**SUMMARY**

Darryl J. Rasmussen, owner of Magpie Wings 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), 91.40 9 (a)(1) & (a)(2), and 91.417 (a) & (b), to operate an Unmanned Aircraft System (UAS) , specifically the DJI Inspire 1, pursuant to Section 333 of the FAA Modernization and Reform Act of 2015 (FMRA). This exemption will permit Magpie Wings (MW) to operate a UAS for the commercial purpose of conducting aerial video and photogra phy over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**
Darryl J. Rasmussen holds an Airline Transport Pilot Multi Engine Land pilot rating along with a Commercial and Instrument Rotorcraft pilot rating with a Sikorsky SK

- 65 type rating , and a Class III Medical Certificate . He has logged 40+ years of military and civilian aviation professional pilot experience and now desires to provide high quality imaging for a variety of commercial and public uses in the following areas:

 Educational videos

 Workplace safety

 Sporting and other outdoor events

 Construction documentation

 Real estate evaluation and advertising

 Property aerial survey

**BACKGROUND**

**Unmanned Aircraft System: DJI Inspire 1** 

Magpie Win gs LLC seeks an exemption to operate a DJI Inspire 1 UAS for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sys tems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, a width of 17.7 inches, a height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1 is equipped with four main rotors; drive n by lithium polymer, battery powered electric motors.**BASIS FOR PETITION**

Petitioner, Darryl J. Rasmussen of Magpie Wings LLC
, pursuant to the provisions of the Federal Aviation Regulations (14 C. F. R. § 11.61) and the FAA Mo d ernization and R eform Act of 2015 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems
, hereby petitio ns the Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspace System (NAS) and for an exemption from the requirements set forth in 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, Magpie Wings’ operation of the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefor e will not require an airworthiness certificate in accordance with 14 C. F. R. Part 21, Subpart H.

Accordingly, Magpie Wings 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 apply to aircraft required to possess an airworthiness certificate.

Magpie Wings LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. Magpie Wings will use ex perienced personnel or technicians to perform maintenance, alterations, or preventative maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents such as the DJI monthly maintenance log and the DJI Inspire 1 Maintenance Manual.

Magpie Wings LLC seeks an exemption from the requirements of Section 91.121, entitled Altimeter Setting, since the DJI Inspire 1 will not have a barometric altimeter onboard. Altitude information for the DJI Inspire 1 UA will be p rovided to the pilot via Global Positioning System (GPS) equipment and radio communications telemetry data link, which links from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with the operation of the UA within line

- of

- sight at all times, at or below 500 feet above ground level, will ensure a level of safety equivalent to Section 91.1.

Magpie Wings LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . Magpie Wings submits that safety will not be adversely affected by operation of the DJI Inspire 1 UA during daylight hours in visual meteorological (VMC) under visual flight rules (VFR, with enough battery power to fly for a total durat ion of approximate ly 13.5 minutes to the first point of intended orbit/landing and, assuming normal cruising speed, to fly for at least another 4.5 minutes.

In accordance with 14 C. F. R. § 11.81, Magpie Wings LLC provides the following information i n support of the petition for exemption:**A. The name and address of the petitioner is**  :
Darryl J. Rasmussen

Magpie Wings LLC

135 Seneca School Road

Harmony, PA 16037

Email: Magpie.Wings@zoominternet.net

**a. The specific sections of 14 C. F. R. from which Da**  **rryl J. Rasmussen seeks exemption.** 

**1. Darryl J. Rasmussen seeks exe**  **mption from the requirements of**  **Section 61.113(a) and (b).**

Section 61.113, entitled Private Pilot privileges and limitation : 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 th at business or employment; and (2) The aircraft does not c arry passengers or property for compensation or hire.

