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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Z-DRONES, LLC FOR 

AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS 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 & S1000 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on February 22, 2016 

Jeffrey M. Zita

3023 Harbor Rd.

Douglas, MI 49406 

Tel: (630) 707-4509 
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TABLE OF CONTENTS

Page 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER....................................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Z-DRONES, LLC SEEKS 

EXEMPTION.................................................................8 

THE EXTENT OF RELIEF Z-DRONES, LLC SEEKS AND THE REASON Z-DRONES, 

LLC SEEKS THE RELIEF.........................15

THE REASONS WHY GRANTING Z-DRONES, LLC’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST .........................................................17

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY..........................................................................25

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......31

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT Z-DRONES, LLC’S REQUEST.........31

CONCLUSION................................................................................................................32

APPENDICES.................................................................................................................33
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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

NA National Airspace 

SNA System 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

Z-DRONES, 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 ZDRONES, LLC to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Z-DRONES, LLC, provides its clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. ZDRONES, LLC has been a hobby UAS enthusiast for several years. He also has a 

Mechanical Engineering degree and an entrepreneurial spirit. He also has years 

recreational/hobby experience in all aspects of aerial video and photography. The 

objective of Z-DRONES, LLC’s aerial video and photography operations is to provide 

high quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting: 

Real estate listings posted on the MLS and social media for sale 

Motion Picture Filming 

Aerial acquisitions used for inspections of public and private structures

Increase public knowledge of UAS and promote safe UAS operations
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BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 & DJI S1000

Z-DRONES, LLC seeks an exemption to operate DJI Inspire 1 & DJI S1000 for 

compensation or hire within the NAS. The DJI systems are vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smart phone systems. 

The DJI Inspire 1 & DJI S1000 units that will be operated by Z-DRONES, LLC will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking. 

BASIS FOR PETITION

Petitioner, Z-DRONES, 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 S1000 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). 
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In consideration of the speed, weight, size, and limited operating area associated with 

the unmanned aircraft and its operation, Z-DRONES, LLC’s operation of DJI Inspire 1 & 

DJI S1000 UAS meets the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Z-DRONES, 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 aircraft with an airworthiness certificate. 

Z-DRONES, LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Z-DRONES, LLC will use experienced personnel or technicians 

to perform maintenance, alterations, or preventive maintenance on the UASs using the 

methods, techniques, and practices prescribed in the operating documents (i.e., 

Monthly Maintenance Log, and DJI Inspire 1 & DJI S1000 Instruction Manual). 

Furthermore, Z-DRONES, LLC will document and maintain all maintenance records for 

the DJI Inspire 1 & S1000 UAS. 

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

privileges and limitations: Pilot in command, is requested by Z-DRONES, LLC to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher 

level certificate, as well as an airman medical certificate, and who has demonstrated, by 

meeting minimum flight- hour and currency requirements, that the PIC is able to safely 

operate the DJI Inspire 1 & DJI S1000 l UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 
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Z-DRONES, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 & DJI S1000 UAS do not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. As such, Z-DRONES, LLC submits 

that he will ensure that the DJI Inspire 1 & DJI S1000 UA is in an airworthy condition, 

prior to every flight, by determining that the UAS is in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 & DJI S1000 Instruction 

Manual), and that the aircraft is in a condition for safe flight. 

Z-DRONES, LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 & DJI S1000 UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Inspire 1 & DJI 

S1000 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 ZDRONES, LLC’s operation of the DJI Inspire 1 & DJI S1000 UAS within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, Z-DRONES, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Z-DRONES, LLC

submits that safety will not be affected by operation of the DJI Inspire 1 & S1000 UA 

during daylight hours in visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total duration of approximately 13.5 

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

after that for at least 4.5 minutes. 
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In accordance with 14 C.F.R. § 11.81, Z-DRONES, LLC provides the following 

information in support of its petition for exemption: 

A. Name and Address Of The Petitioner. 

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

Jeffrey M. Zita

3023 Harbor Rd.

Douglas, MI 49406 

Tel: (630) 707-4509

Email: jeff.zita@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Z-DRONES, LLC Seeks 

Exemption. 

1. Z-DRONES, LLC Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

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. Z-DRONES, LLC Seeks Exemption From The Requirements Of Section 91.7(a). 
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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. Z-DRONES, LLC Seeks Exemption From The Requirements Of Section 91.121. 

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

(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 

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 of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Z-DRONES, 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 

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

least 20 minutes. 

5. Z-DRONES, LLC Seeks Exemption From The Requirement Of Section 91.405(a). 
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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. Z-DRONES, 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 § 

43.7 of this chapter[.] 

