the 500 foot operational area unless such persons or objects are deemed 

permitted by the owner or controller of the property or area and the PIC makes a safety

assessment of the risk of operating closer and it does not pose undue or significant risk. 

h) The ability to quickly and safely land the DJI Inspire 1 in the event of intrusion into the safe 

zone. 

1.) A complete pre-flight systematic check by the PIC of the Inspire 1’s physical condition, i.e. 

props, prop guards, landing gear, position indicator lights, battery capacity and overall airframe 

condition. If any of the above are not within the manufacturers minimum standards no flight will 

take place until such time as the issue(s) is repaired to manufacturers standards. 

2.) Written documentation of each physical inspection and repairs if any, by the PIC (pilot in 

command) will be kept with the Inspire and will be on-site and available for review. 

3.) Software in relation to the Inspire operation will be checked for proper function. The most 

current DJI vision APP and the current firmware will be installed to assure the most up to date 

safety features. 

4.) Prior to every flight, the compass on the DJI Inspire 1 will be calibrated as to ensure precision 

location. 

5.) New View LLC will ensure the altimeter setting on the DJI Inspire 1 is that of AGL (above 

ground level) rather than GPS or barometric pressure derived settings. 

6.) Every safety feature offered through the DJI vision APP will be enabled for every flight, 

every time. 

(6) Enable ground station 

(7) Compass calibration 

(8) Low battery auto go home 
(9) Dynamic home point 

(10) Current RTH (return to home) altitude (AGL)

(14) Low battery alarm 

Of particular interest are the following: 

[3] Flight attitude and radar function 

[4] Flight parameters-RTH (return to home) altitude, horizontal distance from home point, 

altitude-vertical distance from home point, speed-horizontal flying speed. 

[6] Flight Battery Level indication 

[7} There is a built in preflight checklist within the DJI vision APP which is completed prior to 

each flight. [8] Aircraft GPS Status-New View LLC’s Inspire 1 will not fly with less than (7) 

GPS Satellites available. 

[14] Hide or show flight parameters- New View LLC’s Inspire 1 will ALWAYS fly with 

parameters displayed in order to assist in maintaining safe distances from persons and objects 

and to adhere to the flight plan. 

8.) New View LLC will operate with a minimum of (1) one, trained spotter for every flight. 

“Trained” meaning familiarization with the DJI Inspire 1, its abilities according to the operators’ 

manual as well as the abilities of PIC. Spotters will participate in documented training developed 

in-house prior to being allowed on the flight line. Training will consist of, at a minimum the 

following: 

a) The ability to roughly identify minimum distance from objects 

b) The ability to quickly recognize unusual flight maneuvers/attitudes of the Inspire 1

c) The ability to communicate with the PIC the visual limitations and to never let the Inspire 1 

out of the visual capabilities of the PIC and the spotter(s). 

d) The ability to recognize persons or objects that are not part of the intended and permitted part 

of the project that enter the 500 foot operational area unless such persons and objects are deemed 

permitted by the owner or controller of the property or area and the PIC makes a safety

assessment of the risk of operating at a closer range and it does not pose undue or significant risk 

to those persons or objects. “ 

e) The ability to accurately describe to the PIC, the orientation of the Inspire in relation to the 

pre-set home point as well as the direction of travel. 

f) The training will take place under strict, safe conditions away from persons or large obstacles. 

I.e. large open fields. 

9.) Prior to each flight, the PIC and the Spotter(s) will perform a pre-flight briefing detailing the 

estimated flight distance, estimated flight level AGL and the goal of the particular flight. Each 

preflight briefing will be documented by the PIC to include flight details, pilot name, spotter(s) 

name, weather details, time and date. 

Written and/or verbal consent will be obtained from the person/business requesting the flight. 

A post-flight briefing will also be conducted and documented with the PIC and the 
The Documented Pre-flight, the raw pictures and/or the raw video footage as well as the postflight brief and written consent will be kept by New View LLC for a period of at least (2) years. 

New View LLC believes that given the size, weight, speed, and limited operating area associated 

with the Inspire 1, requests an exemption from 14 CFR part 21, Subpart H (Airworthiness 

Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and 

limitations, is warranted and meets the requirements for an equivalent level of safety under 14 

CFR part 11 and Section 333 of P.L. 112-95 (Section 333). 

New View LLC requests exemption from § 45.23 Marking of the aircraft. The Inspire 1 does not 

have a cabin, does not have a cockpit or a pilot station. Minimum sized lettering and wording are 

difficult to place on the Inspire 1. New View LLC will however affix a sticker on the unit which 

will contain contact information for the company in case of aircraft loss. 