**2. Darryl J. Rasmussen seeks exemption from the requirements**  **of Section 91.7(a)**

Section 91.7, entitled Civil Aircraft Airworthiness, S ubsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an

airworthy condition.**3. Darryl J. Rasmussen seeks exemption from the requirements**  **of Section 91.121.**

Section 91.121, entitled Altimeter Settings, subsection 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 altime ter 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. Darryl J. Rasmussen seeks exemption from**  **the requirements**  **of Section 91.15 1**  **(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 f orecast 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. **Darryl J. Rasmussen seeks exemption from the requirements o**  **f 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. Darryl J. Rasmussen seeks exemption from the**  **requirements of Section 91.407**  **(a) (1)** 

Section 91.407 entitled Operation after maintenance, preventative maintenance, rebuilding, or alteration , subsection (a)(1) states the following **:**
(a) No person may operate any aircraft that has undergone maintenance, preventive
ma intenance, rebuilding, or alteration unless

—(1) It has been approved for return to service by a person authorized under §43.7 of this chapter[.]

**7. Darryl J. Rasmussen seeks exemption from the**  **requirements**

**of Section 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 annua l 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 ch apter.

**8**

. **Darryl J. Ra sm**  **ussen seeks exemption from the requirements of Section 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, preven tive 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 r ecords 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

- lim ited 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 require d 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 numbe r 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 instal led 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 supersed ed by other work or for 1 y ear 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 Darryl J.**  **Rasmussen seeks and the reason(s) for seeking relief.** 

1. **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 PI C of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. As set forth more fully below, Darry l J. Rasmussen submits that an equivalent level of safet y will be maintained because no PIC will be allowed to operate the DJ I Inspire 1 unless that PI C has met certain flight

- hour and curren t requirements, demonstrating that the PIC is able to safel y operate either the DJ I Inspire 1 in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintaining approp riate distances from people, vessels, vehicles and structures. Further, Darry l J. Rasmussen submits that all flights of the DJ I Inspire 1 conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to Darryl J. Rasmussen’s business; and (2) will not carry passengers or propert y for compensation or hire.

**2**

. **Section 91.7(a)** . Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Darryl J. Rasmussen to determine that the DJ I Inspire 1 are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Lo g and DJ I Inspire 1 manuals. Darry l J. Rasmussen seeks the requested relief because the DJ I Inspire 1 does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Darry l J. Rasmussen will ensure that the DJ I Ins pire 1 is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I In spire 1 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**

. **Section 91.121** . Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJ I Inspire 1 UAS , which utilize s a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitudeinformation from the UA to the PI C 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), Darry l J. Rasmussen seeks the requested relief because the DJII nspire 1’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Consider ing the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to compl y with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safet y will be ma intained since the DJ I Inspire 1 is equipped with a barometric pressure sensor and GPS equipment, which automaticall y 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**

. **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 DJ I Inspire 1 during day light hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 2.5 minutes. Darryl J. Rasmusse n seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJ I Inspire 1 will severel y constrain the practicality of any aerial video or still photo flight operations that Darry l J. Ras mussen proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJ I Inspire 1 operating documents and Darry l J. Rasmussen’s proposed operating limitations, ensure that Darry l J. Rasmussen will sa fel y operate the battery powered DJ I Inspire 1 during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 12 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 2.5 minutes.

**5**

. **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, Darry l J. Rasmussen requests relief from these Sections because the DJ I Inspire 1 does not require airworthiness certificates. As set forth more full y below, the DJ I Inspire 1 meets the conditions of FMRA Sectio n 333 for operation without an airworthiness certificate. Accordingl y, Darr yl J. Rasmussen will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Aerial Operations Manual, Monthly

Maintenance Log, and DJ I Inspire 1 Instruction Manual). Furthermore, Darry l J. Rasmussen will document and maintain all maintenance records for DJ I Inspire 1.

**D. The reasons why g ranting**  **Darryl J. Rasmussen ’s**  **request would be in t he**  **public i**  **nterest**

.
1. Granting the present Petition will further the public interest by allowing Darry l J. Rasmussen to safel y, efficiently, and economically perform aerial video and photograph y of construction sites, real estate, and landscape over certain areas of the United States. Additionally
, use of the DJ I Inspire 1 will decrease congestion of the NAS, reduce pollution, and providesignificant benefits to the econom y. Notabl y, the benefits of Darry l J. Rasmussen’s proposed

operation of the DJ I Inspire 1 will be realized without i mplicating an y privacy issues.

