LT,1S 

T. BAKER SMITH, LLC 

4Post 

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SOLUTIONS START HERE 

985.868.1050 (P) 1.866.357.1050 (TF) 

www.tbsmith.com 985.868.5843 (F) 

May 20, 2015 

U.S. Department of Transportation 

Docicet Management System 

1200 New Jersey Ave., 

SE Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reforrn Act and Part 11 of the 

Federal Aviation Regulations 

Dear Madam, Sir, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 C.F.R. Part 11, T Baker Smith, LLC. ("T Baker Smith"), a 

professional services firm offering Planning, Environmental Sciences, Engineering and 

Survey services, and an operator of the DJI Inspire 1 UAV system ("Inspire") seeks an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial 

operation of its Small Unmanned Aircraft Systems ("sUAS"') for aerial photography and 

videography for Local Levee districts, private entities, agriculture, scientific studies, 

wildlife monitoring, and forestry, while also furthering the development of the state 

economies related to the oil and gas industries that could be performed safely and more 

cost effectively with the use of small UAS at low altitude within the U.S. National 

Airspace System as compared to manned aircraft. Operations would be performed only at 

the request of and with the authorization and permission of clients or their authorized 

agents in order to facilitate commerce and raise awareness of the beneficial uses of 

sUAS's so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 

• 14 C.F.R. 45.29 

• 14 C.F.R. 61.23 

• 14 C.F.R. 61.3 

• 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 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203 

• 14 CFR Subpart E(91.401 - 91.417) 

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Urban Planning I Environmental Science & Regulatory Compliance I Land, Hydrographic, & OHshore Surveying I Civil & Coastal Engineering I GIS & Mapping 
'~BS T. BAKEEt SMITH, ~.0 

SOLUTIONS START HERE 

Post Office Box 2266 Houma, LA 70361 

412 South Van Avenue Houma, LA 70363 

985.868.1050 (P) 1.866.357.1050 (7F) 

www.tbstnith.com 985.868.5843 (F) 

Exhibits: 

Due to size of files please go to: http://www.dji.com/product/inspire-1/download to 

review the following DJI- Inspire 1 Manuals and Safety Guidelines. Once website opens, 

under pocuments and Manuals open the following PDF files to review: 

1.) Inspire 1 Quick Start Guide (EN) v1.0 

2.) Inspire 1 User Manual (EN) v1.0 

3.) Inspire 1 Safety Guidelines v 1.0 

4.) Inspire 1 Intelligent Flight Battery Safety Guidelines 

5.) 1345 Propeller Locks Quicic Start Guide 

6.) Inspire 1 Maintenance Manual v 1.0 

Other Inspire 1 Informational Data: 

Please refer to the following DJI Inspire 1 tutorial videos listed at 

http://www.dii.com/product/inspire- I /video 

1.) DJI Inspire 1— Unboxing and Preparing for Safe Flight 

2.) DJI Inspire 1 Tutorial "Pilot App" 

3.) DJI Inspire 1 Tutorial "Updating the Firmware" 

4.) DJI Inspire 1 Tutorial "Dual Operator" 

5.) DJI Inspire 1 Tutorial "How to Fly" 

6.) DJI Inspire 1 Quick Start Guide 

7.) DJI Inspire 1 Set Up & Demo Inc. Overview of Features of the App 

8.) DJI Inspire 1 Flight Simulator for Apple App introduction 

As detailed in this document and the referenced DJI Publications and tutorials, the 

requested exemption would permit the operation of sUAS under controlled conditions in 

airspace that is a.) limited b.) predetermined c.) controlled to access and d.) would 

provide safety enhancements to the already regulated safety practices presently followed 

by manned aircraft as governed by the FAA. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibility to ". .. establish requirements for the safe operation of such aircraft systems 

in the national airspace system." Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

T Baker Smith, LLC 

Attention: Eric Deroche 

PO Box 2266 

Houma, LA 70361 

412 South Van Ave 

Houma, LA 70363 

Telephone: (985) 868-1050 

Email: eric.deroche@tbsmith.com 

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Urban Planning I Environmental Science & Regulatory Compliance I Land, Hydrographic, & OHshore Sunreying I Civil & Coastal Engineering I GIS & Mapping 
C~,T117S T. BAKER SM ITH Post Office Box 2266 Houma, LA 70361 

