UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Sonja Stark of PilotGirl Productions

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 

PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on October 30, 2015

Sonja Stark of PilotGirl Productions

56 Silver Creek Drive

Selkirk, NY 12158

Cell: 518.256.0967

Email: pilot@pilotgirlproductions.com

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TABLE OF CONTENTS

 Page

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

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

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

BACKGROUND............................................................................................................5

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

NAME AND ADDRESS OF PETITIONER................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SONJA STARK OF 

PILOTGIRL PRODUCTIONS SEEKS EXEMPTION...................................7

THE EXTENT OF RELIEF SONJA STARK OF PILOTGIRL PRODUCTIONS 

SEEKS AND THE REASON SHE SEEKS THE RELIEF.............................10

THE REASONS WHY GRANTING SONJA STARK OF PILOTGIRL 

PRODUCTIONS’ REQUEST WOULD BE IN THE PUBLIC INTEREST........ 12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.......................................................................13

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......23

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT SONJA STARK OF PILOTGIRL PRODUCTIONS’ 

REQUEST........................................................................................24

CONCLUSION.............................................................................................................24

APPENDICES............................................................................................25

2
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

Sonja Stark, owner of PilotGirl Productions, 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 (DJI Inspire 1) pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit Sonja Stark of PilotGirl Productions to operate an Unmanned Aircraft System (UAS) for 

commercial purpose of conducting aerial video and photography of businesses, residential and 

commercial real estate, construction sites, civil landscapes and events over certain areas of the 

United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Sonja Stark, owner of PilotGirl Productions, has 25 years of professional experience in the ENG 

(Electronic News Gathering) and Broadcast Industry as an Emmy-award winning videographer 

and editor. She was employed full-time as a news videographer for a CBS news affiliate, 

WRGB-TV6, in Schenectady, NY from 1994-2005. In 2005, she left WRGB-TV6 to pursue a 

freelance career as an independent videographer. Her sole proprietorship business is called 

PilotGirl Productions. She is a longstanding union member of the NABET Local #21(National 

Association of Broadcasters, Electricians and Technicians) and IBEW Local #1212 (Radio and 

Television Broadcast Engineers). In 2013, Sonja Stark of PilotGirl Productions received her 

MWBE (Minority and Women Business Enterprise) certification from the State of New York. 

Her work includes providing clients (state and federal agencies and businesses in the private, 

public and non-profit sectors) with expertise in television production (lighting, audio, video) and 

post-production (editing, graphics and writing). Sonja Stark of PilotGirl Productions has worked 

on thousands of productions over the past 25 years in over 60 countries with a perfect client and 

employee safety record. In the past she has supplied clients with aerial video and photography 

using the services of small fixed gear, retractable and twin commercial aircraft. 

The objective of Sonja Stark of PilotGirl Productions and her Unmanned Aircraft System (DJI 

Inspire 1) aerial operations is to provide a high-quality production opportunity for capturing 

visuals that aid in educating, informing and entertaining the needs of her clients. Creative and 

responsible story-telling, be it for government, commercial, news, real-estate or documentary 

purposes, is imperative in remaining unique in a competitive freelance production industry. Her 

UAS system is especially beneficial for specifically targeting:

• Broadcast news stories

• Television/web commercials

• Educational documentary needs 

• Episodic cable programming 

• Special event coverage

• Private and governmental PSAs 

Sonja Stark of PilotGirl Productions has safely flown the DJI Inspire almost daily for 

approximately 6 months without incident.

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BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Sonja Stark of PilotGirl Productions seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Inspire 1 is a 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 (Model T600) has a maximum gross weight of approximately 

6 pounds 7.5 ounces, while having a length of 17.2 inches, width of 17.7 inches, height of 11.8 

inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 is equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors with a maximum 

flight time of approximately 18 minutes per battery. The DJI Inspire 1 UAS that will be operated 

by Sonja Stark of PilotGirl Productions 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, Sonja Stark of PilotGirl Productions, 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 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, Sonja Stark of PilotGirl Production’s operation of the DJI 

Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

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

Accordingly, Sonja Stark of PilotGirl Productions 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.