1

. The DJ I Inspire 1 is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally util ized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of the DJ I Inspire 1 would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as wel l as increase the safet y of life and propert y in the air and on the ground

. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJ I Inspire 1 does not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arr ival, and landing phases of flight operations.

**2** . The Public Will Benefit From The Safet y And Efficiency Of The DJ I In spire 1. Conducting aerial acquisitions with the DJII nspire 1 instead of manned aircraft, will greatl y benefit the public b y 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 DJ I Inspire 1 produces no air pollution, and is the most viable environmental ly

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty

picall y utilized for aerial video and photograph y while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJII nspire 1, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA's are propelled b y battery powered electric motors, rather than an internal combustion engine. By using the DJ I Inspire 1 to perform aerial acquisitions, the s ubstantial 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 DJ I Inspire 1 (weighing approximately 6 pounds 5 ounces at their maximum gross weights (and with no fuel on board) has less ph ys ical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty

picall y conduct similar operations (weighing approximately 6,000 pounds, and a fuel capacit y of 180 gallons).

**3** . P erforming aerial video and photograph y operations with the DJII nspire 1 will benefit the e conom y. In addition to being safe and efficient, the DJII nspire 1 is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 will allow United States based companies, like Darry l J. Rasmussen’s to remain competitive and contribute to growth of the U.S. economy . Specificall y, with the rising cost of aviation fue l and the environmental regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adop t new and alternative technology in order to remain competitive. Operating the battery powered DJ I Inspire 1 is one such technology that not only allows c ompanies greater operational flexibility compared to manned aircraft, but provides such flexibility wi thout the high operational cost of a traditional manned aircraft. By operating the DJ I Inspire 1, companies such as Darryl J. Rasmussen’s can remain competitive and profitable andtherefore, provide greater job stability to employ ees and contractors, which will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the DJ I Inspire 1, provides a stable workforce that increases consumer spending, improves local, state, and federal tax r evenues and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

**4**

. Privacy

I ssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Darryl J. Rasmussen’s proposed operation of the DJ I Inspire 1 will not implicate any

privacy issues. Specificall y, the DJII nspire 1 will be operated onl y in comp liance with operating documents (i.e. Aerial Operations Manual, Monthly Maintenance Lo g, and the DJ I Inspire 1 Instruction Manual's) which require property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude require ments of 14 C.F. R. § 91.119.

**E. Th**  **e reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of s**  **afe ty at least equal to that provided by the rule from** 

**w hich**  **Darryl J. Rasmussen seeks e**  **xemption.**

1. Reasons wh y the DJ I Inspire 1 meet’ s 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, Darry l J. Rasmussen’s operation of the DJ I Inspire 1 meet s 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

r equirements 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 requ irement of this subtitle, and not later than 180 day s after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft s ys tems may operate safel y in the national airspace sy stem before completion of the plan and rulemaking required b y section 332 of this Act or the guidance required b y section 334 of this Act.
(b) Assessment of Unmanned Aircraft S ys tems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) w hich t ypes of unmanned aircraft s ys tems, 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 sy stem 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, isrequired for the operation of unmann ed aircraft sy stems identified under paragraph (1). 20
(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft s ys tems may operate safel y in the national airspace sy stem, the Secretary shall esta blish requirements for the safe operation of such aircraft s ys tems in the national airspace s ystem. In seeking this exemption, Darryl J. Rasmussen submits that the DJII nspire 1 can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Inspire 1; (b) the pilot certification requirement; and (c) the specific operating limitations.
a. The specifications of the DJ I Inspire 1 demonstrates its safe c haracteristics. The DJII nspire 1 does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability

. i. Technical Specifications Of The DJ I Inspire 1 The technical specifications of the DJ I Inspire 1 are set forth by the DJII nspire 1 Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJ I Inspire 1 Autonomous Flight And Navigation Modes Enable The UAS's To Remain Wi thin A Defined Operational Area. The DJ I Inspire 1 may be operated in both manual and full y autonomous flight modes. The DJI Inspire 1 may

be operated in manual flight mode only . A complete description of the flight and navigational modes of the DJ I Inspir e 1 is provided at pages 12

