July 7, 2015

Attn: U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590 

RE: HANSEN PRODUCTION SERVICES REQUESTS AN EXEMPTION FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 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) 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)

Peter Hansen

President

Hansen Production Services

11 Lake Valley Ct

Simpsonville, SC 29681

864-525-5724

hps@hansenproductionservices.com
SUMMARY

HANSEN PRODUCTION SERVICES seeks exemption from the requirements of 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), to operate an Unmanned Aircraft System (DJI Inspire 1) pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

HANSEN PRODUCTION SERVICES to operate an Unmanned Aircraft System (UAS) for 

limited commercial purposes of conducting aerial video and photography of manufacturing 

plants, residential and commercial real estate, civil landscapes and events over certain areas of 

the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

HANSEN PRODUCTION SERVICES has for over twenty years provided its clients (which 

include private sector businesses, non-profits, and ministries) with expertise and knowledge in 

video and multimedia marketing, advertising, public relations and training using advanced 

technologies and solutions. HANSEN PRODUCTION SERVICES has worked on hundreds of 

productions over the past 20 years in all types of locations with a perfect client and employee 

safety record. In the past we have supplied our clients aerial video and photography using 

commercial aircraft. The objective of HANSEN PRODUCTION SERVICES and our Unmanned 

Aircraft System (DJI Inspire 1) aerial operations is to provide a more affordable, high-quality 

production system for a variety of manufacturing, commercial, public, and residential uses, 

specifically targeting 

• Views of commercial and manufacturing facilities

• Facilities of non-profit organizations

• Real-estate marketing 

• Economic development 

• Civic landmarks 

• Special event coverage 

Staff has safely flown small RC electric quadcopters recreationally for approximately 1 year

without incident. 
BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1, UAS

HANSEN PRODUCTION SERVICES seeks an exemption to operate DJI Inspire 1 system for 

compensation or hire within the NAS. The DJI Inspire 1 is vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or 

smart phone systems. The DJI Inspire 1 has a maximum gross weight of approximately 6.5 lb. 

while having a diagonal dimension of 20 inches, a maximum speed of approximately 22 mps and 

a maximum flying height of 400'. The DJI Inspire 1 is equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors. 

The DJI Inspire 1 that will be operated by HANSEN PRODUCTION SERVICES 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, HANSEN PRODUCTION SERVICES, 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, UAS in the National Airspace 

System (NAS), and for an exemption from the requirements of 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). 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, HANSEN PRODUCTION SERVICES’ operation of 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, HANSEN PRODUCTION SERVICES 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. 

HANSEN PRODUCTION SERVICES submits that the requested relief is proper since an 

equivalent level of safety will be ensured. HANSEN PRODUCTION SERVICES will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, HANSEN PRODUCTION SERVICES will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in Command, is requested by HANSEN PRODUCTION SERVICES to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, 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 exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

HANSEN PRODUCTION SERVICES seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Inspire 1 UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, HANSEN PRODUCTION SERVICES

submits that they will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to 

every flight, by determining that the UAS 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. 

HANSEN PRODUCTION SERVICES also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS 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 GPS for active monitoring of the flight 

path. This altitude information, combined with HANSEN PRODUCTION SERVICES’

operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, HANSEN PRODUCTION SERVICES seeks an exemption from the requirements 

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

PRODUCTION SERVICES submits that safety will not be affected by operation of the 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 approximately 20

minutes. Battery power indicators are also able to show exactly how much battery power is left, 

as well as how much time is needed to return safely back to point of take off. 

In accordance with 14 C.F.R. § 11.81, HANSEN PRODUCTION SERVICES 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: 

Peter Hansen

President

Hansen Production Services

11 Lake Valley Ct

Simpsonville, SC 29681

864-525-5724

hps@hansenproductionservices.com
B. The Specific Sections Of 14 C.F.R. From Which HANSEN PRODUCTION SERVICES

Seeks Exemption. 

1. HANSEN PRODUCTION SERVICES Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections 

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

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

(b) 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. 

2. HANSEN PRODUCTION SERVICES 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. 

3. HANSEN PRODUCTION SERVICES Seeks 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. 

4. HANSEN PRODUCTION SERVICES Seeks 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. 

5. HANSEN PRODUCTION SERVICES Seeks 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[.] 

6. HANSEN PRODUCTION SERVICES Seeks Exemption 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[.] 

7. HANSEN PRODUCTION SERVICES 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 

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

21 of this chapter. 