Sonja Stark of PilotGirl Productions submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Sonja Stark of PilotGirl Productions will use 

experienced personnel or technicians to 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 Instruction Manual). 

Furthermore, Sonja Stark of PilotGirl Productions will document and maintain all maintenance 

records for the DJI Inspire 1 UAS.

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

and limitations: Pilot in command, is requested by Sonja Stark of PilotGirl Productions to the 

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

certificate, as well as an airwoman 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 UAS in a manner consistent with this exemption, including evasive and emergency 

5
maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Sonja Stark of PilotGirl Productions seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Inspire 1 UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Sonja Stark of PilotGirl Productions 

submits that she will ensure that the DJI Inspire 1 UAS 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 Instruction Manual), and that the aircraft is in a 

condition for safe flight.

Sonja Stark of PilotGirl Productions also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Inspire 1 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 Sonja Stark of PilotGirl Productions’ operation of the DJI 

Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121.

Additionally, Sonja Stark of PilotGirl Productions seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Sonja Stark of 

PilotGirl Productions submits that safety will not be affected by operation of the DJI Inspire 1 UA 

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

with enough battery power to fly for a total duration of approximately 18 minutes. Battery power 

indicators are also able to show exactly how much battery power is left, as well as how much is 

needed to return safely back to the point of take off. 

In accordance with 14 C.F.R. § 11.81, Sonja Stark of PilotGirl Productions 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:

Sonja Stark

Owner of PilotGirl Productions

56 Silver Creek Drive

Selkirk, NY 12158

Tel: 518.256.0967

Email: pilot@pilotgirlproductions.com

6
B. The Specific Sections Of 14 C.F.R. From Which Sonja Stark of PilotGirl Productions 

Seeks Exemption.

1. Sonja Stark of PilotGirl Productions 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. Sonja Stark of PilotGirl Productions 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. Sonja Stark of PilotGirl Productions 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.

7
4. Sonja Stark of PilotGirl Productions 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. Sonja Stark of PilotGirl Productions 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. Sonja Stark of PilotGirl Productions 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. Sonja Stark of PilotGirl Productions 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
8. Sonja Stark of PilotGirl Productions Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b).

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 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.

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C. The Extent Of Relief Sonja Stark of PilotGirl Productions Seeks And The Reason Sonja 

Stark of PilotGirl Productions Seeks The Relief.

1. Extent Of Relief Sonja Stark of PilotGirl Productions Seeks And The Reason Sonja 

Stark of PilotGirl Productions 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, Sonja Stark of PilotGirl Productions submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 

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

the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures.

Further, Sonja Stark of PilotGirl Productions submits that all flights of the DJI Inspire 1 UAS,

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Sonja Stark’s 

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Sonja Stark of PilotGirl Productions Seeks And The Reason Sonja 

Stark of PilotGirl Productions 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 Sonja Stark of PilotGirl Productions to determine that the DJI Inspire 1 UAS is 

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

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Sonja Stark of PilotGirl Productions seeks the requested relief because the DJI Inspire 1 UAS 

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

Therefore, Sonja Stark of PilotGirl Productions will ensure that the DJI Inspire 1 UAS is in 

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

Maintenance Log and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations 

below.

10
3. Extent Of Relief Sonja Stark of PilotGirl Productions Seeks And The Reason Sonja 

Stark of PilotGirl Productions 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 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information from 

the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude 

information concerning UAS operations be reported to air traffic control (ATC) in feet above 

ground level (AGL), Sonja Stark of PilotGirl Productions seeks the requested relief because the 

DJI Inspire 1 UA altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

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

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

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

DJI Inspire 1 UA 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 Sonja Stark of PilotGirl Productions Seeks And The Reason Sonja 

Stark of PilotGirl Productions 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 UA during

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a

total duration of 18 minutes. Sonja Stark of PilotGirl Productions seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration

of the battery powered DJI Inspire 1 UA will severely constrain the practicality of any aerial 

video or still photo flight operations that Sonja Stark of PilotGirl Productions proposes to conduct 

pursuant to this Petition.