■ , LLC 412 South Van Avenue Houma, LA 70363 

S O L U T I O N S S T A R T H E R G 

985.868.1050 (P) 1.866.3571050 (TF) 

www.tbsmith.com 985.868.5843 (F) 

A. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exeinpting civil aircraft, as the term is defined under §40101 

of the Act, including sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702 — 44716 of this title if the 

Administrator fmds the exemption in the public interest. 49 U.S.C. §44701(f) See also 

49 USC §44711(a); 49 USC §44704; CFR §91.203(a)(1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs 

may operate in the National Airspace System without creating a hazard to the user, the 

public, or a threat to national security. In making this determination, the Secretary must 

consider: 

a.) The sUAS's size, weight, speed and operational capability 

b.) Whether the sUAS operates within the visual line of sight of the operator 

c.) Whether the sUAS operates outside of highly populated areas and away from close 

proximity to airports 

Reform Act §333(a). If the Secretary determines that a sUAS "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system." Id. §333(c). 

T Baker Smith will be using a quad copter manufactured by DJI. The model being used is 

the Inspire 1. The Inspire 1 weighs less than 8 pounds, including payload. The Inspire 1, 

operating under normal conditions, (no wind) travels at a maximum speed of 49 knots 

and has the capability to hover and move in the vertical and horizontal plane 

simultaneously. The Inspire 1 will operate only in the pilot's visual line of sight at all 

times and will operate only within the limits of the area required to be videoed or 

photographed. Such operations will insure that the Inspire 1 will "not to create a hazard 

to users of the national airspace system or the public." Reform Act Section 333(b). 

Given the small size of the Inspire 1 and the restricted and predetermined environment 

within which it will operate, this application falls squarely within the zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of sUAS to commence immediately. 

Also due to the small size of the Inspire 1 and the low altitudes and restricted areas in 

which it will operate, approval of the application presents no national security issue. 

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Given the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety, grant 

of the requested exemptions is in the public interest. Accordingly, T Baker Smith 

respectfully requests that the FAA grant the requested exemption without delay. 

B. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress's goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the National Airspace System before completion of the rulemalcing required under 

Section 332 of the Reform Act. By granting an exernption the FAA will fulfill 

Congress's intent of allowing UAS to operate with significant safety precautions in low 

risk environments. 

The use of sUAS for videoing or photographing drainage ways, detention ponds and 

survey mapping can reduce the risk of injuries to worlcers attempting to walk in very 

dangerous/difficult terrain found in waterways, detention ponds and surveying areas as 

well as reduce environmental impacts to wetland areas that are very sensitive for wildlife. 

Use of sUASs on construction sites can significantly reduce the risk to workers of falls 

while inspecting, surveying or monitoring site progress. sUASs can inspect, photograph 

and collect data on hard to get to areas that otherwise would require worker inspection. 

Falls are the leading source of workplace fatality and injury on construction sites l , and 

reducing falls through sUASs use for site imaging could save workers lives. 

Manned aircraft pose a threat to the public through potential catastrophic crashes 

resulting in loss of life due to the potential combustible fuel that can explode and burn on 

impact. sUASs pose no such threat since size and lack of combustible fuel alleviates any 

potential threat to the public. 

Finally, sUASs reduce the environmental impact by dramatically decreasing the energy 

used for aerial imaging. The Inspire 1 uses rechargeable lithium ion batteries, as opposed 

to fossil fuels burned in operation of small aircraft and helicopters that are hundreds or 

thousands of times heavier. 

'"Conunonly Used Statistics", Occupational Safety & Health Administration. Available at: https://wwNv.osha.gov/oshstats/commonstats.html 

C. EQUUIVALENT LEVEL OF SAFETY 

T Baker Smith proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

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BS T. BAKER SMITH Post Office Box 2266 Houma, LA 70361 

■ , LLC 412 South Van Avenue Houma, LA 70363 

SOLUTIONS START F3ERE 

985.868.1050 (P) 1.866.3571050 (TF) 

www.tbsmith.com 985.868.5843 (F) 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the already safe operations conducted with helicopters and other 

conventional aircraft. 

T Baker Smith will be bound by the following limitations when conducting its sUAS 

operations under an 

FAA issued exemption: 

1.) The sUAS will be less than 8 pounds. 