- 33 of the DJ I Inspire 1 User Manuals, attached hereto as Exhibit A.

iii. The DJII nspire 1 Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

iv. When the Control L in k is lost, the DJII nspire 1 will remain stationary in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 due not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJ I In spire 1 are set forth at pages 10 through 17 of the DJ I Inspire 1 User Manuals, attached heret o as Exhibit A.

v. The DJ I Inspire 1 GCS And I ts Operation. A complete description of the operation and specifications of the DJ I Inspire 1 GCS and flight control software is provided at pages 12 through 43 of the DJII nspire 1 User Manual. The DJ I Inspir e 1 User Manuals are attached hereto as Exhibit A.
b. Flight Operations Of DJII nspire 1 Are Limited To The L ine Of Sight Of A Certificated Pilot in Command With A Safety Observer. Darryl J. Rasmussen willonly utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the DJ I Inspire 1. Additionally , a safet y observer will assist all pilots during flight time.
c. Flights Of DJ I Inspire 1 Will Be Conducted Pursuant To Specific Operating Lim itations. In seeking this exemption, Darryl J. Rasmussen proposes to commerciall y operate DJI Inspire 1 for the special purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to the following specific operating lim itations:
1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS's weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 Unmanned Aircraft Sy stems. 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 400 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL

. 5. The UA's must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PI C to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate.
6. The use of first person view (FPV) b y the PI C or safet y 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 alway s maintains VLOS capability . The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight

o perations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents.
8. The SO must not perform any other duties bey ond assisting the PI C with seeing and avoiding other air traffic and other ground basedobstacles/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

exist s between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditi ons 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 op erator’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 an y 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 PI C 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 alt erations must be properl y 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 tes t flight. The PI C 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 alread y covered in the relevant sections of the operating documents.
13. The operator must follow the UAS manufacturer’s aircr aft/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 timein service, description of work accomplished, and the signature of the authorized person returning the UAS to service. Each UAS's o perated under this exemption must comply with all manufacturer Safet y Bulletins.
15. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

16. The PI C must pos sess at least a private pilot certificate and at least a current third

- class medical certificate.
17. The operator may

not permit any

PIC to operate unless the PI C 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 log ged in a manner consistent with 14 C.F.R. §61.51(b). Flights for the purposes of training the operator’s PIC's are permitted under the terms of the exemption. However, training operations may 25 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 PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

1 8. 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 p roposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.
19. 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 a greement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
20.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 PI C.21.If the UA loses communications or loses its GPS signal, it must return to a pre

- dete rmined location within the planned operating area and land or be recovered in accordance with the operating documents.

22.The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

23.Th e PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UAS with 25% battery power remaining.
24.The operator mu st obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y 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.

25.Al l 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 larg e as practicable.
26. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency

requirements.

27. 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 an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon r equest.

28. The UAS must remain clear and yi eld the right of way to all manned aviation operations and activities at all times.
29. The UAS may

not be operated b y the PIC from any moving device or vehicle.
30. Flight operations must be conducted at leas t 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 UAS 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 op erations must cease immediatel y 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 PI C has made a safet y assessment of the risk of oper ating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).
31. All operations sh all be conducted over private or controlled

- access propert y 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.
32. 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 r eported to the National Transportation Safet y 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 Adversel y Affect Safet y. Darr yl J. Rasmussen submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the DJI Inspire 1 unless that PIC has demonstrated, b y meeting minimum fl ight

- hour and currency requirements, that the PI C is able to safel y operate the DJII nspire 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 Darry l J. Rasmussen’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 safel y operate the DJII nspire 1 UAS, Darry l J. Rasmussen submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary fo r Darry l J. Rasmussen’s specific proposed flight operations. The FAA has previousl y granted relief from Section61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 110 63, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Darryl J. Rasmussen will not allow any

PIC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, b y meeting minimum fli ght