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

the DJI Inspire 1 operating documents, and Sonja Stark of Sonja Stark of PilotGirl Productions’ 

proposed operating limitations, ensure that Sonja Stark of PilotGirl Productions will safely 

operate the battery powered DJI Inspire 1 UA during daylight hours in visual meteorological 

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

duration of 18 minutes.

5. Extent Of Relief Sonja Stark of PilotGirl Productions Seeks And The Reason Sonja 

Stark of PilotGirl Productions 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, Sonja Stark of PilotGirl Productions requests 

relief from these Sections because the DJI Inspire 1 UAS does not require an airworthiness 

certificate. As set forth more fully below, the DJI Inspire 1 UAS meets the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Sonja Stark of 

11
PilotGirl Productions will use trained technicians to 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 Instruction 

Manual). 

Furthermore, Sonja Stark of PilotGirl Productions will document and maintain all maintenance 

records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting Sonja Stark of PilotGirl Productions’ 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 Sonja Stark of PilotGirl 

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

news events, businesses, construction sites, real estate, and landscape over certain areas of 

the United States. 

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

pollution, and provide significant benefits to the economy. Notably, the benefits of Sonja Stark’s 

proposed operation of the DJI Inspire 1 UAS will be realized without implicating

any privacy issues.

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

The DJI Inspire 1 UA is battery powered and serves as a safe, efficient, and economical

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

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise

and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. The DJI

Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial video and photography missions would result in fewer aircraft that

must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing

phases of flight operations.

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

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft,

will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the DJI Inspire 1 UAS produces no air pollution, and is the most

viable environmentally conscious alternative to the cabin class, six cylinder internal combustion

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UA, while

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs

are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life

12
and property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing

approximately 6 pounds 7.5 ounces, at its maximum gross weight with a length of 17.3 inches,

widths of 17.7 inches, and with no fuel on board), has less physical potential for collateral

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

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

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

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will 

Benefit The Economy.

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

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

the DJI Inspire 1 UAS will allow United States based companies, like Sonja Stark of PilotGirl 

Productions 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 

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 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 UAS, companies such as Sonja Stark of PilotGirl Productions, 

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 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,

Sonja Stark of PilotGirl Productions proposed operation of the DJI Inspire 1 UAS will not 

implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in 

compliance with operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1 

Instruction Manual), which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the 

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 Sonja Stark of PilotGirl Productions Seeks Exemption.

1. Reasons Why The DJI Inspire 1 UA Meets The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333.

13
In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, Sonja Stark of PilotGirl Productions operation of the DJI 

Inspire 1 UAS meets 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 rule making 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, Sonja Stark of PilotGirl Productions submits that the DJI Inspire 1 

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

characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the

specific operating limitations.

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

The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise 

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

i. Technical Specifications Of The DJI Inspire 1 UAS.

The technical specifications of the DJI Inspire 1 UAS is set forth by the DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Exhibit A.

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

UASs To Remain Within A Defined Operational Area.

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

modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is

provided at pages 12-16 and 45-50 of the DJI Inspire 1 User Manual, attached hereto as Exhibit

B.

iii. The DJI Inspire 1 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 UA will remain stationary, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire control link data

from the GCS, the 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 Inspire 1 UAS are set forth at

pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit B.

iv. The DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1 GCS and

flight control software is provided at pages 40 through 47 of the DJI Inspire 1 User Manual. DJI

Inspire 1 User Manual is attached hereto as Exhibit B.

b. Flight Operations Of DJI Inspire 1 UAS is Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer.