7. Z-DRONES, 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 the following: (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 accordance 

with part 21 of this chapter. 

8. Z-DRONES, LLC Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 
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Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

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

C. The Extent Of Relief Z-DRONES, LLC Seeks And The Reason Z-DRONES, LLC

Seeks The Relief. 

1. Extent Of Relief Z-DRONES, LLC Seeks And The Reason Z-DRONES, LLC

Seeks Relief From Section 61.113(a) And (b). 

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

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

pilot or 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 or 

employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Z-DRONES, LLC submits that an equivalent level of 
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safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 & 

S1000 UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI Inspire 1 & S1000 

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, Z-DRONES, LLC submits that all flights of the DJI Inspire 1 & S1000 UAS, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to ZDRONES, LLC’s business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Z-DRONES, LLC Seeks And The Reason Z-DRONES, LLC

Seeks Relief From Section 91.7(a). 

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

required to allow Z-DRONES, LLC to determine that the DJI Inspire 1 & S1000 UAS is 

in airworthy condition prior to every flight by ensuring that the UAS is in compliance with 

the operating documents (i.e., the Z-DRONES, LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1 & S1000 Instruction Manual). 

Z-DRONES, LLC seeks the requested relief because the DJI Inspire 1 & S1000 UAS 

does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, Z-DRONES, LLC will ensure that the DJI Inspire 1 & S1000 UAS 

is in airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Inspire 1 & S1000 Instruction Manual) prior to every 

flight, and further, determine that the aircraft are in condition for safe flight, as stated in 

the conditions and limitations below. 

3. Extent Of Relief Z-DRONES, LLC Seeks And The Reason Z-DRONES, LLC

Seeks Relief From Section 91.121. 

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

operations of the DJI Inspire 1 & S1000 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 

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(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), Z-DRONES, 

LLC seeks the requested relief because the DJI Inspire 1 & S1000 UA altimeter may be 

set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since DJI Inspire 1 & S1000 UA is equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Z-DRONES, LLC Seeks And The Reason Z-DRONES, LLC

Seeks Relief From Section 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 & 

S1000 UA during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. ZDRONES, LLC seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Inspire 1 & S1000 UA will 

severely constrain the practicality of any aerial video or still photo flight operations that 

Z-DRONES, LLC proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 

Professinal UAS, the DJI Inspire 1 & S1000 operating documents, and Z-DRONES, 

LLC’s proposed operating limitations, ensure that Z-DRONES, LLC will safely operate 

the battery powered DJI Inspire 1 & S1000 UA during daylight hours in visual 

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

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 
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5. Extent Of Relief Z-DRONES, LLC Seeks And The Reason Z-DRONES, LLC

Seeks Relief From Sections 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, Z-DRONES, LLC requests relief from 

these Sections because the DJI Inspire 1 & S1000 UAS does not require airworthiness 

certificates. As set forth more fully below, the DJI Inspire 1 & S1000 UAS meets the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Z-DRONES, LLC will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the Z-DRONES, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 & S1000 Instruction 

Manual). Furthermore, Z-DRONES, LLC will document and maintain all maintenance 

records for the DJI Inspire 1 & S1000UAS. 

D. The Reasons Why Granting Z-DRONES, LLC’s 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 Z-DRONES, LLC

to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 & S1000 UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of Z-DRONES, LLC’s proposed operation of the DJI Inspire 1 & S1000 UAS will be 

realized without implicating any privacy issues. 

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

The DJI Inspire 1 & S1000 UA are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Inspire 1 & S1000 UAS would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well 

as increase the safety of life and property in the air and on the ground. 
16

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 & S1000 UA do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

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

takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 & 

S1000 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 & S1000 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 & S1000 UAS produce no 

air pollution, and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial 

video and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The DJI Inspire 1 & S1000 UA, while reducing the carbon footprint of aerial 

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

electric motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 & S1000 UAS to perform aerial acquisitions, the substantial 

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

traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Inspire 1 & S1000 UA, has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned aircraft that typically 

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

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

3. Performing Aerial Video and Photography Operations With The DJI 

Inspire 1 & S1000 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Inspire 1 & S1000 UAS is also an 

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

such, operation of the DJI Inspire 1 & S1000 UAS will allow United States based 

companies, like Z-DRONES, LLC, to remain competitive and contribute to growth of the 
17

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

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI Inspire 1 & S1000 UAS is one 

such technology that not only allows companies greater operational flexibility compared 

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

traditional manned aircraft. 