2.) Flights will be operated within visual line of sight of the pilot. 

3.) Maximum total flight time for each operational flight will be 14 minutes. The Inspire 

1 calculates battery reserve in real time, and will return to its ground station with at least 

20% battery reserve should that occur prior to the 14 minute limit. 

4.) Flights will be operated normally at approximately 150 feet AGL, never exceeding 

400 feet AGL. 

5.) Horizontal flight speed will not exceed 42 knots. 

6.) Crew for each operation will consist of the sUAS Pilot who will lceep the sUAS 

within his/her visual line of sight at all times and a Visual Observer who will also keep 

the aircraft within line of sight as well as watch for other aircraft or personnel that might 

enter the operations area. 

7.) Pilot and Visual Observer will keep in constant verbal contact throughout the 

duration of each flight. If conventional aircraft or unauthorized personnel enter the flight 

operations area un-expectantly the flight will be terminated immediately. 

8.) The sUAS pilot will be trained in flight, operations, checklists and safety procedures 

as detailed in the DJI Inspire 1 Manuals found at www.dji.cqmZproduct/inspireI/download and DJI Inspire 1 Tutorials found at www.dji.com/product/inspire-1/video. 

9.) The sUAS will only operate in a confined predetermined area around which a 

security perimeter will be established for flight operations. 

10.)Warning signs will be posted in the flight operations area indicating to remain clear 

of the area. 

11.)A briefing will be conducted in regard to the planned sUAS operations prior to each 

flight. It will be mandatory that all personnel who will be present within the boundaries 

of the safety perimeter be present for this briefing. 

12.)All personnel will consent to the UAS flyover on site by waiver, and the operator will 

obtain additional verbal or written consent of all persons who will be allowed within 100 

feet of the flight operation. 

13.)Written and/or oral permission from the relevant property holders will be obtained. 

14.)All required permissions and permits will be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies when required. 

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1'BS T. BAKER SMITH, ~ C 412t SOouth VanxA enue HoumaLLA 70363 

SOLUTIOtUS S5'Al~ Y HERE 

985..868.1050 (P) 1.866.3571050 (TF) 

www.tbsmith.com 985.868.5843 (F) 

15.)The pilot will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight. 

16.) The pilot will have a minimum of 200 flight cycles and 25 hours of total time as a 

sUAS rotocraft pilot and at least 10 hours of sUAS as pilot with the DJI Inspire 1 to be 

utilized for operations under the exemption. 

17.)The pilot will have a minimum of a sport pilot certificate. 

18.)The pilot will perform a minimum of 3 takeoffs and landings within the preceding 90 

days with the Inspire 1 sUAS. 

19.)If the Inspire 1 loses communications or loses its GPS signal, it will automatically 

return to a pre- determined location within the security perimeter and land. Please refer to 

the DJI Inspire 1 User Manual pages 13-16. 

20.)The pilot will abort a flight (return to hoine) in case of unpredicted obstacles or 

emergencies with the push of a button. Please refer to DJI Inspire 1 User Manual page 

28. 

21.)Single family residential and commercial properties to be videoed will be limited to a 

minimum of one acre parcels, in size, which would allow the sUAS to be maneuvered 

around the perimeter of the structure without over flying the structure being videoed as 

well as any structures on adjacent properties thus allowing an emergency landing, if a 

power failure occurs, without any undue hazard to persons or property on the surface. 

22.)sUAS will not be flown within 5 miles of airports as shown on current FAApublished aeronautical charts unless authorization has been granted by the controlling 

ATC facility governing that airport. 

23.)Pilot will preflight/inspect sUAS for airworthiness prior to each flight including the 

Ground Control station. 

24.)Pilot will maintain the Inspire 1 and properly document all maintenance and 

alterations in the Inspire 1 records. 

25.)Pilot will conduct a functional test flight after all maintenance prior to the next 

operational flight and record this flight in the Inspire 1 records/ flight log. 

26.)All flights will be flown only during daylight hours under visual meteorological 

conditions (VMC). 

