James	M	Crotty

Manager,	Aircraft	and	Airport	Rules	Division

800	Independence	Ave	S.W.

Washington	DC	20591

Re:	Public	Docket	FAA-2015-0827	– Exemption	/	rulemaking	request

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

number,	telephone	number,	or	email	address;

Robert	Wise

ImageWise	Video	LLC

18150	NW	Clarno	Ct.

Portland	OR	97229

503	724	5460

Rob@imagewisevideo.com

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

14	C.F.R.	Part	21

14	C.F.R.	45.23(b)	

14	C.F.R.	61.113(a)	&	(b); 14	C.F.R.	61.133(a);	

14	C.F.R.	91.7(a);	

14	C.F.R.	91.9(b)(2)	&	(c)

14	C.F.R.	91.103;	

14	C.F.R.	91.109(a);	

14	C.F.R.	91.119;14	

C.F.R.	91.151(a);	

14	C.F.R.	91.203(a)	&	(b);	

14	C.F.R.	91.405(a);	

14	C.F.R.	91.407(a)(1);	

14	C.F.R.	91.409(a)(2);	14	C.F.R.	91.417(a).	

Sec	333	prohibits	the	use	of	a	sUAS for	commercial	purposes	on	private	property.	I	am	the	

owner	of	a	video	production	company	that	providing	video	services	for	private	and	

corporate	special	events,	and	corporate	information	and	recording	service.	I	am	

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

owners	and	companies	who	wish	to	obtain	and	capture	aerial	photos	and	videos	of	said	

property or	events, for	purposes	including	real	estate	listings,	insurance	property	claims,	

search	and	rescue,	building	and	property	inspections	and	review,	land	surveying	or	for	

use	as	a	marketing	tool	for	businesses. Additional	use	may	be	for	video/film	production.

I	would	like	to	be	able	to	accept	payment	for	these	services	therefore	making	this	a	

commercial	use	of	a	sUAS.
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,	and	other	business	owners	who	wish	to	document	their	land,		

property,		product or	company,	to	take	advantage	of	the	lower	cost	and	technology	that	

now	exists	in	the	form	of	sUAS’s	and	allows	them	to	do	so	using	an	experienced	and	RC	

Pilot	in	Command	that	understands	how	to	safely	operate	such	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;

As	a	qualified	and	commercial	videographer	and	member	of	the	Drone	Pilots	Association,	I	

currently	exercise	many	safety	programs,	including	SAFE	technology	and	GPS	navigating.	

When	flying	for	this	commercial	purpose	I	would	be	flying	at	a	maximum	altitude	of	200	

Feet	and	flying	mostly	vertically	for	the	purposes	of	taking	photos,	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	will	

not	be	flying	near	high	traffic	areas	including	airports,	and	I	pay	attention	to	NOTAMS	by	

following	current	alerts	at	twitter.com/amagov	or	refer	to	pilotweb.nas.faa.gov/PilotWeb/

I intend to follow these suggested safety regulations 

 Always keep aircraft in line of sight and under control.

 Accompanying me will be a second person to monitor the aircraft along with me. 

 Always keeping 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 and do not fly when batteries are 25% or less power 

remaining.

 Utilize auto return home prior to batteries remaining power at 25% or less.

 Not fly within 5 miles of any airport or fly in other no fly zones.

 I have installed the dji Inspire 1 propeller locks which were sent out by DJI, which ensure an 

added safety layer of propellers. 

 The auto	home	point	return	feature,	which	returns	the	aircraft	to	either	when	the	

controller	is	or	where	the	Dji	Inspire	1	initially takes	off	from.	This	can	be	used	when	

low	battery	level	customizable	thresholds	are	enabled,	or	if	the	aircraft	drifts,	for	

simple	recovery	and	automated	return	of	the	aircraft.	

Additional	safety	features	I	will	be	using	to	ensure	a	safe	and	responsible	flight	path,	

including	the	following.

VISION	POSITIONING	SYSTEM

DJI’s	new	Optical	Flow	technology	uses	a	specially	designed	camera	as	well	as	sonic	waves	

to	bring	simplicity	and	safety	when	taking	off	and	landing. These	sensors	read	the	ground	

distance	and	ensure	a	smooth	take	off,	landing	or	use	in	doors	if	applicable.	This	
technology	allows	the	Inspire	to	hold	its	position,	stop	when	the	controls	are	released,	and	

respond	to	your	commands	even	when	GPS	is	unavailable.

INTELLIGENT	POWER	MANAGEMENT	SYSTEM

A	fully	integrated	intelligent	battery	powers	the	Inspire	1	and	virtually	manages	itself.

When	in	flight, my	remaining	battery	power	is	shown	live,	letting me	know	know	how	

long	I	can	 continue	to	fly in	minutes.	Advanced	algorithms	calculate	the	distance	of	your	

aircraft	and	estimated	time	to	return	home,	letting	you	know	when	it’s	time	to	fly	back.

The	battery	tracks	the	voltage	of	each	cell,	the	total	lifetime	charges	and	discharges,	and	

the	overall	health	and	battery	status.	

SAFE FLIGHT

When GPS is available, the Home Point (the location you are standing) automatically 

refreshes, so the Inspire 1 always knows where you are even if you move around. When you 

tell it to come back, or in case of an emergency, it knows exactly where to go and land safely.

FULL-FEATURED APP

In addition to line of site, I simultaneously have access to the camera and flight system with a 

comprehensive mobile app. Everything from manual camera controls to flight telemetry, auto 

takeoff and landing are accessible on the controller and the app alike. 

 Position Hold– The DJI Inspire 1 uses GPS to hold a given location when this function is 

activated. If GPS is enabled and has a solid lock, the aircraft will hold its position when 

elevator or aileron inputs DJI Inspire 1 are at neutral.

 Throttle provides proportional thrust– The throttle responds directly to the throttle input, 

giving the pilot direct control over hovering as well as ascent and descent rates.

A summary we can publish in the Federal Register—

I, Robert Wise am seeking an exemption of the FAA’s Sec 333 rules that does not allow the use 

of a small 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 and public land owners and companies who wish to obtain and capture aerial photos and 

videos of said property, private or public events, real estate listings, insurance property claims, 

inspections and review, marketing tool for business. As a member of the Drone Pilots 

Associations I understanding the importance of 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 sUAS (DJI Inspire 1 whose Operating 

Manual is included in my petition) I am seeking exemption with is one with many safety 

programs, including SAFE technology and GPS navigating. When flying for this commercial 

purpose I would be flying at a maximum altitude, not to exceed 500 feet and flying mostly

vertically for the purposes of taking photos, 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, (unless specifically hired to do so by the organizing management) or high 
traffic areas including airports, and I would monitor and pay attention to NOTAMS. 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 DJI 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 or 

rural areas and stay 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 and with a spotter.

I understand and will comply with all the health and safety regulations for PIC’s and will be the 

only operator under this exemption.

FCC Compliance

This device complies with part 15 of the FCC Rules. Operation is subject to the following two 

conditions: (1) This device may not cause harmful interference, and (2) This device must accept 

any interference received, including interference that may cause undesired operation. Changes 

or modifications not expressly approved by the party responsible for compliance could void the 

user's authority to operate the equipment

General Safety Precautions and Warnings I intend to follow:

 Follow FAA guidelines for safe usage of sUAS flight.

 Maintaining flight log data.

 Update the weather, wind and other factors prior to takeoff.

 I use extreme caution if operating around buildings, people or other personal or business 

property, keeping the aircraft at safe distances away. 

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

must state the reason. 

Although I have no intention of using this exemption outside the United States at this time,

there may be a time in the future for limited or periodic use of the aircraft, outside the United 

States. This could be for relocation, destination videos for personal or commercial use. If used 

outside the United States, I will comply with that government’s laws, exemptions and other 

applicable regulations. 

 

I have attached a copy of the Dji Inspire 1 operating manual and providing you with the link to 

the manufacturer’s website where you can obtain more insight. 

http://www.dji.com/product/inspire-1/feature

Please contact me if I can follow up with anything else regarding my requested exemption. 

Thank you for your consideration for approval.
Sincerely,

Robert Wise

rob@imagewisevideo.com