By operating the DJI Inspire 1 & S1000 UAS, companies such as Z-DRONES, 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 

of the DJI Inspire 1 & S1000 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. 

4. There Are No Privacy Issues. 

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

decades, Z-DRONES, LLC’s proposed operation of the DJI Inspire 1 & S1000 

UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 & S1000 UAS 

will be operated only in compliance with operating documents (i.e., the Z-DRONES, LLC

Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 & S1000 

Instruction Manual) 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. 

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

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Z-DRONES, LLC Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 & S1000 UA Meet The Conditions Of The 

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

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

the unmanned aircraft and its operation, Z-DRONES, LLC’s operation of the DJI Inspire 
18

1 & S1000 UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

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 

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

FMRA Section 333 states the following, in part: 

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

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan and 

rulemaking required by section 332 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 a minimum-- 

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

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a 

hazard to users of the 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 operation of unmanned aircraft systems identified 

under paragraph (1). 

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

section that 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, Z-DRONES, LLC submits that the DJI Inspire 1 & S1000 

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 

by: (a) the characteristics of the DJI Inspire 1 & S1000 UASs; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 
19

a. The Specifications Of The DJI Inspire 1 & S1000 UAS Demonstrate Its 

Safe Characteristics. 

The DJI Inspire 1 & S1000 UAS do not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 

i. Technical Specifications Of The DJI Inspire 1 & S1000 UAS. 

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 

Specifications and Data Sheet, attached here to as Exhibit A and B. 

ii. The DJI Inspire 1 & S1000 UAS Autonomous Flight And Navigation 

Modes Enable The UAS To Remain Within A Defined Operational 

Area. 

The DJI Inspire 1 & S1000 UAS may be operated in both manual and fully autonomous 

flight modes. A complete description of the flight and navigational modes of the DJI 

Inspire 1 & S1000 UAS is provided at pages 25-35 of the DJI Phantom 3 User Manuals, 

attached hereto as Exhibit C and D. 

iii. The DJI Inspire 1 & S1000 UAS Is Designed For Automatic Return 

To Home Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation. 

When the Control Link is lost, the DJI Inspire 1 & S1000 UA will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 & S1000 UA do not 

reacquire control link data from the GCS, the UA will assume that the Control Link is lost 

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

descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set forth 

at pages 27 through 29 User Manuals, attached hereto as Exhibit C and D. 

iv. The DJI Inspire 1 & S1000 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Inspire 1 & S1000 

GCS and flight control software is provided at pages 32 through 43 of the User Manual 
20

1 User Manual. DJI Inspire 1 & S1000 User Manual is attached hereto as Exhibit C. 

b. Flight Operations Of DJI Inspire 1 & S1000 UAS Is Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer. 

Z-DRONES, LLC will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 & 

S1000 UAS. Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of DJI Inspire 1 & S1000 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, Z-DRONES, LLC proposes to commercially operate DJI 

Inspire 1 & S1000 UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UAS weighing less than 

55 pounds maximum gross weight: DJI Inspire 1 & S1000 Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will require a new petition or 

a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 500 feet above 

ground level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UA 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) is not 
21

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The PIC 

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

for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in the 
22

aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

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

sections of the operating documents. 

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

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

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

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the exemption. However, training operations may only be 
23

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. The 

letter of agreement with the airport management must be made available to the 

Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a 

pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice to 

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours 
24

prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the UAS 

is operating. These documents must be made available to the Administrator or 

any law enforcement official upon request. 

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

operations and activities at all times. 

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

31. 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: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

b. 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 of operating closer to 

those objects and determined that it does not present an undue hazard, and; 
25

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

32. 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. 

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov . 

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

(b) Would Not Adversely Affect Safety. 

Z-DRONES, 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 & S1000 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 & S1000 UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering Z-DRONES, LLC’s proposed area of operations, and the operating 

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

requirements to those of commercial pilot requirements (See Exemption No. 11062); 

and the airmanship skills necessary to safely operate the DJI Inspire 1 & S1000 UAS, ZDRONES, LLC submits that the additional manned airmanship experience of a 

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

Z-DRONES, LLC’s specific proposed flight operations. 