8. HANSEN PRODUCTION SERVICES Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

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

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. 

C. The Extent Of Relief HANSEN PRODUCTION SERVICES Seeks And The Reason 

HANSEN PRODUCTION SERVICES Seeks The Relief. 

1. Extent Of Relief HANSEN PRODUCTION SERVICES Seeks And The Reason 

HANSEN PRODUCTION SERVICES 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, HANSEN PRODUCTION SERVICES submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1

UAS 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, HANSEN PRODUCTION SERVICES 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 HANSEN 

PRODUCTION SERVICES’ business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief HANSEN PRODUCTION SERVICES Seeks And The Reason The 

HANSEN PRODUCTION SERVICES 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 HANSEN PRODUCTION SERVICES 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., Monthly Maintenance Log, and DJI Inspire 1 Instruction 

Manual). 

HANSEN PRODUCTION SERVICES seeks the requested relief because the DJI Inspire 1 UAS 

does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 
Therefore, HANSEN PRODUCTION SERVICES 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. 

3. Extent Of Relief HANSEN PRODUCTION SERVICES Seeks And The Reason 

HANSEN PRODUCTION SERVICES 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), HANSEN PRODUCTION SERVICES 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. 

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. 

4. Extent Of Relief HANSEN PRODUCTION SERVICES Seeks And The Reason

HANSEN PRODUCTION SERVICES Seeks 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 20 minutes. HANSEN PRODUCTION SERVICES seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration of the battery 

powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial video or still 

photo flight operations that HANSEN PRODUCTION SERVICES 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 HANSEN PRODUCTION SERVICES’s proposed operating 

limitations, ensure that HANSEN PRODUCTION SERVICES 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 20

minutes. 

5. Extent Of Relief HANSEN PRODUCTION SERVICES Seeks And The Reason

HANSEN PRODUCTION SERVICES 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, HANSEN PRODUCTION SERVICES requests relief 

from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As 

set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, HANSEN PRODUCTION 

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

maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS 

operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). 

Furthermore, HANSEN PRODUCTION SERVICES will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

D. The Reasons Why Granting HANSEN PRODUCTION SERVICES 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 HANSEN 

PRODUCTION SERVICES to safely, efficiently, and economically perform aerial video and 

photography of commercial and manufacturing facilities, real estate, events and civic landscape 

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 HANSEN 

PRODUCTION SERVICES’s proposed operation of the DJI Inspire 1 UAS will be realized 

without implicating any privacy issues. 

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 ben efit 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 UAS are propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing 

approximately 6.5 pounds at their maximum gross weight with diagonal dimension of 20 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 UAS are 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 HANSEN PRODUCTION 

SERVICES, 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 HANSEN PRODUCTION SERVICES, 

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. 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,

HANSEN PRODUCTION SERVICES’s 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 operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1

Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 
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 HANSEN PRODUCTION SERVICES Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UAS 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, HANSEN PRODUCTION SERVICES’s operation of the 

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

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

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

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

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of 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, HANSEN PRODUCTION SERVICES 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. 

i. Technical Specifications Of The DJI Inspire 1 UAS. The technical 

specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 User 

Manual. 

ii. The DJI Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain 

Within A Defined Operational Area. 

The DJI Inspire 1 UAS may be operated in both manual and global 

positioning 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 Appendix A. 

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 UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Inspire 1 UAS does not reacquire control link data from the GCS, the UAS 

will assume that the Control Link is lost and the 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 at pages 12 through 14 of the DJI Inspire 1 User Manual, 

attached hereto as Appendix A. 

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 at pages 23 through 

29 of the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual is 

attached hereto as Appendix A. 

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

HANSEN PRODUCTION SERVICES’ video production staff will be the only 

persons to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. 

Additionally, a safety observer will assist him at all times during flight time. 

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

Limitations. 

In seeking this exemption, HANSEN PRODUCTION SERVICES proposes to 

commercially operate DJI Inspire 1 UAS for the special purpose of conducting 

aerial video and photography over certain areas of United States, pursuant to the 
following specific operating limitations. 