Sonja Stark of PilotGirl Productions will be the only person to act as a pilot in command (PIC) of 

the DJI Inspire 1 UAS. Additionally, a safety observer will assist her at all times during flight 

time.

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

Limitations.

In seeking this exemption, Sonja Stark of PilotGirl Productions proposes to commercially 

operate the DJI Inspire 1 UAS for the special purpose of conducting aerial video and 

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

limitations:

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

described in the operating documents, rotorcraft UASs weighing less than 55 pounds 

maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this grant.

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

purpose of aerial video and photography.

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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 permitted.

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

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and 

PIC must be able to communicate verbally at all times. Electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents. 

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

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

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

operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and

the procedures outlined in the operating documents, the conditions and limitations

contained in the grant of exemption take precedence and must be followed. Otherwise,

the operator must follow the procedures as outlined in its operating documents. The

operator may update or revise its operating documents. It is the operator’s

responsibility to track such revisions and present updated and revised documents to the

Administrator upon request. The operator must also present updated and revised

documents if it petitions for extension or amendment to the grant of exemption. If the

operator determines that any update or revision would affect the basis upon which the

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

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

questions arise regarding updates or revisions to the operating documents.

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

safe flight. If the inspection reveals a condition that affects the safe operation of the

UAS, the aircraft is prohibited from operating until the necessary maintenance has

been performed and the UAS is found to be in a condition for safe flight. The Ground

Control Station must be included in the preflight inspection. All maintenance and

alterations must be properly documented in the aircraft records.

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

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

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

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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 UAS 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 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.

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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 

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

accordance with the operating documents.

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

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

intended landing point and land the UA with 25% battery power remaining.

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

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

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

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

operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

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

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

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

be as large as practicable.

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

control of the UA must comply with the Federal Communications Commission (FCC)

or other appropriate government oversight agency requirements.

28. The 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

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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;

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.

Sonja Stark of PilotGirl Productions 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 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 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Considering Sonja Stark of PilotGirl Productions 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 UAS, Sonja Stark of PilotGirl 

Productions submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Sonja Stark of 

PilotGirl Productions 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).

Sonja Stark of PilotGirl Productions will not allow any PIC to operate the DJI Inspire 1 UAS 

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

Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

19
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 Sonja Stark of PilotGirl Productions 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 flighthour 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. 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, Sonja Stark of PilotGirl Productions will ensure safe operations by not allowing any 

PIC to operate the DJI Inspire 1 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 

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

20
prior to every flight, Sonja Stark of PilotGirl Productions will ensure that the DJI Inspire 1 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 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

Sonja Stark of PilotGirl Productions operation of the DJI Inspire 1 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 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)

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 UAS;

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

operations. Accordingly, Sonja Stark of PilotGirl Productions will ensure that it will safely operate 

the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 18 minutes. 

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

21
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).

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, Sonja Stark of PilotGirl Productions 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

Sonja Stark of PilotGirl Productions will use trained technicians to 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 Instruction Manual). Furthermore, Sonja Stark of PilotGirl Productions will document and 

maintain all maintenance records for the DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents,

Sonja Stark of PilotGirl Productions 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 User Manual is 

attached hereto as Exhibit B; a copy of the DJI Inspire 1 UAS Maintenance Log is attached 

hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Sonja Stark of PilotGirl 

Productions 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 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 Sonja Stark of PilotGirl Productions proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Inspire 1 UAS, Sonja Stark of 

PilotGirl Productions submits that safety will not be 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 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).

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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, Sonja Stark of PilotGirl Productions 

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

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 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.

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 Sonja Stark of PilotGirl Productions intended operation of the 

DJI Inspire 1 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 Sonja Stark of PilotGirl Productions Seeks Exemption:

Sonja Stark of PilotGirl Productions 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 Sonja Stark of PilotGirl 

Productions Seeks:

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This exemption will permit Sonja Stark of PilotGirl Productions 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 Sonja Stark of 

PilotGirl Productions 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, Sonja Stark of PilotGirl Productions 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 an airworthiness certification.

As discussed in detail above, Sonja Stark of PilotGirl Productions will operate the DJI 

Inspire 1 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, Sonja Stark of PilotGirl Productions 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 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 Sonja Stark of PilotGirl Productions to safely, 

efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Sonja Stark of PilotGirl Productions 

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 Sonja Stark of PilotGirl 

Productions to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States.

Dated: October 30, 2015

Respectfully submitted,

Sonja Stark 

PilotGirl Productions 

24
Appendices:

A – DJI Inspire 1 Specifications Data Sheet

B – DJI Inspire 1 Manufacturer’s User Manual

C – Monthly Maintenance Log

APPENDIX – A

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Sonja Stark of PilotGirl Productions only utilizes safe and reliable UASs. DJI is an industry 

leader in small UAS production. DJI UASs are loaded with ground breaking software enabling 

the user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

to a predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices).

1.1 DJI Inspire 1

1.1.1 Aircraft

1.1.1.1 Model – T600

1.1.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

1.1.1.3 Hover Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

1.1.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s

1.1.1.5 Max Tilt Angle - 350

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 4m/s

1.1.1.8 Max Flight Speed – 22m/s (ATTI mode, no wind)

1.1.1.9 Max Flight Altitude – 4500m

1.1.1.10 Max Wind Resistance – 10m/s

1.1.1.11 Max Flight Time – Approximately 18 minutes

1.1.1.12 Motor Model – DJI 3510

1.1.1.13 Propeller Model – DJI 1345

1.1.1.14 Operating Temperature Range - 140F to 1040F (-100C to 400C)

1.1.1.15 Dimensions - 171⁄4” x 17 3⁄4” x 12”

1.1.2 Gimbal

1.1.2.1 Model – Zenmuse X3

1.1.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

1.1.2.3 Operating Current – Static: 750mA; In Motion: 900mA

1.1.2.4 Angular Vibration Range - ±0.030

1.1.2.5 Mounting – Detachable 

1.1.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

1.1.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

1.1.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

1.1.3 Camera

1.1.3.1 Name – X3

1.1.3.2 Model – FC350

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1.1.3.3 Total Pixels – 12.76M

1.1.3.4 Effective Pixels – 12.4M

1.1.3.5 Image Max Size – 4000x3000

1.1.3.6 ISO Range – 100-3200

1.1.3.7 Field of View - 940

1.1.3.8 CMOS – Sony EXMOR 1/2.3”

1.1.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:

1280x720p24/25/30/48/50/60

1.1.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.1.4 Remote Controller

1.1.4.1 Name – C1

1.1.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

1.1.4.3 Communicating Distance (unobstructed) – 2000m

1.1.4.4 Output Power – 9W

1.1.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C)

1.1.4.6 Battery – 600mAh LiPo 2S

1.1.5 Intelligent Flight Battery (Model: TB47)

1.1.5.1 Capacity – 4500mAh

1.1.5.2 Voltage – 22.2V

1.1.5.3 Battery Type – LiPo 6S High voltage battery

1.1.5.4 Energy – 99.9Wh

1.1.5.5 Net Weight – 570g

1.1.5.6 Operating Temp - 140F to 1040F (-100C to 400C)

1.1.5.7 Max Charging Power – 180W

1.1.6 Intelligent Flight Battery (Model: TB48)

1.1.6.1 Capacity – 5700mAh

1.1.6.2 Voltage – 22.8V

1.1.6.3 Battery Type – LiPo 6S High voltage battery

1.1.6.4 Energy – 129.6Wh

1.1.6.5 Net Weight – 670g

1.1.6.6 Operating Temp - 140F to 1040F (-100C to 400C)

1.1.6.7 Max Charging Power – 180W

APPENDIX – B

DJI Inspire 1 Manufacturer’s User Manual (Please see attachment)

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APPENDIX - C

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