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). 
26

Z-DRONES, LLC will not allow any PIC to operate the DJI Inspire 1 & S1000 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

DJI Inspire 1 & S1000 UAS training and currency requirements, that the PIC is able to 

safely operate the DJI Inspire 1 & S1000 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 

14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 

5 hours of those hours as a UAS pilot operating the same make and model of UAS to 

be used for operations under the exemption). In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience 

that was obtained in compliance with applicable regulations will ensure an equivalent 

level of safety during Z-DRONES, LLC’s proposed operations. The Administrator has 

held that prior documented flight experience that was obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS 

pilot operating the same make and model of UAS to be used for operations under 

the exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model 

time may be included in the 10 hours of multi-rotor time and the 10 hours may be 

included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed 

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this requirement. 
27

Training, proficiency, and experience-building flights can also be conducted 

under the grant of exemption to accomplish the required flight time. During 

training, proficiency, and experience-building flights the PIC is required to 

operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. Accordingly, Z-DRONES, LLC will ensure safe 

operations by not allowing any PIC to operate the DJI Inspire 1 & S1000 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the DJI Inspire 1 & S1000 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

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

Would Not Adversely Affect Safety. 

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

prior to every flight, Z-DRONES, LLC will ensure that the DJI Inspire 1 & S1000 UAS is 

in an airworthy condition 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 

Would Not 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 & S1000 UA will be provided to the PIC via 

GPS equipment and a radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Z-DRONES, LLC’s operation of the DJI Inspire 1 & S1000 

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

equivalent to Section 91.121. The altitude information will be generated by GPS

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UASs at ground level. 
28

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) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 

1 & S1000 UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, Z-DRONES, LLC will ensure that 

it will safely operate the battery powered DJI Inspire 1 & S1000 UA during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 

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

after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 & 

S1000 UAS; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 & S1000 

UAS provide audible and visual warnings to the PIC at the GCS when the UA 

experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. At 

the critically low battery level, the DJI 3 Professional UAS will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 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 those presented 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). 
29

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, Z-DRONES, 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 Z-DRONES, LLC will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Z-DRONES, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 & S1000 Instruction 

Manual). Furthermore, Z-DRONES, LLC will document and maintain all maintenance 

records for the DJI Inspire 1 & S1000 UAS. 

Since the DJI Inspire 1 & S1000 UAS will be inspected as prescribed by the operating 

documents, Z-DRONES, LLC will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1 & S1000 

User Manual are attached hereto as Exhibit C; a copy of the DJI Inspire 1 & S1000 UAS 

Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Z-DRONES, 

LLC will use trained technicians to perform 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 of safety established by Sections 91.407, 91.417(a) and 91.417(b), 

because all maintenance of the DJI Inspire 1 & S1000 UAS will be performed by trained 

technicians. Maintenance 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 Z-DRONES, LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 & S1000 UAS, Z-DRONES, 

LLC submits that safety will not be adversely affected by granting exemption from 14 
30

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 relief 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). 

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, Z-DRONES, LLC requests 

that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 

& S1000 UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety 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), 91.121, 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 UA for the limited purpose of conducting aerial video and 

photography 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 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 14 C.F.R. § 

21.16, for operation of the DJI Inspire 1 & S1000 UAS, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety 

standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the 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 

the product. 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 the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 
31

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

C.F.R. § 21.16, the FAA may prescribe special conditions for Z-DRONES, LLC’s 

intended operation of the DJI Inspire 1 & S1000 UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent 

to that established by 14 C.F.R. Part 21, Subpart H, and 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). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Z-DRONES, LLC Seeks Exemption: 

Z-DRONES, LLC seeks 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). 

A Brief Description Of The Nature Of The Exemption Z-DRONES, LLC

Seeks: 

This exemption will permit Z-DRONES, LLC to commercially operate an 

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

photography over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support ZDRONES, 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, Brian P. Sciezka’s request for 

exemption may be granted pursuant 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 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 

airworthiness certification. 

As discussed in detail above, Z-DRONES, LLC will operate the DJI Inspire 1 & S1000 

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or 
32

otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, Z-DRONES, 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 & S1000 UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 

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 ZDRONES, LLC to safely, efficiently, and economically operate the DJI Inspire 1 & 

S1000 UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Z-DRONES, LLC respectfully 

requests that the Administrator grant this 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 ZDRONES, LLC to operate the DJI Inspire 1 & S1000 UAS commercially for the purpose 

of conducting aerial video and photography over certain areas of the United States. 

Dated: February 22, 2016 

Respectfully submitted, 

Z-DRONES, LLC

 Jeff Zita 

Jeffrey M. Zita

3023 Harbor Rd.

Douglas, MI 49406 

Tel: (630) 707-4509

Email: jeff.zita@gmail.com
33

A – DJI Inspire 1 Manufacturer’s User Manual

B – DJI S1000 Manufacturer’s User Manual 

C – Monthly Maintenance Log 
34

APPENDIX – C

MONTHLY MAINTENANCE LOG

Month _______________ YEAR_____________