UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Cureative Communications 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 June 2, 2015

Patrick J. McBride

Cureative Communications LLC

21618 W 71st Terrace

Shawnee, KS 66218

Tel: (816) 853-1314

Email:patrickmcbride@gmail.com
2

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 CUREATIVE 

COMMUNICATIONS LLC SEEKS EXEMPTION............................................................. 9

THE EXTENT OF RELIEF CUREATIVE COMMUNICATIONS LLC SEEKS AND THE 

REASON CUREATIVE COMMUNICATIONS LLC SEEKS THE RELIEF.................14

THE REASONS WHY GRANTING CUREATIVE COMMUNICATIONS LLC’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ................................................ 19

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY ............................................................................................................. 22

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ............ 36

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT CUREATIVE COMMUNICATIONS LLC’S

REQUEST...........................................................................................................................36

 CONCLUSION............................................................................................................................. 37
3

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
4

SUMMARY

Patrick J. McBride 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 Cureative Communications LLC to operate an Unmanned Aircraft

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

construction sites, building inspections, agricultural lands, healthcare centers, outdoor recreational

facilities, real estate, special events, and landscapes within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Cureative Communications LLC will provide its clients with the highest quality digital 

content for use in their commercial, personal, and non-profit multimedia projects. Cureative 

Communications LLC will bring together years of professional marketing expertise, award-winning 

production talent and state-of-the-art technology to make studio quality productions within reach for

organizations of any size. Cureative Communications LLC has over 10 years recreational/hobby

experience in all aspects of aerial video and photography. The objective of Cureative 

Communications 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

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

• Civil engineering inspection and documentation
5

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS

Cureative Communications 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 Cureative Communications 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, Cureative Communications 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 for an exemption from the requirements of 14 C.F.R §§
6

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, Feather Light 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, Cureative Communications 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.

Cureative Communications LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Cureative Communications 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, Cureative Communications 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

Cureative Communications 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 this
7

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Cureative Communications 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, Cureative 

Communications 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.

Cureative Communications 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 Cureative 

Communications 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, Cureative Communications LLC seeks an exemption from the

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR

conditions. Cureative Communications 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,
8

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

In accordance with 14 C.F.R. § 11.81, Feather Light Media 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: Patrick J. McBride

Cureative Communications LLC

21618 W. 71st Terrace

Shawnee, KS 66218

Email:patrickmcbride@gmail.com
9

B. The Specific Sections Of 14 C.F.R. From Which Cureative 

Communications LLC Seeks Exemption.

1. Cureative Communications 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. Cureative Communications 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

3. Cureative Communications 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.--
10

4. Cureative Communications 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. Cureative Communications 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 that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.
11

6. Cureative Communications 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. Cureative Communications 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. Cureative Communications 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. Cureative Communications 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
12

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

10. Cureative Communications 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.
13

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances .

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

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained 

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

work is performed.

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

and transferred with the aircraft at the time the aircraft is sold.

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

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

service.
14

C.The Extent Of Relief Cureative Communications LLC Seeks And The Reason

Cureative Comminications LLC Seeks The Relief.

1. Extent Of Relief Cureative Communications LLC Seeks And The

Reason Cureative Communications 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 flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire.

As set forth more fully below, Cureative Communications 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 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, Cureative Communications 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 Cureative 

Communications LLC business; and (2) will not carry passengers or property for 

compensation or hire.

2.Extent Of Relief Cureative Communications LLC Seeks And The Reason
15

Cureative Communications 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.”

3.Extent Of Relief Cureative Communications LLC Seeks And The Reason

Cureative Communications 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 
16

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.
17

4.Extent Of Relief Cureative Communications LLC Seeks And Cureative 

Communications 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 Cureative Communications 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).

Cureative Communications 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, Cureative Communications 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 Cureative Communications LLC Seeks And The Reason

Cureative Communications 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), Cureative Communications 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.
18

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 Cureative Communications LLC Seeks And Cureative 

Communications 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. 

Cureative Communications 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 Feather Light Media 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 Cureative Communications LLC’s

proposed operating limitations, ensure that Cureative Communications 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.
19

7.Extent Of Relief Cureative Communications LLC Seeks And The Reason

Cureative Communications 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, Cureative Communications 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, Cureative Communications 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, Feather Light Media will document and maintain all maintenance records for

the DJI Inspire 1

UAS.

D.The Reasons Why Granting Cureative Communications 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 Cureative 

Communications LLC to safely, efficiently, and economically conduct aerial video and 

photography of medical institutions, building inspections, agricultural lands, 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 

Cureative Communications LLC’s proposed operation of the DJI Inspire 1 UAS will be

realized without implicating any privacy issues.
20

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 powered electric 

motors, rather than an internal combustion engine.
21

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 Cureative 

Communications 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 Cureative Communications 

LLC, can remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S.
22

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, Cureative Communications 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 Cureative 

Communications 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, Cureative Communications 

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:
23

(a) In General.--Notwithstanding any other requirement of this subtitle,

and not later than 180 days after the date of enactment of this Act, the

Secretary of Transportation shall determine if certain unmanned

aircraft systems may operate safely in the national airspace system

before completion of the plan

and 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, Cureative Communications 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 a threat to national security considering its size, weight, 

speed, and operational capability.
24

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.

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.

Cureative Communications 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
25

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:

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 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 
26

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions

for extension or amendment to the grant of exemption. If the operator

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

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

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

contacted if questions arise regarding updates or revisions to the operating

documents.

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

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

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

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

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

functional test flight 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.
27

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 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

pre- determined 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.
28

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 immediatelyand/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not

present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential

persons do not present an undue hazard to those persons per §

91.119(a)
29

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.

Cureative Communications 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 Cureative Communications 

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, 

Cureative Communications LLC submits that the additional manned airmanship

experience of a commercially certificated pilot would not correlate to the airmanship

skills necessary for Cureative Communications 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, 11156, 11158, 11159, 11160, 11161).

Cureative Communications 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 
30

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 Cureative Communications 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 FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner’s proposed

operations. The FAA also finds that prior documented flight experience that was

obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted

under the grant of exemption to accomplish the required flight time. During
31

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, Cureative Communications 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, Cureative Communications 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.

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 Cureative Communications 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 
32

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, Cureative Communications 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.

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.
33

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, Cureative Communications 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 Cureative Communications 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, Cureative Communications 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, Cureative Communications 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
34

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

Cureative Communications 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 considered.

In consideration of Cureative Communications LLC proposed operating limitations,

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

Communications 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)
35

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, Cureative Communications 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.

§ 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:
36

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 Leading Edge’s intended operation of

the DJI Inspire1 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 Cureative Communications LLC Seeks Exemption:

Cureative Communications 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 Cureative 

Communications LLC Seeks:

This exemption will permit Cureative Communications 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

Cureative Communications LLC Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of

2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine

if certain UAS may operate safely in the NAS. As such, Cureative Communications LLC

request for exemption may be granted pursuant to the authority of FMRA Section 333
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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, Cureative Communications 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, Cureative Communications 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 Cureative Communications LLC to safely, efficiently, and economically

operate the DJI Inspire 1 UAS commercially within the NAS.
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WHEREFORE, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, Cureative Communications 

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 Cureative Communications LLC to operate the DJI Inspire 1 UAS

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

the United States.

Dated: June 2nd, 2015

Respectfully submitted, 

 Patrick J McBride

Cureative Communications LLC

21618 W. 71st Terrace

Shawnee, KS 66218

Tel: (816) 853-1314

Email:patrickmcbride@gmail.com
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