- hour requirements of the DJII nspire 1 UAS training and currency requirements, that the PI C is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriat e distances from people, vessels, vehicles and structures. Specificall y, the PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (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 safet y during Darry l J. Rasmussen’s proposed operations. The Administrator has held that prior d ocumented 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 PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (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 sa fel y 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 PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. E xemption No. 11138 at page 15. Accordingl y,Darry l J. Rasmussen will ensure safe operations by not allowing any

PIC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJII nspire 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 Re quirements Of Section 91.7(a) Would Not Adversel y Affect Safety . The equivalent level of safet y established by Section 91.7(a) will be maintained because prior to every flight, Darry l J. Rasmussen will ensure that the DJ I Inspire 1 UAS is in an airworth y c ondition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally , the FAA has previousl y granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all materia l 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 Se ction 91.121 Would Not Adversel y Affect Safety . 31 The equivalent level of safety

established by

Section 91.121 will be maintained because the altitude information of the DJ I Inspire 1 UAS's will be provided to the PI C via GPS equipment and a radio communi cations 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 Darry l J. Rasmussen’s operation of the DJ I Inspire 1 UA's within visual line of sight, at or below 400 feet AGL , will ensure a level of safet y equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed on board the aircraft. Prior to each flight, a zero altitude initiation point is automatically establishe d by

the UAS's at ground level. The FAA has previousl y 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, 1 1109, 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 Adversel y Affect Safety. A grant of this exemption would ensure an equivalent level of saf ety established by

14 C.F.R. Section 91.151(b) as a result of

(1) the technical specifications of the DJ I Inspire 1 UAS's;
(2) the limitations on the proposed flight operations; and(3) the location of the proposed flight operations. Accordingl y, Darr yl J. Rasmussen will ensure that he will safel y operate the battery powered DJ I Inspire 1 UA's during day light hours in VFR conditions, with enough battery power to fly

for a total duration of 10 minutes to the first point of intended landing and, assuming n ormal cruising speed, to fl y after that for at least 2.5 minutes. 32 Here, as in Exemption No. 11109, the technical specifications of the DJ I Inspire 1 UAS's the limitations on the proposed flight operations and the the location of the proposed operations, will ensure an equivalent level of safet y established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as DJ I Inspire 1 UAS's provide audible and visual warnings to the PI C at the GCS when the UA's experiences low battery voltage, the f

irst warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the criticall y low battery level, the DJ I Inspire 1 UAS's will descend and land automaticall y. Significantly, previous exemption s granted by the FAA concerning Section 91.151 establish that safet y 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

m inimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previousl y 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 Adversel y Affect Safety. In seeking this exemption, Darry l J. Rasmussen submits that the equivalent level of safet y 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 33 because Darryl J. Rasmussen will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in the operating documents i.e., the Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual. Furthermore, Darry l J.Rasmussen will document and maintain all maintenance records for the DJ I Inspire 1 UAS's. Since the DJ I Inspire 1 UAS's will be inspected as prescribed b y the operating documents, Darryl J. Rasmussen’s will maintain the equivalent level of safet y established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJII nspire 1 Use r Manuals are attached hereto as Exhibit B; a cop y of the DJ I Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C. L ikewise, the exemption sought will not adversel y affect safety because Darryl J. Rasmussen will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y Established b y Sections 91.407 , 91.417(a) and 91.417(b), because all maintenance of the DJ I Inspire 1 UAS's will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly

maintenance log. Significantly , previous exemptions granted b y the F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not adversely affected when the technical characteristics and operating limitation s of the UAS are considered. In consideration of Darry l J . Rasmussen’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Inspire 1 UAS's, Darry l J. Rasmussen’s submits that safet y will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 9 1.407(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, Darry l J. Rasmussen’s requests that the FAA prescribe special conditions for the intended operation of DJ I Inspire 1 UAS's, which contain such safet y standards that the administrator finds necessary to establish a level of safet y 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's 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 nationa l 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 prescrib e special conditions pursuant to 14 C.F.R. §21.16, for operation of the DJ I Inspire 1 UAS's, 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 th e 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 safet y standards for an aircraft, aircraft engine, or propeller beca use of a novel or unusual design feature of the aircraft, aircraft engine or propeller, it may prescribe special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain suc h safet y standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safet y 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 Darry l J. Rasmussen’s intended operation of the DJ I Inspire 1 UAS's, which contain such safet y standards that the administrator finds necessary to establish a level of safet y equivalent to that estab lished 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). 36 F. A Summary That Can Be Published In The Federal Register stating: The Rules From Which Darry l J. Rasmussen Seeks Exemption: Darryl J. Rasmussen 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 Descript ion Of The Nature Of The Exemption Darryl J. Rasmussen Seeks: This exemption will permit Darryl J. Rasmussen to commerciall y operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photograph y over certain areas of the Unit ed States. G. Any Additional Information, Views, Or Arguments Available To Support Darry l J. Rasmussen’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary

of Transportati on to determine if certain UAS may operate safel y in the NAS. As such, Darry l J. Rasmussen 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 require ments 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 det ail above, Darry l J. Rasmussen will operate the DJ I In spire 1 UAS's safel y in the NAS, withoutcreating a hazard to users of the NAS, or the public, or otherwise pose a threat to national

securit y.

CONCLUSION As set forth herein, Darry l J. Rasmussen 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 DJ I Inspire 1 UAS's commerciall y, without an airworthiness certificate, for the limited purpose of c onducting 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 interest s of the public, by allowing Darry l J. Rasmussen to safel y, efficientl y, and economically

operate the DJ I Inspire 1 UAS's commerciall y within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act o f 2012, Section 333, Darry l J. Rasmussen respectfull y 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 Darry l J. Rasmussen to operate the DJII nspire 1 UAS's commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: May 6, 2015
Respectfully

submitted,

Darry l J . Rasmussen

APPENDI CES:

A

- DJ I Inspire 1 Specifications

B

– DJ I Inspire 1

– User Manual

C

– DJII nspire 1

- Monthly Maintenance Log

APPENDIX

–A DJ I Inspire 1 TECHNICAL SPECIFICATIONS

Darry l J. Rasmussen only utilizes safe and reliable UAS's. DJ I i s an industry leader in small UAS production. DJ I UAS's 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 predet ermined 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 PI C via the linked monitor, Inspire 1 Radio Control Transmitter Aircraft Model T600 Weight (Battery I ncluded) 2935 g Hovering Accuracy (Gps Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocit y Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTImode, no wind) Max Fligh t Altitude 4500 m Max Wind Speed Resistance 10 m/s 39 Max Flight Time Approximately 18 minutes Motor Model DJI3510 Propeller Model DJ I 1345 Indoor Hovering Enabled bydefault Operating Temperature Range

- 10° to 40° C Diagonal Distance 559 to 581 mm

Dimens ions 438x451x301 mm Gimbal Model ZENMUSE X3 Output Power (With Camera) Static: 9 W In Motion: 11 W Operating Current Station: 750 mA Motion: 900 mA Angular Vibration Range ±0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30° Pan: ±320° Mechani cal Range Pitch:

- 125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°/s Camera Name X3 Model FC350 Total Pixels 12.76M Effective Pixels 12.4M I mage Max Size 4000x3000 I so Range 100

- 3200 (video) 100

- 1600 (photo) Electronic Shutter Speed 8 s/ 1/8000s Fov (Field Of View) 94° Cmos Sony EXMOR 1/2.3” 40 Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti

- distortion Still Photograph y Modes Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bra cketed frames at 0.7EV Bias Time

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate Of Video Storage 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, D NG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported Sd Card Ty pes Micro SD Max capacity : 64 GB. Class 10 or UHS

- 1 rating required Operating Temperature Range 0° to 40° C Controller Name C1 Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2 .483 GHz Transmitting Distance (Outdoor And Unobstructed) 2 km Eirp 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini

- HDMI Power Supply Built

- in battery

Charging DJ I charger Dual User Capability Host

- and

- Slave connection

;