CellInfo LLC Page 1

September 23, 2015

U.S. Department of Transportation (DOT)

Federal Docket Management System

1200 New Jersey Avenue, S.E.

Washington, D.C. 20590

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), CellInfo, LLC

requests an exemption to permit unmanned aircraft system (UAS) operations as described in this 

petition. CellInfo, LLC requests exemptions in order to legally operate UAS, the DJI Inspire 1, in the 

National Airspace System (NAS) for the purpose of conducting aerial photography and video for site 

inspection of properties including cell phone towers and potential tower locations. 

CellInfo, LLC’s proposed operations will comply with all strict safety standards. Operations will take place 

in sparsely inhabited rural locations or within cell tower easements and occur at altitudes under 400 feet 

above ground level using UAS less than 35 pounds by a pilot who has received the necessary training for

safe operation of the UAS. The proposed operations would not have an impact on any citizen’s privacy 

rights and will be in compliance with all privacy laws. Therefore, granting CellInfo, LLC’s exemption 

request would be in the public interest. 

CellInfo, LLC is committed to finding the best opportunities for new wireless communication facilities 

and providing these opportunities to our trusted partners and developers. We have more signal 

information than any competing firm and unique software that allows us to efficiently identify new high 

opportunity and low risk tower site locations. We provide our sites to developers who get the site on the 

air with major wireless communication service providers such as Verizon, Sprint, T-Mobile, and AT&T. 

The cell tower inspection industry does not operate at maximum efficiency or capability. We strongly 

believe that the utilization of a UAS for asset and location inspections is the necessary step for 

optimization of the industry. 

Seventy-Five Park Plaza

Boston, Massachusetts 02116

Tel +1 603 312 9141

Fax +1 617 322 0150

nate@cellinfo.co

www.cellinfo.co

Petition for Exemption: Section 333 of the FAA Modernization and Reform Act of 2012
CellInfo LLC Page 2

UAS Specifications (DJI Inspire 1)

Aircraft Characteristics

Model T600

Motor Model DJI 3510

Propeller Model DJI 1345

Weight (including battery) 2935 g

Dimensions 438x451x301 mm

Aircraft Performance

Max Pitch Velocity 300°/s

Max Yaw Velocity 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (not recommended)

Max Wind Speed Resistance 10 m/s

Operating Temperature Range -10° to 40°C

Max Flight Time Approximately 18 minutes

Battery

Name Intelligent Flight Battery

Model TB47

Capacity 4500 mAh

Voltage 22.2 V

Battery Type LiPo 6S High voltage battery

Energy 99.9 Wh

Net Weight 570 g

Operating Temperature Range -10° to 40°C

Max Charging Power 180 W
CellInfo LLC Page 3

Exemption Requests

CellInfo, LLC requests exemption from the following regulations as well as any additional regulations

that apply to the operation of the DJI Inspire 1 or similar UASs to the extent necessary to allow CellInfo, 

LLC to perform aerial data collection.

14 CFR § 61.113(a) and (b)

14 CFR § 91.7(a)

14 CFR § 91.119(c)

14 CFR § 91.121

14 CFR § 91.151(a)(1)

14 CFR § 91.405(a)

14 CFR § 91.407(a)(1)

14 CFR § 91.409(a)(1) and (2)

14 CFR § 91.417(a) and (b)

14 CFR 61.113(a) and (b) Private Pilot

CellInfo, LLC will use specially trained staff to conduct the UAS operations. These individuals will each 

hold an FAA issued private pilot certificate and be thoroughly familiar and trained with their UAS’s 

operational and safety procedures. The UAS will not carry property for compensation or hire since it will 

be used solely to evaluate land and infrastructure in the furtherance of CellInfo, LLC’s clients’ primary 

business, the successful operation of infrastructure. However, the employees’ operation of the UAS will 

not be incidental to their employment with CellInfo, LLC, and they will be compensated for such work. 

Without an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. 

Moreover, the risk associated with the contemplated operation is less than that of a traditional aircraft. 

Operations will take place within CellInfo, LLC’s clients’ geographic envelope. The UAS will fly at altitudes 

well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft. Requiring a 

commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose 

additional cost on CellInfo, LLC. Because the contemplated operations would not comply with 

§61.113(b)(1) and none of the other exceptions in paragraph (a) apply, relief is needed from both 

paragraphs.

14 CFR 91.7(a) Civil Aircraft Airworthiness

CellInfo, LLC 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, prior to every flight, CellInfo, LLC 

will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon a visual inspection, in 

order to determine that the UAS and its components are in compliance with its type design and 

operating documents, and that the aircraft can be operated safely.
CellInfo LLC Page 4

14 CFR 91.19(c) Minimum Safe Altitude 

CellInfo, LLC submits that the only relief it requires from §91.119 is from the minimum altitudes listed in 

paragraph (c). Relief is requested because the UAS will be operating at a maximum 400 feet AGL. Since 

operations at 500 feet or higher also pose a heightened risk of collision with another aircraft, safety can 

only be assured through grant of this exemption. The UAS will not be operated within 5 NM of any 

airport and will only be operated with the consent of property manager and/or owner.

14 CFR 91.121 Altimeter Setting

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may 

be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and 

Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data feed, 

which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be 

generated by equipment installed on board the aircraft using GPS triangulation, a digitally encoded 

barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a zero altitude 

initiation point will be established and confirmed for accuracy by the pilot.

14 CRF 91.151 Fuel Requirements

CellInfo, LLC does not intend to use the UAS for point-to-point flights and will not operate out of VLOS. 

The UAS will not require an airport to land. CellInfo, LLC will operate using a pre-planned flight path. As 

such, there is no need for a time-based excess fuel requirement. Rather it should be sufficient to require 

only as much additional excess flight capacity as necessary to safely land the UAS. We believe that 25% 

battery reserve is more than sufficient to meet this objective. The DJI Inspire 1 UAS as employs a “return 

to home” safety feature that will automatically return the UAS to the established “home” position upon 

its battery reaching a critical level. Therefore, an equivalent level of safety is certainly met.

14 CFR 91.405(a), 91.407(a), 91.409 (a), 91.417 (a)&(b) Maintenance Inspections 

CellInfo, LLC believes that an exemption from there regulations is appropriate because the FAA has not 

developed maintenance standards that would allow an operator to meet the part 91 maintenance 

requirements. In particular, there are no individuals authorized by the FAA to approve a UAS for return 

to service under §91.407(a). CellInfo, LLC will maintain the aircraft until it has reasonably determined 

that any needed repairs have been made. However, because of the technological impossibility of the 

meeting the requirements of §91.405(a), 407(a), 409(a), and 417(a)&(b), we believe exemption from 

these provisions is appropriate.
CellInfo LLC Page 5

CellInfo, LLC would like to safely operate a business that employs the utility of a UAS for inspections of 

cell tower infrastructure and potential tower locations. A Section 333 exemption will give our business 

the necessary permissions to legally enter the NAS. Our safe and compliant operations will discourage 

illegal operations and assist in the proper solidification of the changing cell tower inspection industry. 

Please do not hesitate to contact me at the phone number or email address provided above should you 

have any questions or concerns.

Thank you for your consideration.

Sincerely,

Victor Drouin

President

CellInfo, LLC