1 

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Altiora Media, LLC FOR 

AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a), 

61.315(a), 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 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

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

Submitted on May 11, 2015 Ammended July 21, 2015

Daniel O. Montaño/Altiora Media, LLC

37 Vista Alegre Belen, NM 87002 

Tel: (505)450-7123

Email: daniel@neonbuffalo.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. ...........................................................................8 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ALTIORA MEDIA, LLC 

SEEKS EXEMPTION..............................................................................................................8 

THE EXTENT OF RELIEF ALTIORA MEDIA, LLC SEEKS AND THE REASON 

ALTIORA MEDIA, LLC SEEKSTHE RELIEF.................................................................12 

THE REASONS WHY GRANTING ALTIORA MEDIA, LLC’S REQUEST WOULD BE 

IN THE PUBLIC INTEREST .............................................................................................17 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY ................................................................................................................20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ...................34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT ALTIORA MEDIA, LLC’S REQUEST.... .......................................................34 

 CONCLUSION ..................................................................................................................... 34 
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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

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 

Daniel O. Montaño seeks exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and 

(5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Altiora Media,

LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography of forestry/fire project sites, construction sites, building 

inspections, agricultural lands, outdoor recreational facilities, real estate, special events, and 

landscapes within the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Altiora Media, LLC will provide its clients with the highest quality digital content for use in 

their commercial, personal, and non-profit multimedia projects. Altiora Media, LLC will bring 

together years of professional marketing expertise, award-winning production talent and state-of-theart technology to make studio quality productions within reach for organizations of any size. Altiora 

Media, LLC will also leverage years of professional forestry, fire, and film experience to become a 

leading provider of geomapping and image analysis services to the forestry and environmental 

monitoring industries. Altiora Media, LLC has over 20 years commercial experience in all aspects of 

forestry/fire and 15 years in the film industry. The objective of Altiora Media, LLC aerial video and 

photography operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, specifically targeting: 

• Aerial event filming and photography

• Feature film and Documentary cinematography 

• Promotional videos for businesses, non-profits & government entities 

• Agricultural surveys and environmental monitoring 

• Forestry/land surveys and documentation

• Real estate 
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BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS 

Altiora Media, LLC seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Inspire 1 (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 Inspire 1 is an electric powered rotary wing UAS that is capable of transmitting live 

airborne video images and location information to a Ground Control Station (GCS). The Inspire 

stores the photographs and data on board and makes them available for download after completion of 

the flight. The Inspire is 22 in x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs mandated 

in the FMRA. The Inspire can conduct hovering flight and has a maximum cruising speed of 42 

knots. It is battery powered, has a flight endurance of 22 minutes and can operate in temperatures 

ranging from 0° to 40° C. The Inspire’s omni-directional antenna has a range of 2.1 km and operates 

in the 2.420 – 2.483 GHz frequency range. 

The Inspire 1 that will be operated by Altiora Media, LLC will be registered in accordance 

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

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

Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Altiora Media, LLC, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the DJI Inspire 1 in the National Airspace System (NAS), and 
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for an exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 

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, Altiora Media’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, Altiora Media, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Altiora Media, LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Altiora Media, LLC will use experienced personnel or technicians to perform 

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

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, Altiora Media, LLC will document and maintain all maintenance 

records for the DJI Inspire 1 UAS. 

Relief from certain requirements of Section 61.101(e)(4) and (5) entitled Recreational pilot 

privileges and limitations: Pilot in command, and from Section 61.315(a) entitled What are the 

privileges and limits of my sport pilot certificate, and from Section 61.23(a) entitled Medical 

certificates: Requirements and duration, is requested by Altiora Media, LLC to the extent necessary 

to allow a Pilot in Command (PIC) holding a sport pilot or higher level certificate, as well as a valid 

driver’s license, 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 
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this exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Altiora Media, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Altiora Media, LLC submits that it will ensure that the DJI 

Inspire 1 UAS are in an airworthy condition, prior to every flight, by determining that the UASs are 

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

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

Altiora Media, LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 UA 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 Altiora Media, LLC’s operation of the DJI Inspire 1 UAS within visual line of sight, 

at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Altiora Media, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Altiora Media, LLC 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 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. 
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In accordance with 14 C.F.R. § 11.81, Altiora Media, LLC provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Daniel O. Montano 

Altiora Media, LLC 

37 Vista Alegre 

Belen, NM 87002 

Tel: (505)450-7123 

Email: daniel@noenbuffalo.com

B. The Specific Sections Of 14 C.F.R. From Which Altiora Media, LLC Seeks 

Exemption. 

1. Altiora Media, LLC Seeks Exemption From The Requirements Of Section 61.101(e)(4) 

and (5). 

Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in 

command, subsection (e)(4) and (5) prescribe the following, in relevant part: 

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not 

act as pilot in command of an aircraft- 

(4) For compensation or hire; 

(5) In furtherance of a business; 

2. Altiora Media, LLC Seeks Exemption From The Requirements Of Section 61.23(a). 

Section 61.23(a), entitled Operations requiring a medical certificate: Requirements 

and duration, subsection (a) prescribe the following, in relevant part: 

(f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act 

as pilot in command of an aircraft- 
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3. Altiora Media, LLC Seeks Exemption From The Requirements Of Section 61.315(a). 

Section 61.315(a), entitled What are the privileges and limits of my sport pilot 

certificate, subsection (a) prescribe the following, in relevant part: 

(c) You may not act as pilot in command of a light-sport aircraft: 

(2) For compensation or hire. 

(3) In furtherance of a business.- 

4. Altiora Media, LLC 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. 

5. Altiora Media, LLC 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 t

 hat 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. 
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6. Altiora Media, LLC 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. 

7. Altiora Media, LLC 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[.] 

8. Altiora Media, LLC 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[.] 

9. Altiora Media, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) 

and 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had - 

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by § 43.7 of this chapter; or 
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(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter. 

10. Altiora Media, LLC 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 
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major alteration to the airframe and currently installed engines, rotors, propellers, a nd 

appliances. 

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

prescribed: 

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

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

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

with the aircraft at the time the aircraft is sold. 

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

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

service. 

C. The Extent Of Relief Altiora Media, LLC Seeks And The Reason Altiora Media, LLC 

Seeks The Relief. 

1. Extent Of Relief Altiora Media, LLC Seeks And The Reason Altiora Media, 

LLC Seeks Relief From Section 61.113(a) and (b). 

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

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level 

certificate, as well as a current and valid airman medical certificate, and who has met certain flighthour 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, Altiora Media, LLC submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS UA unless that 
13

PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate either 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, Altiora Media, LLC 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 Altiora Media, LLC business; 

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

2. Extent Of Relief Altiora Media, LLC Seeks And The Reason Altiora Media, LLC 

Seeks Relief From Section 61.23(a). 

Relief from Section 61.23(a), entitled Operations requiring a medical certificate: 

Requirements and duration, is requested to the extent required to necessary to allow a PIC holding a 

sport pilot certificate or higher level certificate, as well as a current and valid driver’s license, to 

conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.23(a) otherwise require the 

PIC of any flight for compensation or hire to hold a comprehensive FAA issued medical certificate. 

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, because of the risk mitigations 

established in the conditions and limitations of this exemption, a person that holds a U.S. issued 

driver’s license who is operating a UAS will not adversely affect safety. The FAA is granting relief 

from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed above to operate 

a UAS under this exemption with a U.S. issued driver’s license, in lieu of an FAA-issued medical 

certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to 

operate aircraft other than LSA with a U.S. issued driver’s license under this exemption.” 
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3. Extent Of Relief Altiora Media, LLC Seeks And The Reason Altiora Media, LLC 

Seeks Relief From Section 61.315(a). 

Relief from Section 61.315(a) entitled What are the privileges and limits of my sport pilot 

certificate, is requested to the extent necessary to allow a PIC holding a sport pilot or higher level 

certificate to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.315(a) restrict a sport pilot

from acting as the PIC of any flight for compensation or hire, or for the furtherance of any business. 

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re-assessed the level of pilot 

certificate that would be appropriate for the petitioner’s operations. In evaluating this petition, similar 

to the evaluation of the private and commercial pilot certificates in Exemption No. 11062, the agency 

compared the aeronautical knowledge requirements of the recreational and sport pilot certificates to 

those of the private pilot certificate. They found that the aeronautical knowledge requirements that 

would be applicable to a UAS operation for a recreational pilot and sport pilot certificate are 

substantially similar as those for a private pilot certificate. 

Additionally, similar to the private and commercial pilot certificates, holders of recreational 

and sport pilot certificates are subject to security screening by the Department of Homeland Security 

(DHS). 

Therefore, because they must demonstrate aeronautical knowledge relevant to UAS 

operations and are subject to DHS screening, factors that were considered by the FAA in allowing 

private pilot operations under previous exemptions, the FAA now determines that holders of 

recreational and sport pilot certificates may serve as the PIC for UAS operations. 
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4. Extent Of Relief Altiora Media LLC Seeks And The Reason Altiora Media, LLC 

Seeks Relief From Section 91.7(a). 

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

required to allow Altiora Media, LLC to determine that the DJI Inspire 1 UAS are in airworthy 

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

documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). 

Altiora Media, LLC seeks the requested relief because the DJI Inspire 1 UAS do not require 

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

Media, LLC will ensure that the DJI Inspire 1 UAS are 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 are in condition for 

safe flight, as stated in the conditions and limitations below. 

5. Extent Of Relief Altiora Media, LLC Seeks And The Reason Altiora Media, LLC 

Seeks Relief From Section 91.121. 

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

operations of the DJI Inspire 1 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), Altiora 

Media, LLC seeks the requested relief because the DJI Inspire 1 UA’s altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 
16

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 UAs are 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. 

6. Extent Of Relief Altiora Media, LLC Seeks And The Altiora Media, LLC 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 UAs during 

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

duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. Altiora Media, LLC seeks the requested relief because without 

an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 

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

Altiora Media, LLC 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 Altiora Media, LLC’s proposed operating limitations, ensure 

that Altiora Media, LLC will safely operate the battery powered DJI Inspire 1 UAs during daylight 

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

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

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 
17

7. Extent Of Relief Altiora Media, LLC Seeks And The Reason Altiora Media, LLC 

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply 

to aircraft with an airworthiness certificate, Altiora Media, LLC requests relief from these 

Sections because the DJI Inspire 1 UAS does not require airworthiness certificates. 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, Altiora Media, LLC will use trained technicians to 

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

techniques, and practices prescribed in the UAS operating documents (i.e., the DJI Inspire 1 

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

Furthermore, Altiora Media, LLC will document and maintain all maintenance records for the DJI 

Inspire 1 UAS. 

D. The Reasons Why Granting Altiora Media, LLC 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 Altiora Media, LLC 

to safely, efficiently, and economically conduct aerial video and photography of construction sites, 

building inspections, agricultural lands, wineries, outdoor recreational facilities, real estate, special 

events, and landscapes 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 Altiora Media, 

LLC’s proposed operation of the DJI Inspire 1 UAS will be realized without implicating any 

privacy issues. 
18

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

The DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical 

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

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

DJI Inspire 1 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 UAS 

do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting 

aerial video and photography missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

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

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 produce no air pollution, and is the most viable 

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

aircraft that are typically utilized for aerial video and photography, while burning approximately 20-

30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UASs are propelled by battery 
19

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 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 UAS (weighing approximately 6.5 pounds maximum gross weights with a 

length of 17.3 inches, width 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 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 Altiora Media, LLC, 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 Altiora Media, LLC, can remain 

competitive and profitable, and therefore, provide greater job stability to employees and contractors, 
20

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, 

Altiora Media, LLC 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 the 

conditions set forth in any exemption granted under this petition. 

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 Altiora Media, LLC Seeks Exemption. 

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

Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited 

operating area associated with the unmanned aircraft and its operation, Altiora, Media LLC operation 

of the DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides 

authority for a UAS to operate without airworthiness certification and sets forth requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security. Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days 

after the date of enactment of this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion of 
21

the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 

of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), 

the Secretary shall determine, at a minimum-

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

operational capability, proximity to airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system or the public or pose a threat to 

national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1). 