D. DESCRIPTION OF SPECIFIC REGULATIONS REQUESTING EXEMPTION 

FROM: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by T Baker Smith, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

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12 SOou'th VanXA enue Hou a A790363 

soLUTI®MS sTART tiERC 

985.868.1050 (P) 1.866.3571050 (TF) 

www.tbsmith.com 985.868.5843 (F) 

V.S.C.§44701 (t) and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas 

of the particular sUAS. Our small UAS will be operated at low speed in a controlled 

environment, at least five miles from an airport and more than three miles from any 

densely populated area. An analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate, in the restricted enviromnent and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or helicopter) operating with an airworthiness certificate without the restrictions 

and conditions proposed. 

The DJI Inspire 1 to be operated hereunder is less than 81bs. fully loaded, carries neither 

a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured area. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator and under the 

requirements and in compliance with local public safety requirements, to provide security 

for the area of operation. 

These safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the sUAS, due 

to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and ability to carry an external load no greater than two pounds . 

14 C.F.R. 45.23(b): Marking of the Aircraft 

This regulation requires certain experimental, provisionally certificated aircraft, or 

lightsport category aircraft to be marked with letters between 2 inches and 6 inches high 

"limited," "restricted," "light-sport," "experimental," or "provisional," near each entrance 

to a cabin, cockpit, or pilot station. 

Even though the sUAS will have no airworthiness certificate, an exemption would be 

needed as the sUAS will have no entrance to the cabin, cocicpit or pilot station on which 

the word "Experimental" can be placed. Given the size of the sUAS, two-inch lettering 

would be impossible. 

The FAA has issued an exemption to this regulation: Exemption No. 11109. 

14 C.F.R. 61.113(a) &(b): Private pilot privileges and limitations: Pilot in Command 

Sections 61.113 (a) &(b) limit private pilots to non-commercial operations. Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

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Urban Planning I Environmental Science & Regulatory Compliance I Land, Hydrographic, & OHshore Surveying ( Civil & Coastal Engineering I GIS & Mapping 
TBS T. BAKER SM ITH Post Office Box 2266 Houma, LA 70861 

■ , LLC 412 South Van Avenue Houma, LA 70363 

50LUTIONS START k1ERE 

. 7)

985,868.1050 (P) 1.866.3571050 (TF) 

www.ibsmith.com 985.868.5843 (F) 

equivalent level of safety of current operations by requiring the pilot operating the sUAS 

to have completed sUAS flight training by reviewing each of the three DJI Inspire I 

manuals (attached to this document), review all DJI Inspire 1 tutorial videos listed at 

www.dji.com/product/inspire-1/video . The pilot would also perform a minimum of 200 

flight cycles, 25 hours of total time as a sUAS rotocraft pilot and a minimum of 10 hours 

of piloting the Inspire 1 before performing the first "operational flight" under this 

exemption. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS 

is reinotely controlled with no living thing or cargo on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance. The 

risks associated with the operation of the sUAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a pilot who has met the minimum 

requirements stated above exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) & (b). 

14 C.F.R. 91.7(a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the DJI 

Inspire 1 Manuals, DJI Inspire 1 tutorials and the use of a preflight checklist prior to each 

flight an equivalent level of safety will be provided. 

14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 

The sUAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no 

room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 956513, 10167, 

10167A, 10602, 32827, and 10700. 

14 C.F.R. 91.103(b): Preflight Action 

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. An exemption is needed from this requirement as the pilot will 

take separate preflight actions, including checking for weather conditions, checking flight 

battery requirements, checking takeoff and landing distances, and all other actions in the 

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Preflight Checklist in the DJI Inspire 1 Manuals. These actions will provide an equivalent 

level of safety. 

14 C.F.R. 91.109: Flight Instruction 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. 

By design, sUASs and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has previously 

approved exemptions for aircraft without fully functional dual controls. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a 

pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via 

radio signals from the controller, and by the size and speed of the aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a 

helicopter, with vertical takeoff and vertical landing, which will typically operate at 

altitudes of 150 AGL, so an exemption may be needed to allow such operations. The 

sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area 

with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS 

as well as the location where it is operated. No flight will be taken without the permission 

of the property owner or local officials. Because of the advance notice to the property 

owner and any onsite personnel all affected individuals will be aware of the planned 

flight operations. Compared to flight operations with aircraft or rotorcraft weighing far 

more than the maximum 81bs. proposed herein and carrying flammable fuel, any risk 

associated with our operations is far less than those presently presented with helicopters 

and other conventional aircraft operating at or below 500 AGL. In addition, the lowaltitude operations of the sUAS will ensure separation between these sUAS operations 

and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. 