1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UAS 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1

Unmanned Aircraft Systems. 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 400 feet above 

ground level (AGL), as indicated by the procedures specified in the 

operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the 

PIC at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is 

not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains 

VLOS capability. The SO and PIC must be able to communicate verbally 

at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must 

ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the PIC 

with seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant 

of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It 
is the operator’s responsibility to track such revisions and present updated 

and revised documents to the Administrator upon request. The operator

must also present updated and revised documents if it petitions for 

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

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

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

amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

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

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

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

until the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. The Ground Control Station must be 

included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records. 

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

UAS operation or 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 UAS operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

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

corrective action taken against discrepancies discovered between 

inspections. 

17. The 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 experiencebuilding 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. 

18. UAS operations may not be conducted during night, as defined in 14 

C.F.R. § 1.1. 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. 

19. 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. 

20. 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. 

21. 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. 

22. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

23. 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. 

24. 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. 

25. 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. 

26. 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. 

27. 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. 

28. The UA must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

29. The UAS may not be operated by the PIC from any moving device or 

vehicle. 

30. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, operator 

trainees or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of 

an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

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

where the owner/controller of such vessels, vehicles or structures 

has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that 

it does not 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). 

31. All operations shall be conducted over private or controlledaccess 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. 

32. 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. 

HANSEN PRODUCTION SERVICES 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 HANSEN PRODUCTION SERVICES’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private 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, HANSEN PRODUCTION 

SERVICES submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for HANSEN 

PRODUCTION SERVICES’s 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). 

HANSEN PRODUCTION SERVICES will not allow any PIC to operate the DJI Inspire 1 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI 

Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 

hours as a UAS pilot operating the same make and model of UAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 
during HANSEN PRODUCTION SERVICES’ 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 flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that 

prior documented flight experience that was obtained in compliance with applicable regulations 

would satisfy this requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, HANSEN PRODUCTION SERVICES 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, HANSEN PRODUCTION SERVICES 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 UA to the GCS for 

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

HANSEN PRODUCTION SERVICES’s operation of the DJI Inspire 1 UAS within visual line 

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

The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior 

to each flight, a zero altitude initiation point is automatically established by the UAS 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, HANSEN PRODUCTION SERVICES will ensure that it will safely 

operate the battery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with 

enough battery power to fly for a total duration of 20 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. 

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, HANSEN PRODUCTION SERVICES 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 HANSEN PRODUCTION SERVICES 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., Monthly Maintenance Log, and DJI 

Inspire 1 Instruction Manual). Furthermore, HANSEN PRODUCTION SERVICES 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,

HANSEN PRODUCTION SERVICES will maintain the equivalent level of safety established 

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

are attached hereto as Appendix A and B; a copy of the DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because HANSEN 

PRODUCTION SERVICES 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 HANSEN PRODUCTION SERVICES’s proposed operating limitations, the 

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

PRODUCTION SERVICES submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) 

and 14 C.F.R. § 21.16 entitled Special Conditions, HANSEN PRODUCTION SERVICES

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: 

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 Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

• A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which HANSEN PRODUCTION SERVICES Seeks Exemption: 

HANSEN PRODUCTION SERVICES seeks exemption from the requirements of 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). 

A Brief Description Of The Nature Of The Exemption HANSEN PRODUCTION 

SERVICES Seeks: 

This exemption will permit HANSEN PRODUCTION SERVICES to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video 

and photography over certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To Support HANSEN 

PRODUCTION SERVICES’ 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, HANSEN PRODUCTION SERVICES’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 
11, as set forth above. 

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

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

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

As discussed in detail above, HANSEN PRODUCTION SERVICES will operate the DJI Inspire 

1 UAS 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, HANSEN PRODUCTION SERVICES 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 HANSEN PRODUCTION SERVICES to 

safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the 

NAS. 

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

Modernization and Reform Act of 2012, Section 333, HANSEN PRODUCTION SERVICES

respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 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), and permit Leading Edge to operate the 

DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography 

over certain areas of the United States. 

Dated: July 7, 2015 

Respectfully submitted,

Peter Hansen

President

Hansen Production Services

11 Lake Valley Ct

Simpsonville, SC 29681

864-525-5724

hps@hansenproductionservices.com

Appendices: A – Link to DJI Inspire 1 Manual: Click on link below 

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf