Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Your name and mailing address. You may include other contact information such as a fax number, 

telephone number, or email address; 

Name: Mark J. Young

Address: 620 112th Street SE #370; Everett WA, 98208

Phone: (425) 299-1945

Email: mark0259@comcast.net

The specific section or sections of 14 CFR from which you seek an exemption; 

Petition for Exemption under Sec 333

The extent of relief you seek and the reason you seek the relief; 

Sec 333 prohibits the use of an unmanned aircraft systems (UAS) for commercial purposes on private 

property. I at this time simply petitioning for an exemption to provide a commercial service to private 

land owners and companies who wish to obtain and capture Aerial photos and videos of said property 

for purposes including real estate listings, insurance property claims, and for use as a marketing tool for 

businesses. In addition I hold an FCC Extra Class Amateur Radio License; call sign AA7FY and, and further 

simply petitioning for an exemption to provide UAS service in the inspection of amateur radio antenna 

towers and antenna installations. For these services I would like to be able to accept payment therefore 

making this a commercial use of a UAS.

How your request would benefit the public as a whole; 

My request benefits the public as a whole by providing an opportunity for small business owners, real 

estate agents, Radio Amateurs, and others a safe and economic way to document and inspect their land 

or property by taking advantage of the technology that now exists in the form of UAS’s. It further allows 

them to do so safely by employing an experienced RC Pilot in command of the UAS that understands 

how to safely operate the technology.

Reasons why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule; 

I have an Engineer with the Boeing Company for over 35 years and have been involved in the safety, 

design, manufacture and certification of commercial and military aircraft. I have successfully completed 

over 40 hours community college training in design and construction of UAS with emphasis on FAA 

regulations and safety of construction and flight. I therefore understanding the importance of different 

uses and safety concerns regarding FAA regulated airspace. I feel that I would be a good candidate for 

exemption of Sec 333 while and not putting Air Safety in any accelerated risk. The specific UAS that I will 

be deploying is the DJI Inspire 1 (whose Operating Manual is Included in my petition) and it is the Inspire 

1 that I am seeking exemption with. This particular model was chosen because of its many proven 

safety features, including GPS navigation and Vision Positioning technology. It was also chosen for its 

return to home (RTH) feature that will return and land the UAS in the event of a failure by either a loss 
of control signal or a low battery condition. This in conjunction with its GPS and Vision Positioning 

provides three levels of hovering and flight precision, and exemplary safety of operation. While flying 

for commercial purposes the Inspire 1 will be preprogrammed to not fly above a maximum altitude of 40 

meters and will primarily fly vertically for the purposes of taking photographs, therefore decreasing the 

risk of any interference. My general knowledge and training in the aviation safety systems implemented 

by the FAA would be used to ensure that safety would not be compromised by my operations. I would 

not be flying near disaster areas unless specifically directed by the emergency coordinator for the 

disaster, sporting events, or high traffic areas including airports.

For your further consideration there are three modes of flight available for the Inspire 1, for commercial

use I will be only flying in P (positioning) mode (default) which I have outlined below:

P mode (Positioning) - There are three different states of P mode, which will be automatically selected by 

the Inspire 1 depending on GPS signal strength and the Vision Positioning sensors:

P-GPS: GPS and Vision Positioning both are available, and the aircraft is using GPS for 

positioning.

P-OPTI: Vision Positioning is available but the GPS signal is not. Aircraft is using only Vision 

Positioning for hovering.

P-ATTI: Neither GPS or Vision Positioning available, aircraft is using only its barometer for 

positioning, so only altitude is controlled.

The remaining two Modes need to be manual selected 

A mode (Attitude):

GPS and Vision Positioning System is not used for stabilization. The aircraft only uses its 

barometer to stabilize. The aircraft can automatically return home if Remote Controller 

signal is lost if the Home Point is recorded successfully.

F mode (Function):

Intelligent Orientation Control (IOC) is activated in this mode. For more information 

about IOC, refer to the IOCI Intend to fly in one of these two safe modes: 

In addition, the Inspire 1 controlling transmitter provides an important additional safety feature not 

available in other UAS of this class; a neutral stick hold position. This is where the UAS transmitter’s

elevation, rudder, yaw, and pitch control sticks are normal to the center or neutral position. When 

releasing any control, they will return to the neutral position and the aircraft will stop and hover at that 

position.

As was stated above, in the event of low battery or any loss of contact with the transmitting device, the 

Inspire 1 will elevate to a pre-determined safe height; in order to avoid any obstacles and return to 

either the original takeoff point or to the controlling transmitter (which also has a GPS feature, used if 

the operator has moved away from the original take off point), hover, land, and safely shut down.

I intend to follow these suggested UAS safety regulations:

• Always keep aircraft in sight and under control.
• Always keep people and pets at least 35 feet (10 meters) away when the battery is connected.

• Keep children out of the vicinity of this product at all times.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly.

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Always have a first aid kit with you.

• Always have an appropriate fire extinguisher with you.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

A summary we can publish in the Federal Register Federal Register —

I, Mark J Young am seeking an exemption of the FAA’s Sec 333 rules that does not allow the use of an 

Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safety. I am 

simply petitioning for an exemption to provide a commercial service to private land owners and 

companies who wish to obtain and capture Aerial photos and videos of said property for purposes 

including real estate listings, insurance property claims, and for use as a marketing tool for businesses. 

In addition to be used for amateur communication tower and antenna installation inspection. Being a 

Boeing Engineer and a licensed FCC Amateur Radio Operator Extra Class as well as a an RC plan hobbyist

give me the understanding and the importance of regulation adherence and the different uses and 

safety concerns regarding FAA regulated airspace, I would be a good candidate for exemption of Sec 333 

while not putting Air Safety in any accelerated risk. The specific UAS (The DJI Inspire 1) I am seeking 

exemption with is one with many safety programs, including GPS and Vision positioning navigating, and 

unique return to home features. When flying for this commercial purpose I would be flying at a 

maximum altitude of 40 meters and primarily flying vertically for the purposes of taking photos, and 

therefore decreasing the risk of any interference. My general knowledge of the aviation safety systems 

implemented by the FAA would be used to ensure that safety would not be affected by my operations. I 

would not be flying near disaster areas, sporting events, or high traffic areas including airports. I 

appreciate the FAA’s consideration of this petition for exemption.

Any additional information, views, or arguments available to support your request; 

I am fully aware of the preflight safety checks and procedures implicated in the operation manual for 

the Inspire 1 and intend to implement preflight safety checks and utilize the safety technology provided 

with this unit. I intend to only fly in non-populated, residential and rural areas and flying clear of all 
utility lines etc. I intend to be fully aware of my surroundings at all times and to only fly the unmanned 

aircraft within a visual line of sight and only in visual flight conditions. I understand and will comply with 

all the health and safety regulations and will be the only operator under this exemption. 

Operations of the Inspire 1 include the following information and operations manual: 

Weight 2935g (Battery Included)

Takeoff Weight 3400g

Hovering Accuracy (GPS mode) Vertical: 0.5m; Horizontal:2.5m

Max Angular Velocity Pitch: 300°/s; Yaw:150°/s

Max Tilt Angle 35°

Max Ascent/Descent Speed 5/4 m/s

Max Speed 22m/s

Max Flight Altitude 4500m

Max Wind Speed Resistance 10m/s

Operating Temperature Range -10°~40°C

Max Flight TimeApproximately 18 minutes

General Safety Precautions and Warnings I intend to follow in my UAS operations:

• Always keep a safe distance in all directions around your model to avoid collisions or injury. This 

model is controlled by a radio signal subject to interference from many sources outside your control. 

Interference can cause momentary loss of control.

• Always operate your model in open spaces away from full-size vehicles, traffic and people.

• Always carefully follow the directions and warnings for this and any optional support equipment 

(chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach of children.

• Always avoid water exposure to all equipment not specifically designed and protected for this 

purpose. Moisture causes damage to electronics.

• Never place any portion of the model in your mouth as it could cause serious injury or even death.

• Never operate your model with low transmitter batteries.

• Always keep aircraft in sight and under control.

• Always move the throttle fully down at rotor strike.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.
• Always remove batteries before disassembly.

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

If you want to exercise the privileges of your exemption outside the United States, you must state the 

reason.

I have no intention of using this exemption outside the United States