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The Inspire 1 is limited to operations in predetermined and controlled environments, and 

has a limited range and flight time which require an exemption from 14 CFR 91.151(a). 

The battery powering the Inspire 1 provides approximately 18 minutes of powered flight. 

To meet the 30 minute reserve requirement in 14 CFR §91.151, DJI Inspire 1 flights 

would not be possible. Given the limitations on the DJI Inspire 1 proposed flight area and 

the location of its proposed operations within a predetermined area, a time frame of 14 

minutes for flight in daylight VFR conditions is reasonable. 

T Baker Smith believes that an exeinption from 14 CFR §91.151(a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the DJI Inspire 1, in a 

tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does 

not engender the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the Inspire 1. Additionally, limiting Inspire 1 flights to less than 14 

minutes would greatly reduce the utility for which the exemption will be granted. 

An equivalent level of safety can be achieved by limiting flights to 14 minutes, or enough 

battery reserve to ensure that the Inspire 1 lands at the ground station with at least 20% of 

battery power (as determined by the onboard monitoring system and the pilot), whichever 

happens first. This restriction would be more than adequate to return the Inspire 1 to its 

planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

14 CFR 91.203 (a) &(b): Carrying civil aircraft certification and registration 

The regulation provides in part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate .... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

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The DJI Inspire 1 fully loaded weighs no more than 8 lbs. and is operated without an 

onboard pilot. Therefore there is no ability or place to carry certification and registration 

documents or to display them on the DJI Inspire 1. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

flight control point where the pilot flying the sUAS will have immediate access to them; 

to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700. 

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) &(b): Maintenance inspections 

These regulations require that an aircraft operator or owner "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 ...," and others shall inspect or maintain the aircraft 

in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to T Baker Smith. Maintenance will be 

accomplished by the operator. An equivalent level of safety will be achieved because the 

DJI Inspire 1 is very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If inechanical issues arise the DJI Inspire 1 

can land immediately and will be operating from no higher than 400 feet AGL. The 

operator will ensure that the DJI Inspire 1 is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, 

the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 

C.F.R 45.23 (b); 14 C.F.R. §§ 61.113( a) &(b);91.7(a); 91.9 (b) (2);91.103(b);91.109; 

91.119; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 

(a) &(b) to operate commercially a small unmanned vehicle (81bs. or less) in aerial 

photography and videography for mapping, inspections of drainage ways, detention 

ponds, utilities, construction industries and real estate properties and other flight 

operations that could be performed safely and more cost effectively with the use of small 

UAS at low altitude within the U.S. National Airspace System as compared to manned 

aircraft. 

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Urban Planning I Environmental Science & Regulatory Compliance I Land, Hydrographic, & OHshore Surveying I Civil & Coastal Engineering I GIS & Mapping 
r,T117S T. BAKER SM ITH, LLC 

4Post 

12 Sou'th VanXAvenue HoumaLLA 90363 

SOLUTIOEJS START HERE 

985.868.1050 (P) 1.866.3571050 (TF) 

www.ibsmith.com 985.868.5843 (F) 

Approval of exemptions allowing commercial operations of sUASs enhances safety 

while reducing risk. Manned aircraft create a greater risk because the craft are much 

larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS 

weighing fewer than 8 lbs. and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lacic of combustible fuel carried on board. The sUAS will 

carry no passengers or crew and, therefore, will not expose them to the risks associated 

with manned aircraft flights. 

The operation of small UASs, weighing less than 8 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of 

Part 21 and allowing commercial operations. These lightweight aircraft operate at slow 

speeds, close to the ground, and in a sterile environment and, as a result, are far safer than 

conventional operations conducted with turbine helicopters operating in close proximity 

to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge. Images taken will be of individuals who have also 

consented to being filmed or otherwise have agreed to be in the area where aerial 

photography will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 — size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security — provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

T Balcer Smith's sUAS in above referenced services pursuant to the DJI Manuals 

attached hereto. 

Yours sincerely, 

Eric D 

Director of Office and Field Technology 

P

T Baker Smith, LLC 

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