New View LLC requests an exemption from §§ 91.405(a), 91.407(a) (1), 91.409(a) (2) and 

91.417(a) and (b) Maintenance inspections and feel it should be granted since they only apply to 

aircraft with an airworthiness certificate. New View LLC has developed maintenance inspections 

and documentation methods for the DJI Inspire 1 from personal experience as well as the 

manufacturer’s user manual. 

DJI Pilot in Command (PIC) 

Under § 61.113 (a) and (b) private pilots are limited to non-commercial operations. 

New View LLC will only use, at a minimum a pilot with a private pilot license, current 3rd class 

airmen medical certificate. 

Under current regulations, civil operations for compensation or hire require a PIC holding a 

commercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in 

accordance with pertinent parts of 14 CFR 61.113(a) and (b), a pilot holding a private pilot 

certificate cannot act as a PIC of an aircraft for compensation or hire unless the flight is only

incidental to a business or employment. “However, in Grant of Exemption No. 11062 to 

Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate 

operating the Astraeus DJI would not adversely affect operations in the NAS or present a hazard 

to persons or property on the ground.” New View LLC requests that an exemption allowing a 

private pilot employed by New View LLC be allowed to be the PIC of the Inspire 1 for 

compensation similar to the grant of exemption No.11602 to Astraeus Aerial. 

New View LLC requests relief from § 91.119(c) because the aircraft will be operated at altitudes 

below 400 feet AGL. Section 91.119(c) states that no person may operate an aircraft below the 

following altitudes: over other than congested areas, an altitude of 400 feet above the surface, 

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

operated closer than 500 feet to any person, vessel, vehicle, or structure. New View LLC will 

operate pursuant to the following restrictions related to § 91.119: 

-Operate in reasonably safe environments that are closely monitored by ground assistants and 

signage placed in locations that would be considered reasonable locations for pedestrians, 

vehicles or vessels to enter the area. 

-Within 6 miles of airports and congested areas. Congested areas will be defined by VFR charts 

as well as by contacting the local FSDO (flight standards district office) 
- Conduct all operations under New View LLC’s guidelines contained in the operating 

documents and will analyze flight data and other sources of information such as the 

manufacturer’s website to constantly update and enhance safety. 

-Contact respective airports if operations will be within 6 miles to advise them of estimated flight 

time, flight duration, elevation of flight and other pertinent information deemed important by the 

airport. 

- Always obtain all necessary permissions prior to operation. Permissions include but are not 

limited to a (COA) and a request for a (NOTAM) as well as permission from the property owner 

or person in control of the property and when practical will be in writing and kept on file for 2 

years for review. If it’s not possible to obtain written permission, the PIC will document in 

writing how permission was obtained i.e. phone call with date, time and party information.

New View LLC requests relief from 14 CFR 91.121 Altimeter Settings. New View LLC’s 

Inspire 1 has a barometric altimeter and GPS derived altitude capabilities. The FAA requires any 

altitude reported to ATC to be in feet AGL. New View LLC will set the altimeter on the Inspire 

1 to zero feet AGL rather than local barometric pressure or field altitude before flight. 

New View LLC requests relief from § 91.151(a) Fuel requirements for flight in VFR conditions 

based on the following: 

No fuel is used in the Inspire 1 but it is battery operated. Batteries have, in our experience have 

about 15 minutes of quality flying time. In the interest of safety, New View LLC generally lands 

with 35% of battery remaining which gives about 9 minutes of flying time per battery. The 

Inspire 1 has an audible battery state warning system. New View LLC will always follow the 

manufactures minimum battery warning which is 30% remaining. There is also an onscreen 

warning of not enough battery to return to home message if flight distance has exceeded battery

capacity. In this event, an emergency landing would be made as soon as safe and practical. The 

Inspire 1 also has an automated function which results in immediate landing when a low battery

is detected. Researching previous relief requests, relief has been granted for manned aircraft to 

operate at less than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In 

addition, similar DJI-specific relief has been granted in exemption Nos. 8811, 10808, and 10673 

for daytime, VFR conditions. New View LLC will adhere to all VFR minimums as well as VMC 

conditions when planning and/or executing any flights. There is little purpose for aerial video or 

pictures if the weather is less than desirable. Following VFR minimum standards will at least 

ensure a safe flight. Wind and forecast weather will be a key in deciding suitable conditions. 

Local weather can be attained from the nearest airport by using AWOS. No flight will take place 

in any condition that would potentially be outside of the Inspire 1 capabilities in wind. New 

View LLC will always fly within its 30% minimum remaining battery life at its first intended 

landing point. 

New View LLC will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations. New View LLC will also request a 

Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior 

to the operation. 
If there are any areas that have not been addressed, please contact me for supplemental 

information. 

Sincerely, 

John Parisoff

New View LLC 

PO Box 285

Helotes, TX 78023

(210) 396-6224 

jpdirtwork@live.com