IN FLIGHT 

12534 Valley View St. #144 

Garden Grove, CA. 92845 

April 30, 2015 

U.S. Department of Transportation, 

Docket Management Systems, 

1200 New Jersey Avenue SE, 

Washington, DC 20590 

RE: Section 333 Petition for Exemption 14 CFR § 11.81 

 Electronic Submittal – Via FDMS Website 

Dear Sir or Madam, 

This letter serves as a petition for exemption from specific rules contained in Title 14 of 

the Code of Federal Regulations (14CFR), with regards to operation of a small, 

unmanned aircraft (sUAS) to allow In Flight commercial operation in the industries 

listed below. 

The requested exemption would permit In Flight to pursue its commercial interests in 

providing services to clients using small advanced sUAS with a focus on the following 

areas of interest; 

• Oil and Gas Infrastructure Monitoring and Inspection Services 

• Aerial Surveying 

• Industrial Facility Inspections 

• Conservation Reviews 

• General Video and Photography assignments 

• Inspection of Wind and Solar power generation 

• Inspection of Telecom structures 

• Amusement park rides 

• Search and Rescue Operations in cases of emergency or natural disaster only 

when the local authorities or government has requested 

• Spill response for Oil companies to provide accurate data of incident in real time 

In addition to the waiver authority provided in Section 333 of the Modernization Act, the 

FAA may grant an exemption under 49 U.S.C. Section 44701(f) if it has determined that 

such an exemption is in the public interest. 
Each commercial interest has an inherent risk to associated tasks performed by 

personnel. For example; 

 

Wind power generation – Individuals have to rappel each blade to visually inspect. 

This risk of equipment failure is removed with a sUAS providing the visual inspection. 

Oil and Gas – Individuals may have to climb high towers and or equipment to do visual 

inspections. If conducted solo and the individual were to fall or have a medical 

emergency it would be difficult to for Emergency Medical Service personnel to respond. 

 

With our focus on safety we intend to implement all of the Operational Limitations, 

outline in Proposed Part 107 of the Notice of Proposed Rulemaking (NPRM), at a 

minimum. These limitations will ensure the same level of safety offered by the rules for 

which the exemption is sought. By adhering to the Operational Limitations, the proposed 

sUAS operation will minimize risk to the NAS, and to persons and property on the 

ground. 

The Regulations we are requesting exemption from; 

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203(a) & (b) 

14 CFR 91.205(b) 

14 CFR 91.401 – 91.417 

An exemption would allow In Flight to broadly evaluate assets and operations with 

sUAS, resulting in a safer and more efficient inspection and monitoring scheme in the 

resource industries. The grant of an exemption is consistent with Congress’ intent, 

reflected in Section 333 of the FA Modernization and Reform Act of 2012, that safe 

systems be permitted in the national airspace prior to the issuance of final regulations 

governing general use of these items. 

In Flight shall conduct operations with one of the following sUAS: 

 DJI Inspire 1 

 DJI Phantom 

 DJI S-1000 
Furthermore, our commitment to safety is foremost in our operations: 

• Personnel will act as an Observer for 20 assignments and will have 10 hours of 

flight time prior to being given assignments. 

• Each assignment will be accompanied by a pre-flight check list (See Attached). 

• Operators shall wear a highly visible vest with wording on the back that reads; 

“Pilot” 

Do not disturb 

While in flight 

In Conclusion, due to their light weight, sUAS generally pose a significantly low risk to 

people and the property on the ground. The size, weight, speed, and capability of the 

DJI product line will not create a hazard to the users of the NAS or the general public, 

nor will it pose a threat to national security. Granting this request for exemption would 

not adversely affect safety, rather it would give opportunities to reduce risk to the 

personnel of the industries serviced. 

The sUAS’s listed in this request will be registered with the FAA. Upon award of 

exemption, a “blanket” 200-foot Certification of Waiver or Authorization would be 

requested. 

Sincerely, 

Timothy Houston 

Owner, In Flight 

thouston@inflightca.com