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

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Altiora Media, LLC 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 

athreat 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.

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

UAS 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 in the DJI Inspire 1 User Manual, attached hereto as Exhibit B.
22

iii. The DJI Inspire 1 UAS Are 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 in 

the DJI Inspire 1 User Manual, attached hereto as 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 in 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 Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Altiora Media, LLC will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. Additionally, 

a safety observer will assist all pilots during flight time. 

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

Limitations. 

In seeking this exemption, proposes to commercially operate 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 System. Proposed operations of 
23

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 UAs 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 UAs 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 
24

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight. The PIC who conducts the functional test flight must make an entry in the aircraft 

records. 

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

components, items, or equipment, not already covered in the relevant sections of the operating 

documents. 

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

replacement, inspection, and life limit requirements. 

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

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the authorized person returning 

the UAS to service. 

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

Bulletins. 

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

against discrepancies discovered between inspections. 

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

medical certificate. 

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

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

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

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

the exemption. However, training operations may only be 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. § 

19.1. 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 
25

made available to the Administrator upon request. 

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

cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a 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 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 
26

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. 

Altiora Media, LLC submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

DJI Inspire 1 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 Altiora, Media LLC 

proposed area of operations, and the operating limitations set forth-above; the parallel nature of sport 

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, Altiora

Media, LLC submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for Altiora Media, LLC 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, 
27 

11156, 11158, 11159, 11160, 11161). 

Altiora Media, LLC 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 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 Altiora Media, LLC 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 
28

FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely conduct the 

petitioner’s proposed operations. The FAA also finds that prior documented flight experience 

that was obtained in compliance with applicable regulations would satisfy this requirement. 

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, Altiora Media, LLC 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 prior 

to every flight, Altiora Media, LLC 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. 
29

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from the UAS to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with Altiora Media, 

LLC’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by 

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

automatically established by the UASs at ground level. 

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, Altiora Media, LLC 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 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. 
30

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 UAs 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 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, Altiora Media, LLC submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Altiora
31

Media, LLC 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., the DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 

Instruction Manual). Furthermore, Altiora Media, LLC 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, Altiora Media, LLC will maintain the equivalent level of safety established by 

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

are attached hereto as Exhibit B; a copy of the DJI Inspire 1 Maintenance Manual is attached 

hereto as Exhibit C; a copy of the DJI Inspire 1 UAS Maintenance LOG is attached hereto as 

Exhibit D. 

Likewise, the exemption sought will not adversely affect safety because Altiora Media, 

LLC will use trained technicians to perform maintenance, alterations or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI 

Inspire 1 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 
32

considered. 

In consideration of Altiora Media, LLC proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Inspire 1 UAS, Altiora Media, LLC 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). 

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, Altiora Media, LLC 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 UAs 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. 
33

§ 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 Altiora Media, LLCs 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 Feather Light Media LLC Seeks Exemption: 

Altiora Media, LLC seeks exemption from the requirements of 14 C.F.R Sections 

61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Altiora Media, LLC Seeks: 

This exemption will permit Altiora Media, LLC to commercially operate an Unmanned 

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

certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support Altiora Media, 

LLC Request. 
34

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, Altiora Media, LLC request for exemption may be granted pursuant to 

the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, Altiora Media, LLC will operate the DJI Inspire 1 UASs 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, Altiora Media, LLC seeks an exemption pursuant to 14 

C.F.R § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the DJI Inspire 1 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 Altiora Media, LLC to safely, efficiently, and economically 

operate the DJI Inspire 1 UAS commercially within the NAS. 
35

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

Modernization and Reform Act of 2012, Section 333, Altiora Media, LLC respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Altiora Media LLC to operate the DJI Inspire 

1 UAS commercially for the purpose of conducting aerial video and photography over areas of the 

United States. 

Respectfully submitted, 

 Daniel Montaño 

 

 Altiora Media, LLC 

 37 Vista Alegre 

 Belen, NM, 87002 

 Tel: (505)450-7123 

 Email: daniel@neonbuffalo.com